Allegiance Refining, LLC, together with its subsidiaries and affiliates, including but not limited to The San Antonio Refinery LLC (collectively “ARL” or “We” or “Our”), are committed to conducting our business in compliance with both applicable law and the highest ethical standards. ARL engages third parties (“Vendors”) to provide products and services to ARL. As part of its commitment to appropriate business conduct and ethics, ARL strives to engage only those Vendors who treat their workers with dignity and respect, maintain decent and healthy working conditions, adhere to all applicable laws, rules, and regulations, and make their products and offer their services in a safe and environmentally sound manner. ARL expects and holds its Vendors accountable for conducting business in a lawful, honest, and responsible manner.

 

Accordingly, we require each Vendor and their representatives and subcontractors to conduct their business interactions and activities ethically, with integrity, and in accordance with their obligations under their specific agreements with ARL and to adhere to and comply with the following Vendor Code of Conduct (the “Code”).

 

This Code defines our minimum expectations. No code of conduct can be all-inclusive, but we expect those Vendors with whom we do business to act reasonably in all respects and to ensure that no abusive, exploitative, or illegal conditions exist at their workplace.

 

VENDOR BUSINESS RELATIONSHIPS WITH ARL

 

ARL selects its Vendors based on the ability of the Vendor to add value to ARL through the provision of goods or services, regardless of whether that Vendor, in turn, will purchase any products from ARL. ARL may consider the following factors in its business decisions: A Vendor’s competitive pricing, quality of services and materials provided by the Vendor, a Vendor’s ability to timely perform, and whether the Vendor agrees to abide by this Code.

 

ARL has the following expectations of our Vendors:

 

Conflicts of Interest

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All business decisions ARL employees make must be free from any conflict of interest and appear impartial. A conflict of interest occurs when an employee or Vendor’s private activities conflict or appear to conflict with his or her responsibilities to ARL. All employee conflicts of interest, including those involving Vendors, must be disclosed fully in writing to the employee’s supervisor and ARL’s Human Resources department for review as soon as the conflict is known.

 

A familial or intimate relationship between an employee and a Vendor can create an actual or at least potential or perceived conflict of interest. To avoid this problem, ARL will not hire a Vendor’s relative or other intimately associated individuals where the potential for favoritism or a conflict exists, with very few exceptions. For the purposes of this Code, a relative is any person who is related by blood or marriage or whose relationship with the employee is similar to that of persons who are related by blood or marriage (e.g., domestic partnership or civil union status).

 

Vendors must avoid interactions with ARL employees that create or appear to create conflicts of interest. Vendors should never provide incentives or offers of employment to ARL employees, their families, or their friends in an effort to obtain or maintain a business relationship with ARL.

 

Gifts and Entertainment

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ARL recognizes that gifts and entertainment can play an important role in business relationships, especially those involving our Vendors. However, ARL employees are limited in their ability to accept gifts and entertainment from Vendors, and business entertainment expenditures are monitored closely. Under the ARL’s Conflicts of Interest Policy and accounting policies for employees:

 

• Entertainment, gifts, or other gratuities must have a legitimate business purpose.

• Entertainment must be legal, reasonable, and consistent with legal and ethical limitations. All ARL business entertainment expenditures must be made in compliance with the provisions of its Conflicts of Interest Policy and applicable ARL travel expense policies.

• ARL employees cannot accept personal gifts or entertainment from competitors, customers, Vendors, or potential Vendors in excess of $100 in value.

• ARL Employees must not solicit loans, gifts, or favors from Vendors. 

• ARL employees must record all business entertainment expenses and receive approval from a supervisor for such expenditures.

• ARL cannot have a direct or indirect financial interest in or relationship with a competitor, customer, or Vendor, except that ownership of less than one percent (1%) of the publicly traded stock of a corporation will not be considered a conflict.

 

VENDOR CONDUCT        

 

ARL abides by the law, treats employees and contractors fairly and with respect, is a good steward of the environment, and supports the communities where we work. ARL strives to engage Vendors who embrace and abide by these values in their operations.

 

ARL is committed to abiding by a higher standard of ethical conduct and seeks out Vendors who are likewise committed to complying with the following conduct requirements:

 

Commitment to Legal and Ethical Business Conduct

 

Vendors must conduct business ethically and always ensure that their operations are compliant with the law.

