Code Of Conduct

1. General

The Nordic culture is rooted in the principles of honesty and respect for all people. Successful businesses are dependent on confidence and a good reputation. Nordic's operations demand a high degree of care, honesty and integrity. Accordingly, Nordic values its company culture and reputation as a key asset. We expect our employees to promote our core values by acting responsibly towards colleagues, business associates and society at large.

The main purpose of Nordic's Code of Conduct is to ensure that all persons acting on behalf of Nordic perform their activities in an ethical way and in accordance with the standards Nordic sets through its Steering Documents. The rules will help secure compliance with laws and regulations. This Code of Conduct provides a framework for what Nordic considers responsible conduct, but is not exhaustive. As a Nordic employee, you should always strive to exercise good judgment, care and consideration in your service for the Company.

2. Scope and responsibility

The Code of Conduct applies to all employees, including temporary personnel of the Company and members of the Board of Directors. You shall avoid acting or encouraging others to act contrary to this Code of Conduct, even if such deviations under the circumstances may appear to be in the Company's interest. If you are uncertain whether a particular activity is legally or ethically acceptable, you should, as far as practicable, consult in advance with your immediate superior.

As a line manager, you are responsible for making these guidelines known and to promote and monitor compliance. Violation of this Code of Conduct will not be tolerated and lead to internal disciplinary actions, dismissal or even criminal prosecution. Should an improper practice or irregularity occur within the Company, the Company is committed to make necessary corrections and take remedial action to prevent recurrence.

3. Complaints, expression of concern and non-punishment

Nordic wishes to stimulate employees to open discussions about responsible conduct in an un-bureaucratic way. Thus, you should normally discuss your concerns and complaints with your superior. If you deem this not to be appropriate, you may address any other of your superiors or the HR Manager. Complaints may be reported confidentially and if you find it necessary anonymously.

As a matter of law, concerns regarding questionable accounting or auditing matters shall be submitted to the Board of Directors.

If you in good faith express your concern to a relevant body within Nordic concerning possible violation of law or Company policy, you shall be protected against any sanctions from the company or any Nordic representative due to your report.

It is a violation of this Code of Conduct to discriminate or harass anyone for making such report.

4. Personal conducts
   
   
   1. Behavior based on mutual respect

   As a Nordic employee or Board Member, you are expected to conduct business and generally behave impeccably towards business associates, colleagues, and others. This includes being sensitive to and respecting foreign cultures and customs.

   Nordic does not accept any form of harassment, discrimination or other behavior that colleagues or business associates may regard as threatening or degrading.

   2. Intoxicants

   Nordic is a drug-free workplace. Accordingly, you may not be under the influence of intoxicating substances, including alcohol, while at work for Nordic.

   Banned substances are totally unacceptable and any use of these substances will result in immediate termination of employment in Nordic.

   Limited amounts of alcohol may, however, may be served when the local custom and occasion makes it appropriate to do so, and provided that the consumption will not be combined with operating machinery, driving or any other operation that is incompatible with the use of alcohol.

   You shall refrain from using, or encouraging others to use, intoxicants in a manner that can place the user, Nordic or any of its business associates in an unfavorable light.

5. Equal opportunities

Nordic is committed to an inclusive work culture and appreciates and recognizes that all people are unique and valuable, and should be respected for their individual abilities. Nordic does not accept any form of harassment or discrimination on the basis of gender, religion, race, national or ethnic origin, cultural background, social group, disability, sexual orientation, marital status, age or political opinion.

Nordic shall provide equal employment opportunity and treat all employees fairly. Nordic shall only use merit, qualifications and other professional criteria as basis for employee-related decisions.

6. Conflict of interest and integrity



1. Fraud and conflict of interest

Nordic's employees and Board Members shall not seek to obtain advantages for themselves (or related persons) that are improper or in any other way may harm Nordic's interests, whether or not this constitutes criminal fraud. You may not take part in or seek to influence any decision that can give rise to an actual or perceived conflict of interest. Such circumstances may be a personal - economically or otherwise - directly or through someone closely related. If you become aware of a potential conflict of interest you shall, without delay, notify your immediate superior.

2. Bribes, gifts and favors

You shall not, in order to obtain or retain business or other improper advantage in the conduct of business, offer, promise or give any undue advantage to a public official (or a third party) to make the official act or refrain from acting in relation to the performance of her/his official duties. This applies regardless whether the advantage is offered directly or through an intermediary.

Gifts or other favors to business associates shall comply with locally accepted good business practice. Gifts and other favors can only be given or granted provided that they are modest, both with respect to value and frequency.

