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MIDSTREAM AND DOWNSTREAM PETROLEUM CODE OF CONDUCT REGULATIONS, 2023

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entities is undertaken on a transparent arm’s length basis and in a 
manner that reflects the pricing principles contained in the Act; 
and 
(g) not release from its employment a senior staff except with the prior 
authorisation of the Authority and in accordance with the 
Framework for Staff Release the Nigerian Midstream and 
Downstream Petroleum Industry in the First Schedule to these 
Regulations. 
 
(2) The code of business conduct and ethics referred to in this regulation 
shall take into account the legal obligations and reasonable 
expectations of the company’s stakeholders, as well as the responsibility 
and accountability of individuals reporting on issues of unethical 
practices. 
 
(3) The code shall be reviewed at least once every five years provided 
that the Authority may direct further reviews of the code prior to the 
expiration of the five-year period. 
 
 
 
 
First Schedule 
9. A licensee or permit holder shall comply with the provisions of 
Recommended 
Practice 
26 
of 
Nigerian 
Code 
of 
Corporate 
Governance in force as well as the requirements of the Midstream and 
Downstream 
Petroleum 
Sustainability 
Governance 
Framework 
published by the Authority. 
Sustainability 
 
 
 
10. A company shall develop and implement an annual corporate social 
responsibility plan.  
Corporate social 
responsibility 
11. The Board shall develop and adopt a policy the management of 
conflict of interest. 
 
Conflict of interest 
 
12. (1) A company shall ensure adequate stakeholder communication 
and engagement. 
 
(2) A company shall have forums, at least once a year, where 
stakeholders and customers are encouraged to express their concerns on 
the operations of the company. 
 
Stakeholder 
communication 
13. A company shall submit to the Authority, an annual report on matters 
connected with these Regulations. 
 
Submission of 
annual reports