BP PLC

The company has adopted a code of ethics for its chief executive officer, chief financial officer, SVP accounting, reporting and control and SVP internal audit whose roles are equivalent to the SEC roles as required by the provisions of Section 406 of the Sarbanes-Oxley Act of 2002 and the rules issued by the SEC. There have been no waivers from the code of ethics relating to any officers. A copy of the code of ethics can be found at bp.com/codeofethics.

The NYSE rules require that US companies adopt and disclose a code of business conduct and ethics for directors, officers and employees. bp has adopted a code of conduct, which applies to all employees, officers and members of the board. This was updated and published in January 2023. In addition, bp has adopted a code of ethics as described above for the chief executive officer, chief financial officer, SVP accounting, reporting and control and SVP internal audit as required by the SEC. bp considers that these codes and policies address the matters specified in the NYSE rules for US companies. During 2021, the board adopted a diversity policy, which requires it to encourage a diverse and inclusive working environment in the boardroom, where everyone is accepted, valued and receives fair treatment according to their different needs and situations without discrimination or prejudice. The policy was reviewed by the board in 2022, and amendments were made to reflect regulatory changes and market practice. The updated policy was then approved and published in February 2023.