Our Code of Conduct.

1.0 Message from the MD/CEO

Welcome to our Code of Conduct (the Code). This guide is meant to empower you to make decisions that are in line with our Core Values and Business Principles. We want to encourage informed decision-making in Renaissance Africa Energy Company Limited and Renaissance Africa Business Operations Limited (hereinafter referred to as Renaissance).

At Renaissance, these principles and values define us and shape our success. We find it essential to uphold them, and together, we create a workplace where integrity thrives without fear.

Although we all attempt to behave ethically, the global and business environments keep changing. Remaining informed and on guard helps ensure that we evolve in a responsible manner when confronted with emerging challenges. This Code serves as a resource, illuminating significant responsibilities and risk areas relevant to your role. If you are a manager, you will also come across additional guidance meant to bolster your leadership. Finally, our Integrity Check functions as a useful tool to assist in areas or dilemmas not specifically covered by this Code.

Regardless of whether you occupy the role of manager, employee, or even contractor staff, I urge you to take up the Code as a means of developing an ethical culture that will bring Renaissance to a secure future. Not only do you have the authority to enforce ethical standards, but you are also the best line of defense we have to ensure that all of us comply with the Code a hundred percent (100%) of the time.

We appreciate your dedication to ethics, integrity, and excellence. Together, we are constructing a stronger, more believable, and resilient Renaissance.

— Tony Attah, Managing Director / Chief Executive Officer

1.2 Who is Our Code of Conduct for?

This Code applies to every employee, director, and officer in Renaissance Africa Energy Company Limited and Renaissance Africa Business Operations Limited (both hereinafter referred to as “Renaissance”).

Contract staff working for Renaissance must also follow the Code. Contractors and consultants who are agents of, or working on behalf of, or in the name of Renaissance are required to act consistently with the Code when acting on our behalf. Independent contractors and consultants must be made aware of the Code as it applies to their dealings with our staff.

Where Renaissance has formally been designated the operator of a Joint Venture, Renaissance must apply the Code to the operation of the Joint Venture.

1.3 Our Core Values and Business Principles

At Renaissance, we share a set of core values — Collaboration, Respect, Integrity, Safety and Performance (C.R.I.S.P). By making a commitment to these in our working lives, each of us plays our part in protecting and enhancing Renaissance's reputation.

Our shared core values underpin all the work we do and are the foundation of our Code of Conduct and Renaissance's General Business Principles. These principles govern how Renaissance conducts its affairs and outline our responsibilities to shareholders, customers, employees, business partners and society. We are judged by how we act, and our reputation is upheld when we act in accordance with the law, our Business Principles, and our Code.

2.1 Your Individual Responsibilities

The Code of Conduct is for you. It sets the boundaries within which all Renaissance staff must operate every day, without exception. Read it. Understand it. Follow it.

Your responsibilities

• Understand the risks in your role and how to manage them.
• Seek advice when things are not clear.
• Promptly complete the ethics and compliance training assigned to you.
• Make sure any third-party contractors, agents or consultants you work with are aware that we are bound by our Code and that they should act accordingly.
• Speak up. It is your duty to report any suspected violations of the Code.

2.2 Your Integrity Check

Our Code of Conduct cannot give you specific advice for every situation, dilemma, or decision. When in doubt, ask yourself:

• Am I keeping to our core values of Collaboration, Respect, Integrity, Safety and Performance (C.R.I.S.P)?
• Is what I am doing ethical and in line with Renaissance General Business Principles, our Code of Conduct and supporting manuals?
• Is it legal and am I authorised to do it?
• Have I thoroughly understood the potential risks, including risks to Renaissance's reputation?
• Is it the right thing to do and am I leading by example?
• If this becomes public knowledge, will I still feel I have done the right thing?

If you are unsure about any of these, seek advice — from your line manager, the Renaissance Ethics & Compliance Team, Human Resources, Renaissance Legal or the Helpline.

