Oil Finder

Policies & Compliance

Gulf Pacific Lubricants FZC (“GPL”, “the Company”) is a privately held company based in the United Arab Emirates. We are committed to conducting business ethically, responsibly, and in compliance with applicable laws and regulations. The policies below define our expectations for employees, contractors, and business partners.

  • Applies To: All employees, officers, directors, temporary staff, contractors, and agents acting on behalf of GPL.

Table of Contents

1. Code of Conduct & Employee Behaviour

GPL requires all personnel to:

  • Act honestly, fairly, and professionally in all business activities.
  • Comply with all applicable laws, regulations, and internal procedures.
  • Avoid discrimination, harassment, bullying, intimidation, or unsafe behaviour.
  • Protect confidential information, company property, and intellectual property.
  • Use company resources responsibly and for legitimate business purposes.
  • Maintain accurate and truthful business records and communications.
  • Report suspected violations promptly without fear of retaliation.

Viscosity Retention & Shear Stability

GPL is committed to a safe and respectful workplace. Any form of harassment, abuse, threats, or discrimination is prohibited.

Confidentiality

Employees and contractors must protect confidential information relating to GPL, its customers, suppliers, pricing, formulas, specifications, contracts, and internal processes.

Reporting & Non-Retaliation

GPL encourages good-faith reporting of concerns. Retaliation against anyone who reports a concern in good faith is prohibited.

Disciplinary Action

Violations may result in disciplinary measures up to and including termination and/or legal action.

2. Anti-Fraud Policy

GPL maintains zero tolerance for fraud, theft, falsification, or misrepresentation.

Fraud includes (but is not limited to):

  • Theft or misuse of company funds, inventory, or assets.
  • False invoicing, kickbacks, or improper payments.
  • Falsifying documents, financial records, test reports, quality documents, or approvals.
  • Manipulating procurement, tenders, bids, quotations, or contracts.
  • Intentional misstatements to customers, suppliers, banks, or authorities.

Controls & Responsibilities

  • Transactions must be supported by legitimate documentation and approvals.
  • Financial controls must be followed (segregation of duties where feasible).
  • Procurement must be based on transparent and documented decision-making.

Reporting

Suspected fraud must be reported immediately to management or the compliance contact listed below.

3. Anti-Bribery & Anti-Corruption Policy

GPL has zero tolerance for bribery and corruption in any form.

Prohibited Conduct

  • Offering, giving, requesting, or accepting bribes, facilitation payments, or any improper advantage.
  • Providing anything of value to influence a business decision improperly.
  • Using third parties (agents, consultants, intermediaries) to conduct prohibited acts.

Gifts, Hospitality, and Entertainment

  • Must be reasonable, modest, infrequent, and lawful.
  • Must not create a conflict of interest or appear to influence decisions.
  • Cash or cash equivalents (gift cards, vouchers) are prohibited.

Third Parties

GPL expects third parties acting on our behalf to follow equivalent anti-corruption standards. Where applicable, GPL may conduct due diligence and may terminate relationships for non-compliance.

Books & Records

All transactions must be accurately recorded. Off-the-books accounts and misleading entries are prohibited.

4. Conflict of Interest Policy

All personnel must avoid situations where personal interests conflict (or appear to conflict) with GPL’s interests.

Examples of conflicts:

  • Financial interest in a supplier, customer, competitor, or tender participant.
  • Family relationships that influence hiring, procurement, or contracting decisions.
  • Accepting improper gifts, discounts, commissions, or personal benefits.
  • Outside employment or business activities that affect performance or create risk.

Disclosure

Conflicts must be disclosed promptly to management. GPL will review and determine mitigation measures (recusal, reassignment, or other controls).

5. ESG Policy (Environmental, Social, Governance)

GPL is committed to responsible operations aligned with practical ESG principles.

Environmental

  • Comply with applicable UAE environmental laws and regulations.
  • Minimize waste and prevent spills, leaks, and environmental contamination.
  • Promote safe handling, storage, and disposal of oils, chemicals, and waste.
  • Encourage efficiency initiatives (energy, water, packaging) where feasible.

Social

  • Provide a safe workplace and promote health & safety culture.
  • Respect human rights and prohibit forced labour and child labour.
  • Promote equal opportunity and fair treatment.

Governance

  • Maintain ethical business conduct, transparency, and accountability.
  • Maintain accurate records and support compliance controls.
  • Encourage reporting of concerns without retaliation.

6. Sanctions & Restricted Parties Compliance

GPL does not knowingly conduct business with sanctioned or restricted parties where prohibited by applicable laws/regulations.

Scope

This includes restrictions and sanctions regimes that may apply through:
  • The UAE
  • The United Nations
  • The European Union
  • The United Kingdom
  • The United States (including OFAC), where relevant to counterparties, banks, payments, or cross-border trade

Controls

  • GPL may perform reasonable screening of customers/suppliers/logistics/agents where required.
  • If screening identifies a potential match, GPL will pause the transaction and review before proceeding.

7. Criminal Offence / Misconduct Declarations

Company Statement

To the best of GPL’s knowledge, the Company has not been convicted within the past 15 years of offences relating to:
  • Corruption or bribery
  • Fraud or misconduct
  • Money laundering or tax evasion
  • Other criminal activities or unethical business practices
  • Breaches of sanctions regimes and/or regulatory frameworks
  • Labour-rights or environmental violations

Key Executives Statement

To the best of GPL’s knowledge, none of the Company’s key executives have been convicted within the past 15 years of any civil or criminal offence in connection with their employment relating to:
  • Corruption or bribery
  • Fraud or misconduct
  • Money laundering or tax evasion
  • Other criminal activities or unethical business practices
  • Breaches of sanctions regimes and/or regulatory frameworks
  • Labour-rights or environmental violations
Note: If any confirmation is required in a specific legal format for a particular onboarding process, GPL will review and respond on a case-by-case basis.

8. Public Officials / Government Interaction (Including Outside UAE)

GPL may interact with public officials strictly for legitimate business purposes such as customs clearance, permits, inspections, registrations, and compliance processes.

Rules

  • No bribes, facilitation payments, or improper advantages are permitted.
  • Any government interaction must be documented and transparent.
  • Use of agents/intermediaries must follow GPL's anti-corruption expectations.
  • Where operations involve jurisdictions outside the UAE, GPL will comply with applicable local laws and relevant cross-border compliance requirements.

9. Reporting, Enforcement & Contact

Reporting

All employees and contractors must report suspected violations of these policies.

Non-Retaliation

GPL prohibits retaliation against anyone who raises a concern in good faith.

Contact

For compliance questions or reports, contact:

Frequently Asked Questions

Does GPL have a Code of Conduct?
Yes. Gulf Pacific Lubricants FZC maintains a comprehensive Code of Conduct & Employee Behaviour policy. See Section 1 above.
Yes. GPL maintains zero-tolerance Anti-Fraud and Anti-Bribery & Anti-Corruption policies. See Sections 2 and 3 above.
GPL does not knowingly conduct business with sanctioned parties where prohibited by applicable laws and may apply reasonable screening where required. See Section 6 above.
These policies are intended to communicate GPL’s standards of ethical conduct and compliance expectations. GPL reserves the right to update these policies as needed.