Conflict of Interest Policy

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You have a responsibility to disclose or avoid any activity that conflicts with United Gulf
Shadows and its sub companies interests. A conflict of interest exists when your personal
interest or activity interferes or appears to interfere with the duties that you perform or owe to
the Company.
You should always be on the lookout for situations that may create a conflict of interest, and do
everything you can to avoid those situations. The following are some of possible conflicts of
interest:

Using company time, resources, or influence to promote personal interests or the

interests of third parties.

Conducting Company business with relatives or dealing with business in which you or

relative has a significant interest.

Availing yourself of opportunities for self-enrichment that is discovered through
knowledge gained in the performance of an assigned function or through the use of

contacts, information, products, or service related to or obtained from the Company.

Acquiring or maintaining a direct ownership interest in any business enterprise of a

competitor, client, supplier, or vendor of UGS.

Accepting tips or gifts from clients, vendors, or other third parties.

You are responsible for telling your supervisor about any situation or activity that you think may
be a conflict of interest. Failing to disclose actual or potential conflicts of interest may result in
disciplinary action, up to and including termination.