The Internal Audit unit operates as an autonomous, objective assurance, and consulting department with the goal of enhancing Diakrino’s operations.
Its purpose is to assist Diakrino in achieving its objectives by implementing a systematic, disciplined approach to assess and enhance the effectiveness of risk management, control, and governance processes. The department evaluates the sufficiency, suitability, effectiveness, and integrity of internal controls pertaining to financial reporting and business operations, offering recommendations where weaknesses are identified.
The Internal Audit function conducts a diverse array of audit services, encompassing financial audits, compliance audits, operational audits, information technology audits, and investigations.

A range of decisions are specifically reserved for the Board to ensure it retains proper direction and control of the Group.
The Board is authorized to delegate some of these functions to executive directors who are responsible for the day-to-day management of the business.
The document delegating Authority to certain directors and committees sets the financial limits on the decisions that can be taken by the Executive Directors and the various committees of the board.

Periodic reviews are conducted by independent professional consultants to evaluate the board, its committees and individual directors in the performance of  their duties to maximum capabilities. The evaluation is guided by the UK Corporate Governance Code (FRC) 2010

The evaluation reviews the performance of the Board and its committees by assessing:

• The directors’ understanding of their fiduciary roles and responsibilities;
• The ability of the Board of directors to manage its own activities;
• The Board’s role in the strategy process;
• The  role of the Board in setting and communicating standards of ethical conduct;
• The Board’s role in monitoring management and evaluating its performance against set goals;
• The responsibility of the Board towards shareholders and other stakeholders and accountability for their interests.
• The balance of skills within the board;
• The attributes required for any new appointments;
• The practices and procedures in place to improve board efficiency and effectiveness.

The Board meets at least once every quarter. Additional meetings are scheduled whenever matters which require the attention of the Board arises. The office of the Company Secretary circulates the agenda for each meeting along with all documents that the Directors would be required to deliberate upon in advance of the meeting. This enables the directors to apprise themselves of the matters to be discussed and contribute effectively at Board meetings.

As permitted under the Articles of Association of the Company, the Board is assisted by its standing Committees established in order to make the decision-making process of the Board more efficient and support the vision and activities of the company. 

All the Committees have terms of references that guide the execution of their duties. Each Committee reports to the Board of Directors by providing updates on its activities and draft recommendations on matters that require board approval. The following Committees are currently operating at the Board level:

• Board Audit, Strategic, Planning and Finance Committee
• Statutory Audit Committee
• Risk, Environmental, Social and Governance Committee
• Governance and Nominations Committee

Directors’ Induction Program: Newly appointed members of the Board are educated on the provisions of the company’s Code of Business Conduct & Ethics and other related policies as part of the induction program. 

Continuing Education: Directors attend training and conferences on a wide-range of topics aimed at supporting their professional development and educating on recent regulatory changes that may affect the Company. The Board evaluation process also identifies skill gaps on the board and recommends ways to bridge those gaps. Individual development plans can then be drawn up for each director and implemented to bridge any knowledge gaps.

The Ethics and Compliance Program strives to promote ethical conduct in all business dealings, train employees on ethical standards. The program is part of the effort to mitigate risks and address our core values and is applicable to all directors, managers, employees and all third parties who work for and on behalf of Diakrino.

The Company is committed to doing business in a clear, open and transparent manner and the global fight against corruption.

The Company’s Governance Office, led by the Company Secretary & Chief Compliance Officer is responsible for developing and implementing policies and the compliance infrastructure.

1.1- Introduction

This Corporate Governance Policy establishes the principles and practices that govern the operations of Diakrino (“the Company”). The policy ensures that the Company is managed and operates in a manner that enhances shareholder value while respecting the interests of all stakeholders, including employees, customers, suppliers, and our host community.

1.2 – Board of Directors

1.2.1 – Composition and Independence

• The Board of Directors (“the Board”) shall consist of a majority of independent, non-executive directors to ensure objective oversight.
• The Board shall be composed of individuals with diverse backgrounds, skills, and experiences to provide balanced and effective leadership.

1.2.2 – Roles and Responsibilities

• The Board is responsible for overseeing the Company’s management and business affairs, including setting strategic direction, approving major initiatives, and monitoring performance.
• Directors are expected to act in the best interests of the Company and its shareholders, with integrity and due diligence.

1.2.3 – Committees

• The Board shall establish committees to focus on specific areas of governance, such as Audit, Compensation, and Nominations. Each committee shall have a charter outlining its duties and responsibilities.

1,3 – Ethical Conduct and Compliance

1.3.1 – Code of Conduct

• The Company shall maintain a Code of Conduct that sets forth the ethical standards and expectations for all employees, officers, and directors. 
• The Code of Conduct shall be communicated to all personnel and compliance shall be monitored regularly.

1.3.2 – Compliance Program

• The Company shall implement a comprehensive compliance program to ensure adherence to legal and regulatory requirements.
• Regular training and education on compliance issues shall be provided to all employees.

1.4 – Risk Management

1.4.1 – Risk Assessment

• The Company shall adopt a risk management framework to identify, assess, and manage risks that could impact its operations and objectives.
• The Board and management shall regularly review the risk management processes and update them as necessary.

1.4.2 – Internal Controls

• Effective internal controls shall be established to safeguard the Company’s assets and ensure the accuracy and reliability of financial reporting.
• The Audit Committee shall oversee the internal control system and ensure that it operates effectively.

1.5 – Shareholder Rights and Relations

1.5.1 – Shareholder Meetings

• The Company shall facilitate the participation of shareholders in annual and special meetings, ensuring they can vote on key issues and ask questions.
• Information relevant to shareholders shall be provided in a timely and transparent manner.

1.5.2 – Communication

• The Company shall maintain open and effective communication channels with shareholders and other stakeholders.
• Regular updates on the Company’s performance, strategy, and other significant developments shall be provided through various communication platforms.

1.6 – Sustainability and Social Responsibility

1.6.1 – Environmental Responsibility

• The Company is committed to sustainable practices that minimize environmental impact. 
• Initiatives to reduce energy consumption, waste, and emissions shall be implemented and reported regularly.

1.6.2 – Social Responsibility 

• The Company shall engage in socially responsible activities that benefit the community and society at large.
• Ethical labour practices, including diversity, equity, and inclusion, shall be promoted within the Company.

1.7 – Performance Evaluation

1.7.1 – Board Evaluation

• The performance of the Board and its committees shall be evaluated annually to ensure effectiveness and identify areas for improvement.
• Independent external consultants may be engaged to assist in the evaluation process.