2.3 Seek Advice and Speak Up

If you would like advice on any matter relating to the Code or wish to report a concern, speak to your line manager, the Renaissance Ethics & Compliance Team, a Human Resources or Renaissance Legal representative. Alternatively, you can contact the Helpline — available 24 hours a day, seven days a week, via telephone and the internet, and staffed by an independent third party. You can call or submit a report anonymously if you wish.

If you know or suspect someone is violating the Code, you have a duty to report it. Renaissance will not tolerate any form of retaliation directed against anyone who raises a concern in good faith. Any act or threat of retaliation against Renaissance staff will be treated as a serious violation of our Code.

2.4 Manager's Responsibilities

We depend on our managers to promote our ethical standards and act as role models for their teams. We expect managers to show leadership in following our Code and maintain a culture of commitment to ethics and compliance, where it is normal to do the right thing and people feel confident about speaking up.

As a manager you must

• Understand and follow the Code.
• Understand the main Code violation risks that apply in your business or function, and the procedures to mitigate them.
• Ensure your staff make time to complete promptly the Ethics and Compliance training assigned to them.
• Ensure your staff understand the procedures to avoid violating the Code, including recording gifts, hospitality and potential conflicts of interest in the designated Register.
• Make sure anyone new to your team is briefed promptly on our Code of Conduct, the Code risks in their role, and where they can seek advice and support.
• Be alert to any violations of the Code and encourage your team to speak up.
• If told of a possible violation, report it and keep all reported concerns confidential. Never investigate the matter yourself.

3.1 Health, Safety, Security, Environment & Social Performance

Renaissance is helping to meet Africa's growing energy needs in ways that are economically, environmentally, and socially responsible. Our aim is to achieve Goal Zero, with No Harm and No Leaks. We are committed to doing no harm to people and protecting the environment while developing energy resources, products and services.

Renaissance, its contractors and joint ventures under Renaissance operational control are required to have a systematic approach to the management of Health, Safety, Security, the Environment and Social Performance (HSSE&SP), designed to ensure compliance with the law and achieve continuous performance improvement.

Your responsibilities — the three Golden Rules

• Comply with the law, standards and procedures.
• Intervene in unsafe or non-compliant situations.
• Respect our neighbours.

You must ensure your work complies with the HSSE&SP Commitment and Policy, follow the International Association of Oil & Gas Producers (IOGP) Life Saving Rules, and report and act on any HSSE&SP incident, potential incident, or near-miss.

3.2 Human Rights

Conducting our activities in a way that respects human rights is a business imperative for Renaissance and supports our licence to operate. Human rights requirements are embedded across Social Performance, Security, Human Resources, and Contracting & Procurement.

We comply with applicable laws and regulations, including the United Nations Universal Declaration of Human Rights and the core conventions of the International Labour Organisation. If you know of or suspect any potential human rights violations relating to our business, it is your duty to speak up.

3.3 Harassment

Renaissance will not tolerate harassment. We will not tolerate any action, conduct or behaviour which is humiliating, intimidating or hostile. Treat others with respect and avoid situations that may be perceived as inappropriate.

Your responsibilities

• Treat others with respect at all times.
• Do not physically or verbally intimidate or humiliate others.
• Do not make inappropriate jokes or comments.
• Do not display offensive or disrespectful material.
• Challenge someone if you find their behaviour hostile, intimidating, humiliating or disrespectful — and contact your line manager, the Ethics & Compliance Team, Human Resources, Legal or the Helpline.

3.4 Equal Opportunity

At Renaissance, we offer equal opportunities to everyone. This helps us draw on the widest possible talent pool and attract the best people. When making employment decisions — hiring, evaluation, promotion, training, development, discipline, compensation, and termination — you must base them solely on objective factors, including merit, qualifications, performance, and business considerations.

You must not discriminate in any way based on race, colour, religion, age, gender, sexual orientation, gender identity, marital status, disability, ethnic origin or nationality.

3.5 Use of IT and Electronic Communications

Renaissance supplies you with IT and electronic communications so you can conduct your work in a secure and compliant manner. Renaissance logs and monitors use of its IT equipment and any equipment connected via the Renaissance network.