As a Nordic employee or Board Member, you are not permitted to accept from business associates monetary or other favors that may affect or appear to affect your integrity or independence. Gifts and other favors can only be accepted to the extent they are modest, both with respect to value and frequency.

If you are offered or have received such favors beyond common courtesy gifts you shall, without delay, notify your immediate superior that will determine whether your integrity or independence may be perceived to be affected.

3. Financial interests in other businesses

As a Nordic employee or Board Member, you should avoid having a personal ownership interest - directly or indirectly - in any other enterprise if it compromises or appears to compromise your loyalty to the Company. Before making an investment in a company that competes with Nordic or does business with the Company (such as a supplier), your immediate superior shall be consulted.

4. Confidential information

Information, intellectual property and innovative ideas are valuable Nordic assets. These assets must be appropriately managed and protected. Nordic's general policy of openness and transparency shall not prevent appropriate protection of information that may be of value to Nordic's business interests. Information other than general business knowledge and work experience that becomes known to you in connection with performance of your work, shall be regarded as confidential and treated as such.

7. Compliance



1. Compliance with laws - general

You shall comply with all applicable laws and regulations when conducting business on behalf of the Company. You shall not assist in breach of laws by business associates, whether it constitutes an illegal act for the Company or yourself as an individual, or not.

2. Accurate period reports and other public financial communication

As a matter of applicable laws and stock exchange listing standards, Nordic is obligated to provide full, fair, accurate and understandable disclosure in its periodic financial reports, other documents filed with applicable regulatory authorities and agencies as well as in its other public communications. Employees, particularly our management and financial officers, are expected to exercise the highest standard of care in preparing such materials.

You shall comply with all applicable laws and regulations when conducting business on behalf of the Company. You shall not assist in breach of laws by business associates, whether it constitutes an illegal act for the Company or yourself as an individual, or not.

8. No rights created

This Code of Conduct is a statement of certain fundamental Nordic principles, policies and procedures that govern the Company's employees and Board Members. It does not create any rights for any customer, supplier, competitor, shareholder or any other person or entity.

Nordic's Management Team is handling the day-to-day management of Nordic's people, delivery of services to our customers and oversees policy implementations across the different countries. Together they lead a team of dedicated staff of more than 15 nationalities in five countries.

Our Management and Supervisory team offer more than 150 years combined experience in the field. In fact, even today all of Nordic's Management team still participates in the day-to-day field operations when needed - a level of service that is greatly valued by our customers.

Sonny Sola - General Manager
Mr. Sola has 25 years international operative and managerial experience in well interventions, coiled tubing operations, under-balanced drilling, coiled tubing drilling and horizontal drilling operations. He held several managerial positions within the TransOcean Group from 89 to 99.

Christian Wolff - Finance Manager
Mr Wolff holds a MSc in Business Administration from the Norwegian School of Economics and Business Administration (NHH) in Bergen, Norway. Prior to joining Nordic Energy, he spent several years with Ernst & Young as part of an international task force working for one of the largest oil producers in the World.

Hans Christian Pretorius - Administration Manager
Mr Pretorius holds degrees in Administration and Economics from University of Bergen and Norwegian School of Management (BI). Long managerial experience from operations worldwide. Extensive experience from oil, shipping and IT industry.

Ibrahim Hasan - Business Delivery Manager
Mr. Hasan has 21 years of experience from thru-tubing and coild tubing operations. More than 18 years of experience in the Middle East region holding operational and managerial positions.

Dylan Johnstone - Assets Manager
Mr Johnstone has 21 years of experience from thru-tubing, completion, wire-line, coiled tubing and fishing operations. 6 years experience from operations in the Middle East.

John Meritt - Country Manager Argentina
Mr .Meritt has 21 years of experience from thru-tubing and coiled tubing operations. More than 18 years of experience in the Middle East region holding operational and/or managerial positions.

Shadi Nasser - Acting Country Manager Egypt
Mr Nasser holds a degree in Petroleum technician from Duncan, USA. He has several years experience as consultant, service engineer and service area Manager.

Ian Gurmin - Well Intervention Manager
Mr. Gurmin has 17 years experience from Well intervention and fishing operations worldwide.

Jason Robertson - Workover Manager
Mr Robertson has 20 years experience from workover and snubbing operations worldwide.

Kjell Revheim - Engineering, Development Manufacturing Manager
Mr Revheim has 19 years oil field experience, and holds a degree in Mechanical Engineering and Project Managemen from the University of Stavanger and Norwegian School of Management (BI). He has long managerial experience in the Middle East in various technical and operational positions (Engineering Manager, Product Line Manager).