Ethical Conduct D

Appendix E –Ethical Due Diligence Questionnaire

This questionnaire can be modified to the extent the items or requirements are not applicable or suitable to a particular situation, but only with the prior approval of the relevant LCO.

Ethical Due Diligence Questionnaire
This questionnaire is to be completed by all new and existing Counterparties prior to completion of any transaction with BG Group. The signature of a director or officer of a similar seniority is required.
Name of Counterparty:
Business Ownership
1 / Please describe your ownership structure including giving details of all ultimate owners of your business.
2 / Please give details of the proposed contracting company entity and all directors (name, address, contact information, company registration number etc.).
3 / Is your business currently solvent? If no, please explain.
4 / Has your business been insolvent at any point during the last three years? If yes, please explain the history and current status.
Ethical Conduct
5 / Do any of your business’s directors or owners (if privately owned) have any criminal convictions for offences involving corruption or dishonesty? If yes, please provide full details.
6 / With regards to bribery or corruption or dishonest dealings with third parties, in the last 3 years have any external investigations been commenced in which you have been involved or implicated in, or the subject of corrupt or dishonest dealings. If so, please provide details.
Have you been required to disclose any corrupt dealings under relevant laws or stock exchange requirements? If so, please provide details.
7 / Which anti-bribery laws apply to your business (for example the UK Bribery Act and the US Foreign Corrupt Practices Act)? Do you have policies to ensure compliance?
If you are not aware or these laws and if you do not have policies etc. are you willing to adopt the policies that BG has adopted?
8 / Does your business act in a manner consistent with BG Group's Business Principles? Please indicate any areas of inconsistency.(Available at www.bg-group.com)
9 / Do you have a written ethical conduct policy?
10 / What level of engagement does senior management have with any ethical conduct policy? Please provide details.
11 / Do you agree never to make facilitation, or "grease", payments in connection with any business dealings with or on behalf of or related to BG Group?
12 / What is your policy on conducting due diligence on all prospective business Counterparties? How do you carry it out?
13 / Does your business ever make political donations? If yes – please detail.

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Doc Ref: BG-ST-LEG-ECCU-003 Version: 2.1 (01 July 2013)

Author: Edward Wall

14 / A)  A) -Do you employ agents or intermediaries for the proposed relationship with BG group? If so, who, and for what purposes?
B) 
C)  B) -Do you conduct due diligence on all prospective agents or intermediaries who have dealings on your behalf with public officials?
D) 
15 / Do you employ anyone who might (or whose family might) improperly benefit from fees or commissions paid directly or indirectly to BG Group? Please identify all below.
16 / Do you employ, directly or indirectly, any Public Official or person connected (by a family or business relationship) to a Public Official in a position of influence with respect to your business? If yes, please provide details.
17 / Do any of your contractors have family or other relationships that might improperly influence governmental decisions? If yes, please provide details.
18 / Are you the end user of the items to be sold?
19 / If you are not the end user of the items to be sold, do you know the identity (or likely identity) of the end user?
20 / Do you do business in any sanctioned countries?
21 / Have you ever conducted business with a sanctioned entity?
22 / What is the destination country of the items being sold / what is the intended use of the items being sold?
I confirm that the answers given above are correct.
______
Name:
Position: Must be a director or officer of similar seniority
Date:
NOTE: If completed and submitted electronically, confirmation of the authority of the sender as an authorised representative of the company is acceptable.

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Doc Ref: BG-ST-LEG-ECCU-003 Version: 2.1 (01 July 2013)

Author: Edward Wall