Our Business Conduct

DRAGOL Energy Resources Limited is a privately held, independent energy company focused on the responsible exploration and production of Africa’s oil and natural gas resources.

Core Ethical Pillars

Our Commitment to integrity, transparency and accountability

Integrity

We act honestly and with candour, transparency, and fairness in all our business dealings.

Compliance Standard :

We prohibit all forms of fraud, theft, and misuse of company assets or information.

Anti-Corruption

We maintain a Zero-Tolerance Policy against all forms of bribery, corruption, extortion, and money laundering.

Compliance Standard :

We adhere to our Anti-Bribery and Corruption (ABC) Policy and comply with all national and international anti-corruption laws.

Conflicts of Interest

“We avoid any activity that could compromise our professional judgment and duty to the Company.”

Compliance Standard :

All actual or potential conflicts must be promptly disclosed to management for review and resolution.

Confidentiality

We protect the Company’s proprietary information, as well as the confidential information of our clients and partners.

Compliance Standard :

We ensure strict handling of all sensitive data, commercial secrets, and intellectual property.

Fair Dealing

We treat all stakeholders—employees, customers, suppliers, and competitors—with dignity, respect, and fairness.

Compliance Standard :

We comply with all labour laws, promote diversity, and prohibit all forms of discrimination and harassment.

Shareholders Engagement

We maintains transparent communication with shareholders by promptly sharing key developments and updates through investor channels and its official website.

Compliance Standard :

We ensure transparency, accountability, and ethical conduct through strict adherence to governance and compliance standards.

Reporting Violations: Any deviation from this Code must be reported immediately through the Company’s established Whistleblowing channels.

Whistleblowing Policy Statement

Dragol Energy Resources Limited is committed to fostering an open, ethical, and accountable work environment. This Policy provides a safe and confidential mechanism for reporting genuine concerns about misconduct, without fear of retaliation.

Purpose

To encourage and enable all employees, contractors, and external stakeholders to report suspected illegal, unethical, or improper conduct related to the Company’s business operations, including:

Reporting Channels & Protection

Confidentiality

All reports will be treated with the utmost confidentiality. Every effort will be made to protect the identity of the whistleblower, unless required by law for an investigation.

Reporting in Good Faith

Reports must be made in good faith, meaning the individual genuinely believes the information and allegations are true. Malicious, false, or vexatious reporting will be subject to disciplinary action.

Non-Retaliation Guarantee

The Company strictly prohibits any form of retaliation, harassment, victimization, or adverse employment action (including demotion, suspension, or termination) against anyone who makes a report in good faith.

Reporting Method

Concerns should be directed to the designated, independent internal channel, such as the Head of Internal Audit or a dedicated, secure third-party Whistleblowing Hotline/Email.

The Board of Directors is responsible for overseeing the implementation of this policy and ensuring all reported matters are independently and promptly investigated.

Health, Safety, and Environment (HSE) Policy Statement

Dragol Energy Resources Limited is committed to conducting its business operations in a manner that ensures the highest standards of safety, protects the health and well-being of its personnel and host communities, and minimizes its impact on the environment.

Zero Harm Goal

We believe that all accidents are preventable. We are committed to the goal of zero harm to people and no damage to the environment.

Compliance

We operate in strict compliance with all relevant Nigerian laws and regulations, including the Petroleum Industry Act (PIA) 2021 and the requirements of the Nigerian Upstream Petroleum Regulatory Commission (NUPRC) and the Nigerian Midstream and Downstream Petroleum Regulatory Authority (NMDPRA).

Decarbonisation & Sustainability

We are committed to aligning our operations with Nigeria's climate objectives, including the reduction of Greenhouse Gas (GHG) emissions and the elimination of routine gas flaring and venting, in line with global ESG standards.

Core HSE Principles

Safety First

All employees, contractors, and third parties have the responsibility and authority to Stop Work if they observe an unsafe act or condition without fear of retribution.

Health Protection

We provide a healthy workplace, proactive medical surveillance, and promote the physical and mental well-being of our entire workforce.

Environmental Stewardship

We are committed to the responsible management of natural resources, prevention of pollution, responsible waste disposal, and continuous reduction of our environmental footprint across all areas of operation.

Training & Competence

We ensure all personnel are properly trained and competent to execute their tasks safely and responsibly.

Powering Africa’s energy future through responsible development of oil, gas, solid minerals, and renewable energy resources.

Corporate Headquarters

POINT House, Plot 129, Bodo Road, GRA Phase 2, Port Harcourt, Rivers State, Nigeria.

Equatorial Guinea Office

Point Engineering EG SL Complejo Siglo XXI Malabo II, EG