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Conduct and Business Ethics (CoBE)

(Revised effective 1/4/2026)

Our Code of Conduct and Business Ethics (“CoBE”) sets out detailed policy statements on the standards of behaviour and ethical conduct expected of each individual to whom the CoBE applies. It provides the foundation for integrity and ethical decision making – the cornerstone of the trust we have built with our stakeholders over the years.

Taking a principles-based approach, each section of the CoBE contains key principles, practical guidance, decision making prompts, and references to additional resources to help clarify its application. Wherever we operate, our conduct is guided by the highest standards.

For previous version of the CoBE, click HERE

CoBE Country Supplement

In view of the CoBE’s international application, certain provisions of the CoBE will be modified to meet the requirements of the local jurisdictions in which PETRONAS is operating. The country supplements ensure our CoBE remains robust and caters to the respective local jurisdiction’s applicable legislations.

CoBE Guide

The CoBE Guide is a practical, user-friendly resource that illustrates how the CoBE applies in practice. It offers examples, decision-making tips and direction on where to seek further advice, making it easier for everyone to understand how to translate principles into action.

Read more:
• PETRONAS Code of Conduct and Business Ethics (CoBE) (Revised)
• CoBE Guide

PETRONAS is committed to conducting business with the highest standards of integrity, ethics, and transparency. The CoBE is supported by the PETRONAS Anti-Bribery and Corruption Policy (“ABC Policy”) and the PETRONAS Anti-Bribery and Corruption Standard (“ABC Standard”). 

The ABC Policy and the ABC Standard is applicable to all employees, directors, and third parties working for or on behalf of the PETRONAS Group. We also seek to work with business partners who share our values and commitment to ethical conduct and compliance with applicable laws and regulations.

PETRONAS enforces zero tolerance for all forms of bribery or corruption, and we hold ourselves, and those who work with us, accountable to these principles. Our zero-tolerance strictly prohibits facilitation payments, kickbacks, and political contributions. Any violation may result in disciplinary action, including termination of employment or business relationships.

To ensure accountability and manage risk across our value chain, all third parties, including potential business partners, must undergo PETRONAS’ Third-Party Risk Management programme. The PETRONAS ABC Policy, PETRONAS ABC Standard, together with the PETRONAS Integrity Compliance Framework, further strengthens our culture of integrity across the Group.

Read more:

• PETRONAS Anti-Bribery and Corruption Policy
• PETRONAS Anti-Bribery and Corruption Standard

The Anti Money Laundering Policy reinforces PETRONAS’ commitment to preventing and detecting money laundering and terrorism financing activities within PETRONAS Group. We are committed to adhering to all applicable anti-money laundering laws and implementing adequate measures to strengthen our anti-money laundering governance. PETRONAS strictly opposes any practices related to money-laundering. 

This Policy applies to every director, employee and third party working for or on behalf of PETRONAS. Joint venture companies where PETRONAS is not a controlling shareholder and associate companies of PETRONAS are encouraged to adopt this policy or implement similar principles and standards.

Read more:

• PETRONAS Anti-Money Laundering Policy

The PETRONAS Whistleblowing Policy encourages the reporting in good faith about any improper conduct within PETRONAS as well as any non-compliance by a third party where this could affect PETRONAS.

We encourage our employees, directors and members of the public to report concerns they may have, anonymously if they wish, and without fear of retaliation. The concerns must be reported through the designated reporting channels and will be deliberated by the relevant Whistleblowing Committee, established in accordance with applicable local laws. Regular updates on whistleblowing matters are provided to the Board Risk Committee.

Read more:

• PETRONAS Whistleblowing Policy

To lodge a report, please visit our Whistleblowing page.

The Non Retaliation Policy encourages employees, directors and members of the public to speak up without fear of retaliation. Any form of retaliation against a reporting party or person involved in an investigation is strictly prohibited and constitutes serious misconduct.

