ETHICS AND GOVERNANCE

Good corporate governance will be implemented successfully if it is supported by a strong corporate culture. The Company has therefore developed a corporate culture founded on a series of principles collectively known as ProCISE, or Professionalism, Continuous Improvement, Integrity, Safety and Excellent Service. ProCISE has been disseminated throughout PGN's employees and management, and change agents have been selected to support the internalization of the ProCISE values in each individual's working activities. Every PGN employee has signed the PGN Employees Culture Book as a tangible sign of their commitment to the application of the ProCISE values.

Code of Conduct

Based on the corporate culture and values, as well as the principles of good corporate governance, PGN has drawn up a code of conduct for its employees, issued as the "Employee Code of Ethics" and the"Leader Code of Ethics." The Employee Code of Ethics sets forth the conduct expected of employees in their day-to-day work, and the procedures or rules for their interaction with stakeholders. The Employee Code of Ethics also provides practical guidance on dealing with conflicts of interest, corruption, bribery, gratuities, information management and so on. The Leader Code of Ethics explains the conduct expected of managers in doing their jobs. The Employee Code of Ethics and the Leader Code of Ethics have been disseminated throughout the Company and must be adhered to by all PGN employees.