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The Right Way I Every Day Question A vendor offers his contact at LyondellBasell Diana two high priced front row seats to a sporting event. The vendor tells Diana that he does not want anything in return as he cannot attend the event. What should Diana do Answer Diana should consult her supervisor or another Company resource as described in the Where to Seek Guidance and Report Concerns section. Our Gifts Entertainment and Travel Policy addresses such matters and in this case if the value of the tickets exceeds 100 she must obtain approval from her Senior Officer before accepting this gift. If the vendor accompanied Diana to the event then the ticket would be entertainment rather than a gift and she would not be required to obtain prior approval from her Senior Officer. 10 Business Gifts and Entertainment When conducting LyondellBasell business you may exchange business gifts and participate in entertainment to foster good relations between our Company and its customers or vendors. However we must use good judgment when offering or accepting such courtesies. Otherwise we may find ourselves in a conflict of interest situation. This means we may never offer or accept a business gift or entertainment if doing so would create a bias in our decisions. Before accepting or offering a business courtesy ask yourself if you would feel comfortable if others knew of it. As a rule you may only offer or accept a business gift or entertainment if it is unsolicited and complies with applicable Company policies. In addition we may not offer or accept improper gifts and entertainment directly or indirectly through third parties or allow our family members to do so. When interacting with government officials and employees we must follow stricter rules. Refer to the Bribes and Improper Payments section of our Code and applicable Company policies on Elements for additional information. Disclosing Conflicts of Interest If you are aware of actions or interests of your own or others that might create a conflict you must make a disclosure by completing a disclosure form. In addition we should work actively with our customers vendors and anyone doing business on behalf of LyondellBasell to identify and address conflicts of interest. For more information or guidance please see the applicable Company policies on Elements. We Comply with Anti-Corruption Laws As a global organization LyondellBasell is committed to acting ethically and legally across the globe. We uphold this commitment regardless of where we do business. This means in part that we abide by all international anti-corruption laws treaties and regulations that forbid bribery improper payments or kickbacks. Bribes and Improper Payments Doing business the right way means we never offer or accept any form of bribe payment or kickback. A bribe is an offer or promise to give anything of value in order to improperly influence a decision or to gain an improper business advantage. A kickback occurs when money is returned or is paid as a reward for awarding or fostering business. In addition LyondellBasell prohibits facilitating payments. A facilitating payment is a small paymentusually in cashmade to expedite routine government services. Although such payments may be common in certain parts of the world our Company prohibits them. You must take caution to avoid improper payments. You should always determine the ownership structure of our third party representatives by performing due diligence as required by applicable Company policies. You must also ensure that you do not allow third parties to make or receive any improper payment on our behalf. You may never seek or accept any improper payment or kickbacks. Violations of this policy may result in disciplinary action up to and including termination as well as possible civil and criminal penalties for those parties and our Company. If you have any questions or concerns about this please refer to the section Where to Seek Guidance and Report Concerns. You are expected to report your concerns about bribes and improper payments. LyondellBasell will not tolerate retaliation against anyone who makes a good faith report of misconduct.