Concerns relating to retaliation must be raised through the designated reporting channels and will be assessed in accordance with internal governance processes to ensure fairness, confidentiality and appropriate protection.

Read more:

• PETRONAS Non-Retaliation Policy

PETRONAS Privacy Policy outlines the core principles we adhere to when collecting, using, processing, and storing personal data. These principles include ensuring a valid legal basis for processing personal data, providing necessary notices and information to individuals, ensuring data accuracy, retaining data no longer than necessary, maintaining data security, and respecting data subject rights.

Benchmarked against global privacy programmes and best practices, the PETRONAS Privacy Standard further elaborates on the implementation of these principles and form part of PETRONAS' personal data protection and privacy compliance programme. PETRONAS continuously enhances and improves its governance documents related to data privacy to comply with evolving data protection laws and regulations and ensures that they are adopted and implemented across the group. These efforts reflect PETRONAS' unwavering commitment to safeguard personal data across its business operations, both domestically and globally.

Read More:

• PETRONAS Privacy Policy (English)
• PETRONAS Privacy Statement (English)
• PETRONAS Privacy Statement (Malay) 
• Privacy Policy Annex United Kingdom / European - English 
• Privacy Policy Annex Brazil - English
• Privacy Policy Annex Brazil - Portuguese 
• Privacy Policy Annex Argentina - English
• Privacy Policy Annex Argentina - Spanish

PETRONAS is committed to conducting its business activities in full compliance with applicable global competition laws.
This policy reflects PETRONAS’ commitment to ensuring compliance with competition laws in respect of all business activities undertaken by the PETRONAS Group of Companies.

Read more:

• PETRONAS Competition Law Policy

PETRONAS is committed to comply with applicable sanctions and export control laws wherever it operates. 
This policy reflects PETRONAS’s commitment in observing good business practices consistence with international norms and standards relating to sanctions and export control.

Read more:

• PETRONAS Sanctions and Export Control Policy

This policy contains our overarching commitment to respect human rights, which is also reflected in other policies, frameworks, guidelines and processes throughout our business

Policy Statement

PETRONAS is committed to respecting all internationally recognised human rights, as set out in the International Bill of Human Rights and the International Labour Organization's Declaration on Fundamental Principles and Rights at Work, being guided by the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, complying with all applicable laws in the countries in which we operate.

Delivery

Respect and acknowledgement of internationally recognised human rights
We are committed to respecting the human rights of all people who are impacted by our activities, as well as respecting diversity and inclusion, elimination of all forms of discrimination as defined by applicable laws, modern slavery, child labour and human trafficking.

Adoption of a risk-based approach to human rights due diligence
Areas of material importance include labour and working conditions, supply chain, responsible security, communities' well-being and how they are impacted by, among other things, climate change, environmental issues and energy transition.

We apply a risk-based due diligence approach to identify, prevent, mitigate and address actual and potential adverse human rights impacts arising from activities performed across the organisation, and resulting directly from our operations, products or services, with a focus on significant risks and priority areas, and with input from engagement with relevant stakeholders.

Access to effective grievance mechanisms and remedies
We are committed to providing for and cooperating in the remediation of adverse human rights impacts that we identify we have caused or contributed to. Our grievance mechanisms are designed to be confidential, reasonably prompt, non-retaliatory and fair. We seek to ensure that our grievance mechanisms are accessible to all stakeholders, including within and outside our organisation.

Governance & Implementation

This policy is approved by the Board of Directors and its implementation is overseen by the leadership team. Human rights management in PETRONAS is guided by supporting documents, including our Code of Conduct and Business Ethics (CoBE) and our Contractors Code of Conduct on Human Rights (CoCHR)

This policy applies to every employee, director, and officer of PETRONAS. Third parties that may perform works or services for or on behalf of PETRONAS and joint venture companies in which PETRONAS is not a controlling stakeholder and associate companies of PETRONAS are encouraged to adopt this Policy of similar principles and standards.