Your responsibilities

• Comply with Renaissance IT security requirements.
• Do not use personal email accounts for work communications unless authorised.
• Do not share your Renaissance IT login details with others.
• Keep personal use of Renaissance IT and social media occasional and brief, and do not use the Renaissance name or brand in personal emails.
• Do not access, store, send or post pornography or other indecent, offensive or unlawful material.
• Only use approved internet-based services to store, process or share business information.

3.6 Protection of Assets

Renaissance assets come in many forms — physical, electronic, financial, and intangible. Whether it is a laptop, our brand, or a facility, we expect everyone to take diligent care of our assets.

• You are personally responsible for safeguarding and using Renaissance assets appropriately and protecting against waste, loss, damage, abuse, fraud, theft and misuse.
• Protect company property entrusted to you and be alert to the risk of theft.
• Do not unlawfully conceal, alter, or destroy documents.
• Only use your corporate credit card for reasonable and approved business expenses.
• Respect the assets of others.

4.1 Data Privacy

Data privacy laws safeguard information about individuals — their personal data. At Renaissance, we respect the privacy rights of our staff, customers, suppliers, and business partners, and are committed to managing personal data in a professional, lawful, and ethical way.

• Identify privacy risks before collecting, using, retaining, or disclosing personal data.
• Only process personal data for specific, defined, legitimate purposes.
• Always inform individuals when you process or share their personal data — and obtain consent where required.
• Always protect personal data when shared with a third party.
• Keep personal data up to date and dispose of it when no longer required.

4.2 Intellectual Property

At Renaissance, we have great brands, ideas, and technology which give us a great reputation that we all need to protect. It is equally important that we respect, and avoid infringing, the IP rights of others.

• Use Renaissance's brands and trademarks appropriately, following the Brand Standards.
• Report your innovations and inventions to Renaissance Legal.
• Classify and store Renaissance business and technical information appropriately, with appropriate access controls.
• Do not disclose Renaissance's confidential information outside Renaissance without permission or an appropriate written agreement.
• Do not accept or misuse the confidential information of a third party.

4.3 Information and Records Management

We depend on the use and exchange of information for our business decisions and day-to-day activities. We must create, use responsibly, and protect this information — especially personal details, commercially sensitive information, and intellectual property, both our own and that of others.

• Assess the risks associated with any information you handle.
• Assign a confidentiality classification, declare it as a Record if required, and store it in an approved Company repository.
• Only share information with those entitled and permitted to receive it.
• If instructed by Legal to preserve information, ensure it is kept as directed.

4.4 Disclosure and Business Communications

Everything we write or say reflects on Renaissance's reputation. All communications made to the public on behalf of Renaissance are subject to disclosure requirements and must be cleared by External Relations. Every public communication must be accurate, complete, relevant, balanced and compliant with applicable laws.

Use of personal social media for business purposes is strictly prohibited. If you use personal social media to discuss energy-related topics or endorse Renaissance, you must disclose that you are a Company employee, that you are not speaking on behalf of Renaissance, and that the views expressed are your own.

5.1 Anti-Bribery and Corruption

At Renaissance, we build relationships based on trust. For this reason, we never accept or pay bribes, including facilitation payments. Even unsubstantiated claims of bribery and corruption may damage our reputation. Everyone must comply with the anti-bribery and corruption (ABC) laws of the countries where we operate.

• Do not offer, pay, make, seek, or accept a personal payment, gift, or favour in return for favourable treatment or business advantage.
• Do not make facilitation payments — and report any that are requested or made.
• Know who you are doing business with by conducting appropriate due diligence.
• Follow the mandatory requirements when dealing with Government Officials.
• Report corrupt behaviour — turning a blind eye can result in liability for Renaissance and individuals.

5.2 Gifts and Hospitality

We discourage staff from accepting or offering gifts and hospitality (G&H) — especially those you would not be comfortable telling your manager, colleagues, family or the public about. Never allow G&H to influence business decisions or give others reason to suspect an influence.