1.7.2 – Management Evaluation

• The performance of the CEO and senior management shall be reviewed regularly by the Board.
• Clear performance metrics and objectives shall be established to guide the evaluation process.

1.8 – Policy Review

This Corporate Governance Policy shall be reviewed periodically by the Board to ensure its relevance and effectiveness. Amendments shall be made as necessary to reflect changes in regulations, best practices, and the Company’s operational environment.

2.1 – Introduction

Diakrino (“the Company”) recognizes that effective risk management is essential to achieving its strategic objectives and sustaining its competitive advantage. This Risk Management Policy outlines the framework and procedures for identifying, assessing, managing, and monitoring risks across the organization.

2.2 – Purpose

The purpose of this policy is to:

• Establish a structured approach to risk management that supports decision-making.
• Protect the Company’s assets, reputation, and stakeholders.
• Ensure compliance with applicable laws, regulations, and standards.
• Promote a risk-aware culture throughout the organization.

2.3 – Scope

This policy applies to all employees, contractors, and business partners involved in the Company’s operations worldwide. It covers all types of risks, including strategic, operational, financial, compliance, and reputational risks.

2.4 – Risk Management Framework

2.4.1 – Risk Identification

• Conduct regular risk assessments to identify potential threats to the Company’s operations, projects, and objectives.
• Utilize various methods for risk identification, including brainstorming sessions, SWOT analysis, and industry benchmarking.

2.4.2 – Risk Assessment

• Evaluate the identified risks based on their likelihood and potential impact on the Company.
• Use qualitative and quantitative analysis techniques to prioritize risks. 

2.4.3 – Risk Mitigation and Control

• Develop and implement strategies to manage risks within acceptable levels. These strategies may include risk avoidance, reduction, transfer, or acceptance.
• Ensure that appropriate controls and procedures are in place to mitigate identified risks.

2.4.4 – Risk Monitoring and Reporting

• Continuously monitor the risk environment and the effectiveness of risk management strategies.

• Report significant risks and the status of risk management activities to the Risk Management Committee and the Board of Directors on a regular basis.

2.5 – Roles and Responsibilities

2.5.1 – Board of Directors

• Provide oversight and governance of the risk management framework.
• Review and approve the Risk Management Policy and ensure its effective implementation.

 2.5.2 – Risk Management Committee

• Assist the Board in overseeing the Company’s risk management activities.
• Review risk reports and ensure that significant risks are being managed appropriately.

2.5.3 – Executive Management

• Implement the risk management framework and integrate risk management into the Company’s strategic planning and operations.
• Promote a risk-aware culture within the organization.

2.5.4 – Risk Management Department

• Develop and maintain the risk management framework, policies, and procedures.
• Facilitate risk assessments and provide guidance on risk management practices.
• Monitor and report on the effectiveness of risk management activities.

2.5.5 – Employees and Contractors

• Identify and report potential risks in their areas of responsibility.
• Comply with the Company’s risk management policies and procedures.

2.6 – Risk Categories

The Company recognizes several key risk categories, including but not limited to:

2.6.1 – Strategic Risks

• Market fluctuations and commodity prices.
• Regulatory and political changes.
• Competitive pressures and industry trends.

2.6.2 – Operational Risks

• Exploration and production challenges.
• Equipment failure and maintenance issues.
• Health, safety, and environmental incidents.

2.6.3 – Financial Risks

• Exchange rate and interest rate volatility.
• Credit and liquidity risks.
• Financial reporting and control risks.

2.6.4 – Compliance Risks

• Adherence to laws and regulations in all jurisdictions.
• Compliance with internal policies and ethical standards.
• Anti-bribery and corruption risks.

2.6.5 – Reputational Risks

• Public perception and media scrutiny.
• Stakeholder relationships and community impact.
• Corporate social responsibility and sustainability practices.

2.7 – Risk Appetite and Tolerance

The Company shall define its risk appetite and tolerance levels, outlining the types and levels of risk it is willing to accept in pursuit of its objectives. These levels shall be reviewed periodically and adjusted as necessary to align with the Company’s strategic direction.

2.8 – Training and Awareness

The Company shall provide regular training and awareness programs on risk management to ensure that all employees and contractors understand their roles and responsibilities in the risk management process.

2.9 – Policy Review

This Risk Management Policy shall be reviewed annually or as needed to ensure its relevance and effectiveness. Any changes to the policy shall be approved by the Board of Directors.

3.1 – Introduction

Diakrino (“the Company”) is committed to conducting its business with the highest standards of ethics, integrity, and compliance with all applicable laws and regulations. This Code of Conduct and Ethics Policy (“the Code”) sets forth the principles and guidelines that all employees, contractors, and business partners are expected to follow.

3.2 – Purpose

The purpose of this Code is to:

• Promote ethical conduct and integrity in all business activities.
• Ensure compliance with legal and regulatory requirements.
• Protect the Company’s reputation and assets.
• Foster a culture of transparency, accountability, and respect.

3.3 – Scope

This Code applies to all employees, contractors, officers, and directors of the Company, as well as business partners engaged in activities on behalf of the Company.

3.4 – Ethical Principles

3.4.1 – Integrity and Honesty

• Conduct all business activities with integrity and honesty.
• Avoid any form of dishonesty, fraud, or deceit in dealings with stakeholders.

3.4.2 – Compliance with Laws and Regulations

• Comply with all applicable laws, regulations, and industry standards in every jurisdiction where the Company operates.
• Stay informed about changes in laws and regulations that affect the Company’s operations.

3.4.3 – Fair Dealing

• Engage in fair and transparent business practices.
• Treat all stakeholders, including customers, suppliers, and competitors, with fairness and respect.

3.4.4 – Confidentiality and Data Protection

• Protect confidential and proprietary information from unauthorized disclosure.
• Comply with data protection laws and Company policies on the handling of personal and sensitive information.

3.4.5 – Conflict of Interest

• Avoid situations where personal interests conflict with the interests of the Company.
• Disclose any potential conflicts of interest to a supervisor or the Compliance Department.

3.4.6 -Anti-Bribery and Corruption

• Prohibit any form of bribery, corruption, or improper payments in business dealings.
• Adhere to the Company’s Anti-Bribery and Corruption Policy and report any suspicious activities.

