Compliance with Laws, Rules, and Regulations

A. CARACAL complies with all laws, rules, and regulations that may apply to it, as such compliance is critically important to CARACAL’s success. All CARACAL Personnel must comply with all laws, rules, and regulations applicable to CARACAL, and must be mindful of laws and regulations applicable anywhere in the world where CARACAL has entities it conducts businesses with.

The applicable laws, rules, and regulations may include but may not be limited to:

i. All laws, regulations, and administrative requirements in any jurisdiction relating to the prevention and/or sanction of bribery and other forms of corrupt behavior or practices (including without limitation the Nigerian Corrupt Practices and other Related Offences Act 2000, the Nigerian Economic and Financial Crimes Commission Act 2003, the Criminal Code Act 2004 -especially Sections 98 – 104, the United Kingdom Bribery Act 2010, and the United States Foreign Corrupt Practices Act 1977); and

ii. Any laws related to terrorism or money laundering, including the Money Laundering (Prohibition) Act 2003; and Terrorism Prevention Act 2011. Others include international laws: European Community Money Laundering Directives, the United Kingdom Money Laundering Regulations 2007, the United Kingdom Proceeds of Crime Act 2002, the United Kingdom Serious Organized Crime and Police Act 2005, the United Kingdom Anti-Terrorism, Crime and Security Act 2001, the United States Executive Order 13224 or any related enabling legislation or any similar executive order, the United States statutes authorizing the establishment of trade and economic sanctions programs enforced by the U.S. Office of Foreign Assets Control of the United States Treasury Department, the United States Bank Secrecy Act of 1970 and Internal Revenue Code, and, to the extent applicable, the USA PATRIOT Act of 2001.

B. Nothing in this Code is meant or intended to subtract from, change or replace the laws that apply to CARACAL, or any CARACAL Personnel. In countries where there are legal requirements and customary business practices that are less restrictive than those detailed in this Code, compliance with this Code is required. Whereas if a specific law contradicts the policies in this Code, compliance with the law is required. In no event will any CARACAL Personnel be required as a part of his/her/its employment or engagement to violate the directives of the law or professional regulations incumbent on him/her/it.

C. CARACAL Personnel are expected to be familiar with the basic laws, regulations, industry standards, and corporate policies that are relevant to the roles they undertake, and countries, states, cities, and local communities in which it operates. Although CARACAL does not expect that its Personnel will know and understand the details of all of these applicable laws and regulations, CARACAL expects that CARACAL Personnel will know enough to determine when to seek advice from supervisors, managers, or appropriate personnel.

D. Lobbying activity on behalf of the interests of CARACAL is permissible. Any CARACAL Personnel who communicates with government officials on issues that affect CARACAL should contact the CEO to ensure that such activities fully comply with the law and that CARACAL’s lobbying efforts are coordinated.