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The Right Way I Every Day www.lyondellbasell.ethicspoint.com13 Throughout the world countries have enacted laws that prohibit us from trading securities based on material nonpublic information. Material non-public information refers to information that is not available to the public and that a reasonable investor would likely consider important in deciding whether to purchase or sell a security. If you trade on the basis of such information it is considered insider trading and is illegal. Therefore you may not buy or sell our or another companys securities if you possess such information. Additionally if you share information with another person and that other person trades on the basis of the information that is considered tipping and both of you may be guilty of insider trading. Inside information may include Financial information including earnings forecasts or dividend changes Winning or losing a client or contract Changes in our most senior management Litigation or government investigations Mergers acquisitions or divestitures Sale or purchase of major assets or subsidiaries If you feel you or another employee may have engaged in insider trading or tipping you should contact the Legal department immediately. We Maintain Accurate Financial Books and Records Our shareholders depend on our honesty and integrity particularly when measuring the financial strength of our Company. It is crucial then that we maintain accurate and honest accounting practices and recordkeeping at all times. We must all comply with recognized accounting principles. Those who have financial and accounting responsibilities must also ensure that our accounting methods are accurate presenting an honest transparent and forthright picture of our Company. We must comply with all legal and regulatory requirements and follow our internal accounting policies and controls at all times. Incomplete or inaccurate financial disclosures not only damage our Company and its reputation but they also harm our stakeholders who rely on their accuracy. We must Keep and present all Company records and reports in accordance with the law. These records include accounting records as well as any other electronic or written records such as expense reports and time sheets Establish and maintain a system of strong and effective internal controls Ensure that all Company records accurately and fairly reflect the underlying transaction Question Sam accidently saw a copy of a confidential memo describing a large contract that our Company will soon sign with another company. If Sam buys some of the other companys stock on the basis of this information and before the news of the contract is made public is Sam engaging in insider trading Answer Yes assuming that the news of this contract is material nonpublic information or inside information. If Sam purchases securities of the other company on the basis of this information before it becomes public Sam is engaging in insider trading. Never falsify any document Record all financial transactions in the proper account department and accounting period Ensure that all actions and commitments are in accordance with Company policy Records Management We must retain our business records as long as the law requires and as long as necessary for our business purposes. This means we should Classify documents according to Company policy Retain and discard Company records consistent with Company policy and schedules Follow all special record-keeping requirements issued with respect to internal investigations litigation and government inquiries However if you receive notice that some or all of your records are required for an internal or government investigation or legal proceeding you shall not discard or destroy them. If you receive a subpoena or request for any document or record please notify the Legal department immediately. Similarly if you receive a request from a business counterpart a government agency or a third party to provide a record or document you should contact the Legal department.