3.4.7 -Health, Safety, and Environment (HSE)

• Prioritize health, safety, and environmental protection in all operations.
• Comply with HSE regulations and Company policies to prevent accidents and minimize environmental impact.

3.4.8 -Respect and Diversity

• Foster a work environment that values diversity, inclusion, and respect for all individuals.
• Prohibit any form of discrimination, harassment, or bullying.

3.4.9 – Insider Trading

• Refrain from trading in the Company’s securities based on material non-public information.
• Comply with the Company’s Insider Trading Policy and applicable securities laws.

3.5 – Responsibilities

3.5.1 – Board of Directors

• Provide oversight and governance of the Company’s ethical standards and compliance programs.
• Ensure the effective implementation of the Code.

3.5.2 – Executive Management

• Promote a culture of ethics and integrity throughout the organization.
• Implement policies and procedures to support compliance with the Code.

3.5.3 – Employees and Contractors

• Understand and adhere to the principles of the Code in all business activities.
• Report any violations or concerns related to the Code to a supervisor or the Compliance Department.

3.5.4 – Compliance Department

• Develop, implement, and monitor the Company’s compliance programs.
• Provide guidance and training on ethical and compliance-related matters.

3.6 – Reporting and Whistleblowing

The Company encourages the reporting of any unethical or illegal conduct. Reports can be made through the following channels:

• Directly to a supervisor or manager.
• To the Compliance Department via email or hotline.
• Anonymously through the Company’s whistleblowing system.

The Company will investigate all reports promptly and thoroughly. Retaliation against individuals who report concerns in good faith is strictly prohibited.

3.7 – Disciplinary Actions

Violations of the Code may result in disciplinary actions, up to and including termination of employment or contract. The specific disciplinary measures will depend on the severity and circumstances of the violation.

3.8 – Training and Awareness

The Company will provide regular training and resources to ensure that all employees and contractors understand the Code and their responsibilities. This includes onboarding training for new hires and periodic refresher courses.

3.9 – Policy Review

This Code of Conduct and Ethics Policy will be reviewed annually or as needed to ensure its continued relevance and effectiveness. Any changes to the Code will be approved by the Board of Directors.

4.1 – Introduction

 The purpose of this IT Governance Policy is to establish a framework for the management, control, and oversight of IT resources within Diakrino (“the Company”). This policy aims to ensure that IT supports the Company’s strategic objectives, complies with regulatory requirements, and effectively manages risks.

4.2 – Scope

This policy applies to all IT systems, infrastructure, data, and services within the Company. It covers all employees, contractors, and third-party service providers involved in the management and use of IT resources.

4.3 – Objectives

• Align IT strategy with the Company’s business objectives.
• Ensure effective and efficient use of IT resources.
• Manage IT risks and ensure regulatory compliance.
• Foster a culture of continuous improvement and innovation in IT.

4.4 – IT Governance Framework

The IT Governance Framework is based on industry best practices, including COBIT, ITIL, and ISO/IEC 38500. The framework includes the following key components:

4.4.1 –  IT Steering Committee

• Comprised of senior executives, including the CIO, CFO, COO, and representatives from key business units.
• Responsible for overseeing IT strategy, investments, and performance.
• Meets quarterly to review IT projects, budgets, and risk management activities.

4.4.2 – IT Strategy and Planning

• IT strategy is developed in alignment with the Company’s business strategy and reviewed annually.
• A strategic IT plan is created, outlining key initiatives, resource requirements, and performance metrics.

4.4.3 – IT Policies and Procedures

• Comprehensive IT policies and procedures are developed to guide the management of IT resources.
• Policies are reviewed and updated regularly to reflect changes in technology, business needs, and regulatory requirements.

4.4.4 – IT Risk Management

• An IT risk management process is established to identify, assess, and mitigate IT risks.
• Regular risk assessments are conducted, and a risk register is maintained.
• Business continuity and disaster recovery plans are developed and tested annually.

4.4.5 – IT Performance Management

• Key performance indicators (KPIs) are defined to measure the effectiveness and efficiency of IT services.
• Regular performance reviews are conducted, and corrective actions are taken as needed.
• IT service levels are agreed upon with business units and monitored regularly.

4.4.6 – IT Compliance and Audit

• IT compliance is ensured with applicable laws, regulations, and industry standards, including data protection and cybersecurity regulations.
• Regular IT audits are conducted by internal and external auditors to assess compliance and identify areas for improvement.

4.5 – Roles and Responsibilities

4.5.1 – Board of Directors

• Provides overall oversight of IT governance and ensures alignment with business strategy.
• Reviews and approves the IT strategy and major IT investments.

4.5.2 – Chief Information Officer (CIO)

• Develops and implements the IT strategy and governance framework.
• Ensures the effective management of IT resources and alignment with business objectives.
• Reports to the IT Steering Committee and the Board on IT performance and risks.

4.5.3 – IT Steering Committee

• Oversees the implementation of the IT strategy and governance framework.
• Reviews and approves IT projects, budgets, and risk management activities.

4.5.4 – IT Management

• Implements IT policies and procedures and ensures compliance.
• Manages IT resources, projects, and services in line with the IT strategy.
• Conducts regular performance reviews and risk assessments.

4.5.5 – Business Units

• Collaborate with IT to define service levels and requirements.
• Participate in IT planning and performance reviews.
• Ensure compliance with IT policies and procedures within their areas of responsibility.

4.6 – IT Resource Management

• IT resources, including staff, hardware, software, and data, are managed effectively to support business objectives.
• Resource allocation is aligned with strategic priorities and reviewed regularly.

4.7 – IT Security and Data Protection

• Robust IT security policies and controls are implemented to protect the Company’s information assets.
• Data protection measures are in place to ensure compliance with relevant data privacy regulations.

4.8 – Continuous Improvement

• A culture of continuous improvement is fostered through regular reviews, feedback, and benchmarking against industry best practices.
• Innovation in IT is encouraged to drive business value and competitive advantage.

4.9 – Policy Review

This IT Governance Policy will be reviewed annually or as needed to ensure its continued relevance and effectiveness. Any changes to the policy will be approved by the IT Steering Committee and the Board of Directors.

5.1 – Introduction

This Data Management Policy establishes the framework for managing data at Diakrino. It aims to ensure the integrity, availability, and confidentiality of data, enabling informed decision-making and compliance with regulatory requirements.

5.2 – Purpose

The purpose of this policy is to:

• Define the principles and guidelines for effective data management.
• Ensure data quality, security, and privacy.
• Support regulatory compliance and risk management.
• Facilitate data-driven decision-making.