Click here to view PETRONAS Human Rights Policy

PETRONAS Contractors Code of Conduct on Human Rights

In compliance with PETRONAS Human Rights Policy, we seek to work with contractors who share our values of integrity, are committed to fighting bribery and corruption, and contribute to sustainable development.

PETRONAS requires its contractors to:

1. Respect internationally recognised human rights, complying with PETRONAS’ Code of Conduct and Business Ethics (CoBE) and all relevant legal requirements.
    
2. Take reasonable steps to ensure that policies and guidelines with respect to human rights are in place and adhered to by any party performing work and/or business for or on behalf of PETRONAS. These policies and guidelines shall include labour rights, workplace health and safety, security, and conditions of employment. These policies and guidelines shall be made known to employees, workers, and contract personnel in languages they understand.
    
3. Sign an attestation confirming compliance with the CoCHR.
    
4. Identify, mitigate, and address human rights risks, at a minimum on risks relating to forced labour, child labour, labour rights, non-discrimination, freedom of association, and humane treatment (“material risks”).
    
5. Provide human rights awareness training to employees, workers, and contract personnel and ensure that all employees, workers, and contract personnel providing works or services to PETRONAS attend the training.
    
6. Establish a grievance mechanism for its employees, workers, contract personnel and any party involved in providing works or services to PETRONAS. This grievance mechanism shall be made known to them and in languages they understand. The grievance mechanism shall have appropriate follow-up measures while ensuring that the identity of the complainant is protected.
    
7. Systematically close actual and potential adverse human rights impacts through time-bound corrective action plans.
    
8. Provide access to remedy and cooperate in the resolution process of impacted stakeholders where the contractors have caused or contributed to adverse human rights impact.
    
9. Take reasonable steps to embed safeguards for human rights in supply chain processes; ensure appropriate governance frameworks are applied to non-compliant high-risk contractors and subcontractors.
    
10. Provide timely feedback to PETRONAS regarding human rights performance as gathered through personnel engagements, questionnaires and other appropriate means as required.

In line with the above, contractors shall ensure adherence to the following material risks:

1. Forced Labour, by not engaging or employing people, under any circumstances, against their own free will or engaging in bonded labour/debt slavery.
    
2. Child Labour, by not employing children below the legal minimum working age requirement of any country.
    
3. Labour Rights, by upholding the rights and welfare of their employees, workers, and contract personnel (both local and foreign) through compliance with all applicable laws and agreements related to compensation and working conditions. This includes adherence to minimum wage, overtime pay, legally mandated benefits, and the maximum number of working hours. Contractors must also respect local laws or collective agreements that govern overtime work and holiday work, ensuring that their operations do not exploit employees, workers, and contract personnel and provide them with fair compensation for their labour.
    
4. Non-Discrimination, by not engaging in any form of unlawful discrimination based on race, ethnicity, colour, age, gender, gender identity or expression, sexual orientation, political beliefs, citizenship, national origin, religion, disability, parental status, economic/class status, or unrelated characteristic in hiring and employment practices.
    
5. Freedom of Association, by respecting the legal rights of employees, workers, and contract personnel to become members of a labour union or otherwise.
    
6. Humane Treatment, by respecting rights of employees, workers, and contract personnel and ensuring no harsh and inhumane treatment, including any form of mental or physical coercion, or verbal abuse of employees, workers, and contract personnel.

PETRONAS will assess contractors' compliance from time to time. Failure by contractors to comply with the requirements set out in the CoCHR may result in actions taken by PETRONAS, including terminating the non-complying party’s relationship with PETRONAS and other measures.

The CoCHR applies to any parties performing work or services for or on behalf of PETRONAS and those holding PETRONAS’ license and/or registration. It is the contractors’ obligation to ensure that any parties performing work and/or business to PETRONAS for or on its behalf adhere to the CoCHR as well.