 

• Professional Standard of Care

Vendors must act in good faith and should not quote, provide, or continue to provide goods or services that are not in ARL’s best interest or do not add value to ARL. If a Vendor becomes aware that an aspect of its work is no longer in ARL’s best interest or does not add value to ARL, the Vendor should contact ARL immediately and stop work if necessary until appropriate guidance is obtained.

 

• Accurate Accounting and Business Records

Vendors will maintain, and provide to ARL, as requested, accurate records of all aspects of their business with ARL.

 

• No Bribery, Corruption, Extortion, or Embezzlement

ARL does not condone bribery, corruption, extortion, or embezzlement of any kind. Accordingly, ARL requires its Vendors not to engage in any of these behaviors and to comply with the U.S. Foreign Corrupt Practices Act and all other local, federal, or applicable laws dealing with bribery of government employees or officials.

 

• Fair Competition

  Vendors must abide by all applicable fair competition and antitrust laws.

 

• Sanctioned Parties

Vendors must not source services or equipment from individuals or entities that are individually or by reason of their location, subject to economic sanctions, prohibitions, or other restrictions imposed by the U.S. or the U.N.

 

• Data Privacy and Information Security

Vendors must protect sensitive data and confidential information they receive or are made aware of through interactions with ARL, including, but not limited to, customer information, employee information, technology, and trade secrets. Transfer of these types of information must be undertaken only when necessary precautions are in place and due care is exercised.

 

• Intellectual Property

Vendors shall display the highest standard of respect and legal and ethical behavior with regard to the intellectual property rights of third parties. Vendors must ensure that the products or services sold and/or provided to ARL do not violate the patent, trademark, copyright, or any other proprietary rights of any third party.

 

Commitment to Employees

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ARL is committed to providing a work environment where all employees are treated fairly and respectfully. Likewise, we expect our Vendors to similarly cultivate respectful work environments by:

 

• Respecting Freedom of Association and Collective Bargaining Rights and abiding by applicable laws related to labor unions;

• Never Discriminating in Hiring, Employment, or Compensation based on race, sex, religion, color, sexual orientation, disability, age, national origin, gender identity, gender expression, genetic information, veteran status, political preference, or membership or non-membership in any lawful organization;

• Creating a Workplace Free of Harassment or any other form of abuse, including sexual harassment or abuse, through compliance with all applicable laws regarding harassment and abuse;

• Preventing Involuntary or Under Age Labor and refusing to engage in human trafficking, slavery, child labor, prison labor, indentured labor, or bonded labor; and

• Establishing Appropriate Work Hours and Wages through compliance with applicable laws and regulations regarding work hours, overtime, wages, and benefits.

 

Commitment to Health, Safety, and the Environment

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Protecting people and the environment is a key value at ARL. One of ARL’s values is to be good stewards of the assets we operate and remain committed to being safe and environmentally responsible. We protect the health and safety of people and the quality of the environment and conduct our operations reliably and efficiently. Accordingly, ARL’s Vendors must be similarly committed to protecting their employees, the environment, and the communities in which they operate by:

 

• Respecting the Environment through compliance with all applicable environmental laws;

• Implementing Waste and Emissions Systems to ensure that waste, air emissions, and wastewater discharges are minimized and managed safely and appropriately;

• Protecting Health and Safety by providing appropriate training, protocols, controls, procedures, and equipment; and

• Implementing and Abiding by Health and Safety Rules and Regulations to ensure employee safety and health.

 

Commitment to Compliance

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ARL expects its Vendors to demonstrate their commitment to compliance with this Code, as well as applicable laws, rules, and regulations, by implementing systems and protocols necessary to ensure compliance. Vendors should also apply this Code or other similar principles in dealings with subcontractors and suppliers used in connection with ARL business.

 

ARL may cancel, terminate, or suspend its business relationship with any Vendor who fails to comply with this Code or all applicable local, state, and federal laws and regulations. ARL reserves the right to assess, investigate, and monitor Vendor compliance with this Code. Vendors who fail to comply will be expected to take corrective action. If corrective action is not taken, ARL will terminate the relationship and related business contracts.

 

QUESTIONS

 

If you have questions about any of the information in this Code or what is expected of you, please contact our Human Resources department