BUSINESS POLICY PHOENIX OIL LIMITED

The Phoenix Oil Limited is a business incubator operating primarily in the Energy sector. Our core operations are centered within the oil and gas industry and its associated subsectors. The company started operations in 2000 and has grown from being a regional oil marketing firm into an integrated energy corporation, having spun off businesses with operations around the World. Our business activities include:

Oil and gas exploration and production Trading of crude oil and refined petroleum products Gas processing and marketing of Liquefied Natural Gas (LNG) and Liquefied Petroleum Gas (LPG) Bulk liquid storage and terminaling Supply and distribution of refined petroleum products offshore and onshore Operation and management of Power Plants

Phoenix Energy Field Limited (PEFL) is the upstream exploration and production (E&P) arm of the group. Its core business is to explore and develop oil and gas assets in established and emerging frontiers. PEFL aims to create value for its shareholders through successful exploration, development and production of oil and gas reserves while contributing to the future and development of the countries where its operations are located. Our commitment and participatory approach: partnering through time and resources with employees, local communities and contractors; would help create and sustain vibrant

communities which in turn would contribute to our success and the national strength of countries we operate in. Our Vision To be the provider of choice wherever energy is consumed

Our Core values To stay focused on our vision To maintain integrity in our dealings Pursue our objectives with endless determination Encourage loyalty as the foundation of excellence Discipline in the pursuit of our mission

Our Mission To transform; through creativity, determination and relationship building. We will continually seek ways to generate value We will go the extra distance in the pursuit of value We will turn the mundane into the extraordinary

P Partnership

H - Honesty O - Order E - Excellence N-N I - Integrity X-

The importance of the domestic petroleum industry to the economy of Nigeria cannot be over-emphasized as an issue of national security, national self-reliance and as a major source of government revenue. Nigerias average daily production of crude oil and gas in 2007-08 was 70,205 barrels and 4,176 million cubic feet, respectively. Nigerias current crude oil production meets only 18% of the total demand for domestic consumption. The balance requirement is imported involving large expenditures of foreign exchange. Domestic gas production and supply presently fails to meet the demand of domestic users, the industrial sector and power generation. Furthermore, gas supply may soon become insufficient due to increasing demand and depletion of present reserves. This, in turn, will force Nigeria to soon begin importing large volumes of gas at international prices to feed the domestic market. Phoenix Oil Limited is committed to accelerate an exploration and development programme in order to reverse the decline in crude oil production, to increase the domestic gas production and supply and to reduce the burden of imported energy which otherwise will have adverse effect on the balance of payments & trade. In the current global energy price environment, E&P Policy has to be dynamic to meet the new challenges faced in meeting energy needs of the country at least cost option and to minimize the adverse effects on the economy of high import bill of energy.

The principal objectives of this Policy are: 1. To accelerate E&P activities in Nigeria with a view to achieve maximum self sufficiency in energy by increasing oil and gas production. 2. To promote direct foreign investment in Nigeria by increasing the competitiveness of its terms of investment in the upstream sector. 3. To promote the involvement of Nigeriai oil and gas companies in the countrys upstream investment opportunities. 4. To train the Nigeriai professionals in E& P sector to international standards and create favourable conditions for their retaining within the country. 5. To promote increased E&P activity in the onshore frontier areas by providing globally competitive incentives. 6. To enable a more proactive management of resources through establishment of a strengthened Directorate General of Petroleum Concessions (DGPC) and providing the necessary control and procedures to enhance the effective management of Nigerias petroleum reserves. 7. To undertake exploitation of oil and gas resources in a socially, economically and environmentally sustainable and responsible manner.

POLICIES 1. QHSSE Policy At Phoenix, our Quality Health, Safety, Security and Environment, management system (QHSSE MS) focuses on leadership, commitment, and a management system process that is integrated into our business planning. All efforts in this regard, are geared towards ensuring the health and safety of our employees and host communities on one hand, and the effective elimination, curtailment and management of the environmental impact of our operations on the other hand. Safety remains our first priority at all times. Our goal is to attain and continually maintain zero fatalities and accidents. As part of the continued implementation of our HSSE MS, emphasis is placed on critical risk assessment of all high, medium and low risk tasks before the commencement of any such tasks. In light of this we watch our QHSSE Performance very keenly.

At Phoenix, we are committed to protecting the environment, as we strive to meet the worlds demand for energy in an environmentally responsible way. Our continuous environmental improvement processes helps to reduce emissions and waste. Investigation of all incidents and enlightenment on lessons learnt across our subsidiaries is paramount to the achievement of this goal. At Phoenix QHSSE is everybodys business!

2. Corporate social responsibility (CSR INITIATIVE) Giving back to the society has always been a key commitment of the Phoenix . As against making a show of our contributions to the development of society, our focus is on quietly touching lives that genuinely need help. In concerted effort with credible and globally recognized organizations, we ensure that our contributions cut across various societies and regions towards the alleviation of poverty, disease and suffering.

At Phoenix, we are rewarded by the positive impact of our programmes on our society as a whole. As a result, we are refueled with the energy and motivation we need to constantly change the lives of the rural poor and economically disadvantaged.

PHOENIX has launched another laudable CSR programme tagged Eyes Can See. The programme is an extension of PHOENIXs ongoing community engagement initiatives which focuses on bringing quality and comprehensive health care to members of her host communities School Phoenix Feeding plays an active role in child welfare through the school feeding

programme. This is done by providing a meal per day for children within selected schools in various communities nationwide. Thereby increase school enrolment rates, alleviate short term hunger and improve nutritional status, thus increasing

attention Guinea

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Worm

Eradication

Our desire to eradicate socio-economic diseases such as guinea-worm from our society has led to several guinea-worm eradication programmes in various communities all over the country.