5.3 – Scope

This policy applies to all employees, contractors, and third-party service providers involved in the collection, processing, storage, and use of data at [Company Name]. It encompasses all types of data, including but not limited to personal, financial, operational, and client data.

5.4 – Data Management Principles

5.4.1 – Data Governance

• Establish a Data Governance Committee responsible for overseeing data management practices.
• Define roles and responsibilities for data governance.
• Align data governance policies with business objectives and regulatory requirements. 

5.4.2 – Data Quality

• Implement procedures to ensure data accuracy, completeness, and consistency.
• Conduct regular data audits and cleaning processes.
• Establish and monitor data quality metrics.

5.4.3 – Data Security

• Protect data against unauthorized access, breaches, and other security threats.
• Implement access controls, encryption, and other security measures.
• Regularly update security policies to address emerging threats.

5.4.4 – Data Privacy

• Comply with relevant data privacy regulations (e.g., GDPR, CCPA).
• Implement procedures for data subject rights, including access, correction, and deletion.
• Ensure transparency in data collection and processing practices.

5.4.5 – Data Lifecycle Management

• Manage data throughout its lifecycle, from creation to disposal.
• Implement data retention, archiving, and destruction procedures.
• Ensure compliance with regulatory requirements for data storage and disposal.

5.4.6 – Data Access and Sharing

• Define access controls and permissions for data.
• Ensure secure and appropriate data sharing within and outside the organization.
• Establish data sharing agreements with third parties as necessary.

5.4.7 – Data Usage and Analytics

• Promote data usage for informed decision-making and business intelligence.
• Implement tools and processes for data analysis and reporting.
• Ensure data usage complies with ethical standards and privacy regulations.

5.5 – Roles and Responsibilities

5.5.1 – Data Governance Committee

• Provide strategic direction and oversight for data management.
• Approve data management policies and procedures.
• Monitor compliance with data governance practices.

5.5.2 -Data Stewards

• Ensure data quality and integrity within their domains.
• Implement data management practices and procedures.
• Monitor and report on data quality metrics.

5.5.3 – Data Owners

• Define data access and usage policies.
• Ensure compliance with data privacy and security regulations.
• Collaborate with IT and data stewards to maintain data quality.

5.5.4 – IT Department

• Implement and maintain data management systems and tools.
• Ensure data security measures are in place and updated.
• Support data owners and stewards in managing data throughout its lifecycle.

5.5.5 – All Employees

• Adhere to data management policies and procedures.
• Ensure data is collected, processed, and used in compliance with company policies.
• Report any data breaches or incidents to the IT department immediately.

5.6 – Training and Awareness

• Provide ongoing training on data management policies and best practices.
• Ensure all employees understand their roles and responsibilities in data management.
• Promote a culture of data quality and security within the organization.

5.7 – Monitoring and Review

• Regularly review and update the Data Management Policy to reflect changes in the business environment, technology, and regulatory requirements.
• Monitor compliance with the policy and report on data management performance to senior management.
• Conduct regular audits of data management practices and procedures.

5.8 – Conclusion

By adhering to this Data Management Policy, Diakrino commits to maintaining high standards of data management. This ensures that data is accurate, secure, and used responsibly, supporting the organization’s strategic objectives, regulatory compliance, and data-driven decision-making.

Welcome to Diakrino. We are committed to protecting your privacy and ensuring that your personal information is handled in a safe and responsible manner. This Privacy Policy outlines how we collect, use, disclose, and protect your information.

Our Responsibilities

If you are a visitor to our website we act as the ‘data controller’ of personal data. This means we determine how and why your data are processed.

Your Responsibilities

• Read this Privacy Policy
• If you provide us with personal information about other people, please ensure you are authorized to share their information. If others give us your information, we will only use that information for the specific reason for which it was provided to us.
• By submitting the information, you confirm that you have the right to authorize us to process it on your behalf in accordance with this Privacy Policy.

Information We Collect

We may collect and process the following information:

• Personal Information: Name, email address, phone number, postal address, and other contact details.
• Technical Information: IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
• Usage Data: Information about how you use our website, products, and services.
• Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.

How We Collect Information

We use different methods to collect data from and about you including:

• Direct interactions: You may give us your personal information by filling in forms or by corresponding with us by post, phone, email, or otherwise.
• Automated technologies or interactions: As you interact with our website, we may automatically collect Technical   Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and   other similar technologies.
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources.

How We Use Your Information

We use the information we collect in the following ways:

• To provide, operate, and maintain our website and services.
• To improve, personalize, and expand our website and services.
• To understand and analyze how you use our website and services.
• To develop new products, services, features,

Your Privacy choices

• You can choose not to provide us with personal data and continue to use our website only.
• You can turn off, block or delete cookies in your browser by changing its settings. Yes, if you do this, you can continue to use our website.
• You can ask us not to use your data for marketing since we will inform you if we intend to before collecting. Nonetheless, if you inadvertently get a marketing email from us, please use the opt-out/unsubscribe feature available in the email.

How Secure is the Data We Collect?

We have physical, electronic, and managerial procedures to safeguard and secure the information we collect

Your Privacy rights

• You can exercise your rights by sending us an email at info@diakrino.com You have the right to access information we hold about you. 
• We will provide you with the information within one month of your request, unless doing so would adversely affect the rights and freedoms of other (e.g. another person’s confidentiality or intellectual property rights). We’ll tell you if we cannot meet your request for that reason.
• You have the right to make us correct any inaccurate personal data about you.

• You can object to us using your data for profiling you or making automated decisions about you.

• We may use your data to determine whether we should let you know information that might be relevant to you (for example, tailoring emails to you based on your behavior).

• You have the right to port your data to another service. We will give you a copy of your data in CSV or JSON so that you can provide it to another service. If you ask us and it is technically possible, we will directly transfer the data to the other service for you. We will not do so to the extent that this involves disclosing data about any other individual.

• You have the right to be ‘forgotten’ by us.You can do this by asking us to erase any personal data we hold about you, if it is no longer necessary for us to hold the data for purposes of your use of Diakrino

• You have the right to lodge a complaint regarding our use of your data. Please tell us first, so we have a chance to address your concerns.

How Long Do We Store Your Data?

We will archive and stop actively using any personal identifiable information about you within 6 months from the last time you used the Diakrino website. We will delete your personal data from our archives no later than 6 years from the last time you used the Diakrino website.