• Do not offer, give, seek or accept illegal or inappropriate G&H, cash or cash equivalents, vehicles, personal services or loans in connection with Renaissance business.
• Do not exchange G&H when a business partner is absent or during periods when important business decisions are being made.
• Register all G&H above prescribed value limits in the designated Ethics & Compliance Register, and request advance approval where required.

5.3 Conflicts of Interest

Conflicts of Interest (COIs) may arise when your personal relationships, external activities or interests could influence — or be perceived to influence — your business decisions for Renaissance. You must avoid actual, potential, or perceived COIs where possible, and be transparent by entering the details in Renaissance's designated Register.

• Do not let decisions be influenced by personal relationships or outside interests of yourself, family or friends.
• Register all actual, potential, or perceived COIs, whether or not you think they will influence your decision.
• Consult your line manager, the Ethics & Compliance Team or Legal if you are unsure.
• Withdraw from decision-making that creates — or could be perceived as creating — a COI.

5.4 Anti-money Laundering

Money laundering occurs when the proceeds of crime are hidden in legitimate business dealings, or legitimate funds are used to support criminal activities, including terrorism. We must be on guard to protect our reputation and comply with the law.

• Do not knowingly deal with criminals, suspected criminals, or the proceeds of crime.
• Follow any due diligence requirement so we know who we are doing business with.
• Do not hide the origin or nature of criminal property, or facilitate its acquisition, ownership or control.
• If you suspect a counterparty is involved in money laundering, report it promptly to the Ethics & Compliance Team or the Helpline — and do not alert the counterparty.

5.5 Political Activity and Payments

You have the right to engage in lawful political activity in your own time, but you must keep personal political activities separate from your role at Renaissance.

• Do not use Renaissance funds or resources to fund political campaigns, parties, candidates, or political action committees (PACs).
• Do not use Renaissance funds for political payments disguised as charitable donations.
• Always make clear that political views you express are your own, not those of Renaissance.
• If standing for public office, consult and gain approval from your line manager, declare your interest, and comply with local laws.

5.6 Antitrust

Antitrust laws protect free enterprise and fair competition. We expect Renaissance staff to combat illegal practices including price-fixing, market sharing, output limitation or bid-rigging.

• Do not agree with competitors — even informally — to fix prices, reduce output, divide customers or markets, or rig bids.
• Do not boycott any customer or supplier except in connection with internationally imposed sanctions.
• Do not share or receive competitively sensitive information without a lawful reason.
• Leave industry meetings if competitively sensitive issues arise, ensure your departure is noted, and report it.
• Speak up if you know of, or are uncertain about, potentially anti-competitive practices.

5.7 Trade Compliance

We must comply with all applicable national and international trade compliance regulations — governing import, export and domestic trading of goods, technology, software and services, as well as international sanctions and restrictive trade practices.

• Obtain, retain and communicate correct customs and export control classification on all goods and software moved internationally.
• Ensure third parties are properly screened against applicable sanctions lists.
• Stop and seek legal assistance when dealings identify suspicious facts or ‘red flags’.
• Do not deal in a sanctioned country or with a sanctioned party unless specifically authorised.
• Seek legal advice when dealing with military, defence or drug-related items, or when confronted with a restrictive trade request.

6.0 Conclusion

Thank you for taking the time to read our Code of Conduct. It will help you understand the main risks to you and Renaissance and how you can safeguard Renaissance's reputation by knowing and understanding your responsibilities.

The Code cannot cover every situation, so whenever you are unsure of what to do, you must seek advice — from your line manager, the Renaissance Ethics & Compliance Team, Human Resources, Legal or the Helpline. This is especially relevant if you suspect that someone is violating the Code. In that case, it is your duty to speak up.

We hope you will refer to the Code whenever there are changes in your role, you face a new dilemma, or you just need to refresh your memory. Above all, we want you to live by the Code every day, and ensure you always make the right decision.