ALLIANZNEFTPRODUKT LLC

Allianz Nefteprodukt is strongly committed to conducting its business affairs with honesty and integrity and in full compliance with all laws, rules and regulations applicable.Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships; Avoidance of conflicts of interest, including disclosure to an appropriate person of any material transaction or relationship that reasonably could be expected to give rise to such a conflict; Full, fair, accurate, timely and understandable disclosure in reports and documents that the Corporation files with, or submits to, the securities regulators and in other public communications made by the corporation;Compliance with applicable governmental laws, rules and regulations; The prompt internal reporting to an appropriate person or persons of violations of this Code; Accountability for adherence to this Code. The Corporation will expect all its employees, officers and directors to comply and act in accordance, at all times, with the principles stated above and the more detailed provisions provided hereinafter. Violations of this Code by an employee or officer or director are grounds for disciplinary action up to and including immediate termination of employment, officership or directorship.It is not possible to enumerate all of the situations that could result in an actual or apparent violation of this Code. The following areas are, however, of particular concern to the Corporation with respect to the ethical conduct of the Corporation's business.