Where Do We Store the Data?

The personal data we collect is processed at our offices in the United Kingdom and in any data processing facilities operated by the internet service providers.

Cookies

We use cookies. Unless you adjust your browser settings to refuse cookies, we (and these third parties) will issue cookies when you interact with the Diakrino website. These may be ‘session’ cookies, meaning they delete themselves when you leave the website, or ‘persistent’ cookies which do not delete themselves and help us recognize you when you return so we can provide a tailored service.

How Can I Block Cookies?

You can block cookies by activating a setting on your browser allowing you to refuse the setting of cookies. You can also delete cookies through your browser settings. If you use your browser settings to disable, reject, or block cookies (including essential cookies), certain parts of our website will not function fully. In some cases, our website may not be accessible at all. Please note that where third parties use cookies, we have no control over how those third parties use those cookies

Third Parties Who Process Your Data

Businesses often use third parties to help them host their application, communicate with customers, power their emails etc. We partner with third parties who we believe are the best in their field at what they do. When we do this, sometimes it is necessary for us to share your data with them in order to get these services to work well. Your data is shared only when strictly necessary and according to the safeguards and good practices detailed in this Privacy Policy.

Which Specific Cookies Do We Use

Introduction

Diakrino is committed to conducting its operations in a manner that promotes environmental stewardship, social responsibility, and sound governance. This policy outlines our principles and practices to ensure that our oil and gas exploration activities align with the highest standards of ESG performance.

Environmental Policy

1. Environmental Stewardship: We are committed to minimizing our environmental footprint through responsible resource management and operational practices.
2. Regulatory Compliance: We comply with all applicable environmental laws, regulations, and standards. We strive to exceed these requirements through our proactive environmental management systems.
3. Pollution Prevention: We implement best practices to prevent pollution, reduce emissions, and manage waste effectively. This includes the use of advanced technologies to minimize environmental impact.
4. Resource Efficiency: We promote the efficient use of natural resources, including energy, water, and materials, across all our operations.
5. Biodiversity Conservation: We are committed to protecting biodiversity and ecosystems in areas where we operate. We conduct environmental impact assessments and implement measures to mitigate any adverse effects.

Social Policy

1. Community Engagement: We engage with local communities to understand their needs and concerns. We aim to build positive relationships through transparent communication and meaningful collaboration.
2. Human Rights: We respect and uphold human rights in all our operations. We are committed to fair labour practices and ensuring a safe and healthy working environment for all employees.
3. Health and Safety: We prioritize the health and safety of our employees, contractors, and communities. We implement rigorous health and safety standards and provide regular training to prevent workplace incidents.
4. Local Development: We contribute to the socio-economic development of the regions where we operate. This includes investing in local infrastructure, education, and healthcare initiatives.
5. Diversity and Inclusion: We foster a diverse and inclusive workplace where all employees are valued and respected. We are committed to equal opportunity and non-discrimination.

Governance Policy

1. Ethical Conduct: We uphold the highest standards of integrity and ethical conduct in all our business dealings. This includes zero tolerance for corruption, bribery, and unethical behaviour.
2. Board Oversight: Our Board of Directors is responsible for overseeing the implementation of our ESG policies. This includes regular review and assessment of ESG performance.
3. Risk Management: We integrate ESG considerations into our risk management processes. This ensures that we identify and mitigate potential ESG risks effectively.
4. Transparency and Reporting: We are committed to transparent reporting of our ESG performance. This includes regular disclosure of our environmental impact, social contributions, and governance practices.
5. Continuous Improvement: We strive for continuous improvement in our ESG practices. This includes setting measurable targets, monitoring progress, and implementing corrective actions where necessary.

Implementation and Accountability

1. Responsibilities: All employees, contractors, and partners are expected to adhere to this ESG policy. Senior management is responsible for ensuring compliance and promoting a culture of sustainability.
2. Training and Awareness: We provide regular training and awareness programs to educate employees and stakeholders about our ESG commitments and practices.
3. Monitoring and Evaluation: We regularly monitor and evaluate our ESG performance. This includes conducting audits, assessments, and stakeholder feedback to ensure alignment with our ESG objectives.
4. Stakeholder Engagement: We engage with stakeholders, including investors, regulators, and communities, to discuss our ESG performance and gather input for continuous improvement.

Conclusion

Diakrino is dedicated to achieving excellence in environmental, social, and governance performance. By integrating ESG principles into our operations, we aim to create long-term value for our stakeholders and contribute to a sustainable future.

Introduction

Diakrino is committed to maintaining the highest standards of human resource (HR) governance to ensure fairness, transparency, and compliance with applicable laws and regulations. This policy outlines the principles and practices that guide our HR governance to support the strategic goals of our oil and gas exploration activities.

Objectives

• Ensure compliance with legal and regulatory requirements in all HR practices.
• Promote fairness and equality in the treatment of all employees.
• Foster a safe, healthy, and inclusive work environment.
• Support the professional development and well-being of our workforce.
• Align HR practices with the company’s strategic goals and values.

Policy Framework

1. Compliance and Legal Framework

• Adhere to all relevant labour laws, regulations, and industry standards.
• Ensure that all HR policies and procedures are compliant with national and international laws.
• Regularly review and update HR policies to reflect changes in the legal and regulatory environment.

2. Recruitment and Selection

• Implement fair and transparent recruitment processes to attract diverse talent.
• Ensure all job advertisements and selection criteria are free from bias and discrimination.
• Conduct background checks and verify qualifications to ensure the integrity of the hiring process.

3. Employee Development and Training

•  Provide ongoing training and development opportunities to enhance employee skills and competencies.
• Support career development through mentorship programs, performance appraisals, and succession planning.
• Encourage continuous learning and professional growth.

4. Compensation and Benefits

• Offer competitive and equitable compensation packages aligned with industry standards.
•  Ensure transparency in the determination and communication of salaries, bonuses, and benefits.
• Regularly review compensation and benefits policies to remain competitive and fair.

5. Health, Safety, and Well-being

• Prioritise the health and safety of employees by maintaining a safe work environment.
• Implement health and safety training programs and ensure compliance with safety regulations.
• Promote employee well-being through health initiatives, work-life balance programs, and mental health support.

6. Diversity and Inclusion

• Foster a diverse and inclusive workplace where all employees feel valued and respected.
• Implement policies and practices to prevent discrimination and harassment.
• Promote diversity in leadership and decision-making roles.

7. Performance Management

• Establish clear performance expectations and provide regular feedback.
• Conduct fair and objective performance evaluations.
• Recognize and reward high performance and address performance issues promptly.

8. Employee Relations

•  Maintain open and transparent communication channels between management and employees.
• Encourage employee participation in decision-making processes.
• Address employee grievances and disputes fairly and promptly.

9. Ethics and Integrity

• Uphold the highest standards of ethical behaviour and integrity in all HR practices.
• Ensure all employees understand and adhere to the company’s Code of Conduct.
• Implement measures to prevent and address unethical behaviour.

10. Monitoring and Evaluation

• Regularly monitor and evaluate the effectiveness of HR policies and practices.
• Conduct audits and assessments to ensure compliance with HR governance standards.
• Implement corrective actions and continuous improvement initiatives.

Responsibilities

HR Department: Develop, implement, and oversee HR policies and procedures. Ensure compliance with legal and regulatory requirements.

Management: Support and enforce HR policies. Promote a culture of fairness, transparency, and inclusivity.

Employees: Adhere to HR policies and participate in creating a positive work environment.

Conclusion

Diakrino is dedicated to upholding the highest standards of human resource governance. By implementing this policy, we aim to create a fair, transparent, and supportive work environment that enables our employees to thrive and contribute to the success of our activities.

COMMITMENT

In Diakrino we are all committed to:

• • Pursue the goal of no harm to people.
  • Protect the environment.
  • Use material and energy efficiently to provide our products and services.
  • Respect our neighbours and contribute to the societies in which we operate.
  • Develop energy resources, products and services consistent with these aims.

Ensure the Quality of our products are in accordance with international best practices

• Publicly report on our performance.
• Play a leading role in promoting best practice in our industries.
•  Manage EHSSQ matters as any other critical business activity; and
• Promote a culture in which all Diakrino employees share this commitment.

In this way we aim to have an EHSSQ performance we can be proud of and also earn the confidence of customers, shareholders and society at large.

POLICY

Diakrino:

• Has a systematic approach to EHSSQ management designed to ensure compliance with the law and to achieve continuous performance improvement.
• Sets targets for improvement and measures, appraises and reports performance.
• Requires contractors to manage EHSSQ in line with this policy.
• Requires joint ventures under its operational control to apply this policy and uses its influence to promote it in its other ventures.
• Engages effectively with neighbours and impacted communities; and
• Includes EHSSQ performance in the appraisal of staff and rewards accordingly.

Introduction

Diakrino recognizes the importance of engaging with stakeholders to foster transparent communication, build trust, and achieve sustainable development. This Stakeholder Engagement Policy outlines our approach to identifying, communicating with, and addressing the concerns of stakeholders affected by our operations.

Objectives

• Enhance transparency and accountability in all stakeholder interactions.
• Build and maintain trust through regular, honest, and open communication.
• Identify and address stakeholder concerns promptly and effectively.
• Promote sustainable development by integrating stakeholder feedback into decision-making processes.
• Ensure compliance with all applicable laws, regulations, and industry standards.

Scope

This policy applies to all employees, contractors, and third parties involved in stakeholder engagement activities for Diakrino

Stakeholder Identification

1. Stakeholder Mapping
   • • Identify all stakeholders who may be affected by our operations, including but not limited to local communities, government agencies, non-governmental organisations (NGOs), investors, employees, suppliers, and customers.
     • Categorise stakeholders based on their level of influence and interest in our activities.
2. Stakeholder Analysis
   • • Assess the potential impact of our operations on each stakeholder group.
     • Determine the most effective methods of communication and engagement for each stakeholder group.

Communication and Engagement

1. Communication Channels
   • • Utilise a variety of communication channels to reach stakeholders, including public meetings, community forums, newsletters, social media, and company websites.
     • Ensure communication is clear, accurate, and accessible to all stakeholders.
2. Regular Updates
   • • Provide regular updates on project progress, potential impacts, and mitigation measures.
     • Share relevant information on environmental, social, and economic aspects of our operations.
3. Feedback Mechanisms
   • • Establish feedback mechanisms to gather stakeholder input, concerns, and suggestions.
     • Encourage open dialogue and actively listen to stakeholder perspectives.

Addressing Stakeholder Concerns

1. Issue Identification
   • • Proactively identify and document stakeholder concerns related to our operations.
     • Prioritise issues based on their potential impact and urgency.
2. Response Plan
   • • Develop and implement response plans to address stakeholder concerns promptly and effectively.
     • Communicate actions taken and outcomes to stakeholders.
3. Grievance Mechanism
   • • Establish a formal grievance mechanism to address stakeholder complaints and disputes.
     • Ensure grievances are handled fairly, transparently, and in a timely manner.

Community Engagement

1. Community Relations
   • • Foster positive relationships with local communities through regular engagement and collaboration.
     • Support community development initiatives that align with our sustainability goals.
2. Impact Mitigation
   • • Identify and mitigate potential negative impacts of our operations on local communities.
     • Ensure community members are informed and involved in decision-making processes related to project activities.

Government and Regulatory Engagement

1. Regulatory Compliance
   • • Engage with government agencies to ensure compliance with all applicable laws and regulations.
     • Participate in regulatory consultations and provide feedback on proposed legislation and policies.
2. Public Policy
   • • Advocate for public policies that promote sustainable development and responsible resource management.
     • Collaborate with industry associations and other stakeholders to advance best practices.

Employee and Contractor Engagement

1. Internal Communication
   • • Communicate the importance of stakeholder engagement to all employees and contractors.
     • Provide training and resources to ensure effective stakeholder engagement practices are implemented.
2. Employee Involvement
   • • Encourage employees to participate in stakeholder engagement activities.
     • Recognize and reward employees who contribute to successful stakeholder engagement.

Monitoring and Reporting

1. Performance Metrics
   • • Establish key performance indicators (KPIs) to measure the effectiveness of stakeholder engagement activities.
     • Regularly review and assess performance against these metrics.
2. Reporting
   • • Provide regular reports on stakeholder engagement activities to senior management and the board of directors.
     • Disclose stakeholder engagement efforts and outcomes in the company’s sustainability reports.

Continuous Improvement

1. Feedback and Evaluation
   • • Continuously seek feedback from stakeholders on the effectiveness of our engagement efforts.
     • Conduct regular evaluations to identify areas for improvement.
2. Policy Review
   • • Regularly review and update this Stakeholder Engagement Policy to reflect changes in stakeholder expectations, regulatory requirements, and industry best practices.

Conclusion

Diakrino is committed to fostering positive and productive relationships with all stakeholders. By implementing this Stakeholder Engagement Policy, we aim to ensure that our activities are conducted in a transparent, responsible, and sustainable manner, benefiting both our business and the communities in which we operate.

 Introduction

This Vendor Management Policy is designed to ensure that Diakrino maintains effective and efficient relationships with its vendors while ensuring compliance with legal and regulatory requirements, promoting ethical conduct, and maximizing value for the company. This policy applies to all vendors providing goods or services to Diakrino

Objectives

• Ensure compliance with all applicable laws, regulations, and industry standards.
• Promote ethical conduct and prevent conflicts of interest.
• Maximize value by selecting vendors that provide the best combination of quality, service, and price.
• Mitigate risks associated with vendor relationships.
• Maintain transparency and fairness in all vendor dealings.

Scope

This policy applies to all employees, contractors, and third parties involved in the procurement and management of goods and services from vendors for Diakrino

Vendor Selection and Evaluation

1. Vendor Selection Criteria
   • • Vendors must demonstrate the capability to meet Diakrino’s requirements for quality, service, and price.
     • Vendors must comply with all applicable laws and regulations.
     • Vendors should have a proven track record of reliability and financial stability.
     • Preference may be given to vendors who demonstrate a commitment to sustainable and ethical practices.
2. Vendor Evaluation Process
   • • Conduct a thorough evaluation of potential vendors, including background checks and financial assessments.
     • Evaluate vendors based on their ability to meet technical specifications, quality standards, delivery schedules, and cost-effectiveness.
     • Consider vendor certifications, industry reputation, and past performance.
3. Request for Proposal (RFP)
   • • Issue an RFP to shortlisted vendors outlining the scope of work, technical requirements, evaluation criteria, and submission deadlines.
     • Ensure a transparent and competitive bidding process.

Vendor Contract Management

1. Contractual Agreements
   • • All vendor relationships must be governed by written contracts that clearly define the terms and conditions, including scope of work, pricing, payment terms, delivery schedules, and performance metrics.
     • Contracts must include provisions for compliance with legal and regulatory requirements, confidentiality, data protection, and termination clauses.
2. Performance Monitoring
   • • Regularly monitor vendor performance against agreed-upon metrics and key performance indicators (KPIs).
     • Conduct periodic reviews and audits to ensure compliance with contract terms and quality standards.
     • Address any performance issues promptly and document corrective actions.

Risk Management

1. Risk Assessment
   • • Identify and assess potential risks associated with vendor relationships, including operational, financial, legal, and reputational risks.
     • Implement risk mitigation strategies, such as diversification of vendors, insurance coverage, and contingency planning.
2. Due Diligence
   • • Conduct due diligence on vendors before entering into contracts, including background checks, financial assessments, and verification of compliance with legal and regulatory requirements.
     • Ensure vendors have adequate policies and procedures in place to manage risks, including health and safety, environmental, and cybersecurity risks.

Compliance and Ethics

1. Code of Conduct
   • • Require vendors to adhere to Diakrino’s Code of Conduct and Ethics, including standards for ethical behaviour, anti-corruption, and fair labour practices.
     • Prohibit conflicts of interest, bribery, and corruption in all vendor dealings.
2. Training and Awareness
   • • Provide training and awareness programs for employees involved in vendor management to ensure understanding of compliance requirements and ethical standards.
     • Communicate expectations and requirements to vendors regarding compliance and ethics.

Communication and Collaboration

1. Vendor Relationships
   • • Foster open and transparent communication with vendors to build strong, collaborative relationships.
     • Encourage regular feedback from vendors to identify opportunities for improvement and innovation.
2. Issue Resolution
   • • Establish a formal process for addressing and resolving issues or disputes with vendors.
     • Ensure timely and effective resolution of issues to maintain positive vendor relationships.

Record Keeping and Documentation

1. Documentation
   • • Maintain accurate and complete records of all vendor interactions, contracts, performance evaluations, and due diligence activities.
     • Ensure documentation is securely stored and easily accessible for review and audit purposes.
2. Confidentiality
   • • Protect the confidentiality of vendor information and ensure compliance with data protection laws and regulations.

Review and Update

• Regularly review and update this Vendor Management Policy to reflect changes in legal and regulatory requirements, industry best practices, and company objectives.
• Ensure continuous improvement of vendor management processes and practices.

Conclusion

Diakrino is committed to maintaining high standards of vendor management to ensure compliance, ethical conduct, and value creation. By implementing this policy, we aim to build strong, mutually beneficial relationships with our vendors while mitigating risks and ensuring the success of our operations

 Introduction

This Vendor Management Policy is designed to ensure that Diakrino maintains effective and efficient relationships with its vendors while ensuring compliance with legal and regulatory requirements, promoting ethical conduct, and maximizing value for the company. This policy applies to all vendors providing goods or services to Diakrino

Objectives

• Ensure compliance with all applicable laws, regulations, and industry standards.
• Promote ethical conduct and prevent conflicts of interest.
• Maximize value by selecting vendors that provide the best combination of quality, service, and price.
• Mitigate risks associated with vendor relationships.
• Maintain transparency and fairness in all vendor dealings.

Scope

This policy applies to all employees, contractors, and third parties involved in the procurement and management of goods and services from vendors for Diakrino

Vendor Selection and Evaluation

1. Vendor Selection Criteria
• Vendors must demonstrate the capability to meet Diakrino’s requirements for quality, service, and price.
• Vendors must comply with all applicable laws and regulations.
• Vendors should have a proven track record of reliability and financial stability.
• Preference may be given to vendors who demonstrate a commitment to sustainable and ethical practices.
2. Vendor Evaluation Process
• Conduct a thorough evaluation of potential vendors, including background checks and financial assessments.
• Evaluate vendors based on their ability to meet technical specifications, quality standards, delivery schedules, and cost-effectiveness.
• Consider vendor certifications, industry reputation, and past performance.
3. Request for Proposal (RFP)
• Issue an RFP to shortlisted vendors outlining the scope of work, technical requirements, evaluation criteria, and submission deadlines.
• Ensure a transparent and competitive bidding process.

Vendor Contract Management

1. Contractual Agreements
• All vendor relationships must be governed by written contracts that clearly define the terms and conditions, including scope of work, pricing, payment terms, delivery schedules, and performance metrics.
• Contracts must include provisions for compliance with legal and regulatory requirements, confidentiality, data protection, and termination clauses.
2. Performance Monitoring
• Regularly monitor vendor performance against agreed-upon metrics and key performance indicators (KPIs).
• Conduct periodic reviews and audits to ensure compliance with contract terms and quality standards.
• Address any performance issues promptly and document corrective actions.

Risk Management

1. Risk Assessment
• Identify and assess potential risks associated with vendor relationships, including operational, financial, legal, and reputational risks.
• Implement risk mitigation strategies, such as diversification of vendors, insurance coverage, and contingency planning.
2. Due Diligence
• Conduct due diligence on vendors before entering into contracts, including background checks, financial assessments, and verification of compliance with legal and regulatory requirements.
• Ensure vendors have adequate policies and procedures in place to manage risks, including health and safety, environmental, and cybersecurity risks.

Compliance and Ethics

1. Code of Conduct
• Require vendors to adhere to Diakrino’s Code of Conduct and Ethics, including standards for ethical behaviour, anti-corruption, and fair labour practices.
• Prohibit conflicts of interest, bribery, and corruption in all vendor dealings.
2. Training and Awareness
• Provide training and awareness programs for employees involved in vendor management to ensure understanding of compliance requirements and ethical standards.
• Communicate expectations and requirements to vendors regarding compliance and ethics.

Communication and Collaboration

1. Vendor Relationships
• Foster open and transparent communication with vendors to build strong, collaborative relationships.
• Encourage regular feedback from vendors to identify opportunities for improvement and innovation.
2. Issue Resolution
• Establish a formal process for addressing and resolving issues or disputes with vendors.
• Ensure timely and effective resolution of issues to maintain positive vendor relationships.

Record Keeping and Documentation

1. Documentation
• Maintain accurate and complete records of all vendor interactions, contracts, performance evaluations, and due diligence activities.
• Ensure documentation is securely stored and easily accessible for review and audit purposes.
2. Confidentiality
• Protect the confidentiality of vendor information and ensure compliance with data protection laws and regulations.

Review and Update

• Regularly review and update this Vendor Management Policy to reflect changes in legal and regulatory requirements, industry best practices, and company objectives.
• Ensure continuous improvement of vendor management processes and practices.

Conclusion

Diakrino is committed to maintaining high standards of vendor management to ensure compliance, ethical conduct, and value creation. By implementing this policy, we aim to build strong, mutually beneficial relationships with our vendors while mitigating risks and ensuring the success of our operations

Diakrino encourages a culture of compliance, safety and ethics through a governance framework that includes systems designed to ensure that the business acts responsibly, with high standards of corporate governance, while also delivering on shareholder value. These include:

• Financial management systems designed to detect bribery and corruption
• Continual training to ensure employees and business partners are aware of bribery and corruption issues
• Internal communications and reminders to all of their obligations under relevant policies and procedures in this area including the Company’s code of conduct
• Regular reviews of the Company’s policies including: the Anti-Corruption Policy, the Policy on Interactions with Public Officials, and the Gifts & Benefits Policy
• Declaration by all employees of gifts, benefits and entertainment given or received
• Whistle-blowing processes to assist employees report concerns in a confidential manner
• Conducting due diligence on all business partners
• Ensuring that all business partners execute a Non-Solicitation Agreement
• Periodic Risk Assessments to ensure internal controls against corrupt practices are working effectively
• Taking disciplinary action on employees or business partners in relation to established breaches of any anti-bribery and corruption measure

The Company’s code of conduct prohibits improper payments such as bribes and facilitation payments and applies to all employees and business partners. All employees are introduced to the code as part of their induction and must sign a certificate of compliance. In addition, there is an annual mandatory ethics re-certification to ensure all employees and directors maintain an awareness of the issues in this area. All business partners are made aware of the code. 

Diakrino has a zero-tolerance policy towards corrupt practices in all our jurisdictions as this prevents transparency and impacts integrity in the conduct of its business. As Diakrino operations take place all over the world, including some countries that present high bribery and corruption risk, it is important to comply with international laws like the Corruption of Foreign Public Officials Act 1998, the Foreign Corrupt Practices Act and the UK Bribery Act 2010. The code is reviewed regularly.

Diakrino is a responsible business, and we have a duty to all our stakeholders, in the countries and communities in which we operate, to conduct our business in a transparent and socially sustainable manner. Our code of conduct requires that we do not engage in bribery or corruption in any form, and this applies to all employees and business partners. The Board values its communications with the Company’s shareholders and seeks to keep them up to date with company performance and developments.

Clear due diligence procedures have been put in place to ensure that potential bribery and corruption risks associated with doing business with new partners are identified and managed effectively. This allows the company to make appropriate risk assessments and put mitigating measures in place, ensuring informed decisions in the selection of our business partners and suppliers.

Mechanisms are also in place to audit existing relationships to ensure continued compliance with globally acceptable ethical standards by current business partners. Business partners are obligated to maintain effective due diligence systems in compliance with the Diakrino Code of Business Conduct and Ethics. This obligation extends to contractors and sub-contractors who may hire services on Diakrino’s behalf.

Where there is suspected or potential violation of anti-corruption laws, we aim to examine these and take appropriate action where necessary. The company utilizes the World-Check compliance screening software, which enables us to capture any high-risk individuals and entities that are already on the radar of global enforcement agencies. This tool augments the company’s existing policies and procedures for identifying and managing financial, regulatory, and reputational risks associated with doing business with potential and existing business partners and counterparties.

In addition to eliminating bribery and corruption, the company’s KYC and due diligence process also aims to eliminate or reduce the risk of dealing with persons or organizations involved in money laundering, financing terrorism, child labor, and abuse of human rights, or those on any sanctions list.

Diakrino is an international organization that engages with governments on many fronts, from collaborating on entrepreneurial initiatives to understanding our tax liabilities. Although the way we interact with government agencies, ministries and regulatory bodies depends on the legal and regulatory framework in each country of operation, our Code of Business Conduct and Ethics, and Policy on Interactions with Public Officials requires all employees and business partners to be honest, open and transparent in their interactions and dialogue with government officials and regulatory bodies. 

Diakrino policy clearly prohibits the offering of facilitation payments to government officials. Diakrino also has a policy of not participating directly in party political activity or making contributions to political candidates whether in cash or in kind.