Akita Drilling 

Business Code of Conduct


This Corporate Code of Conduct is intended to guide employees’ activities to enhance value and to minimize situations where a conflict of interest could arise that could harm the Company or its employees. Every employee has a personal responsibility to comply with the letter and the spirit of this Corporate Code of Conduct.

Conflicts of Interest

Conflicts of Interest

Employees must avoid any situation that involves a conflict or appearance of a conflict between their personal interests and the interests of Xtreme Drilling Corp. or its subsidiary companies. In dealing with current or potential customers, suppliers, contractors, or competitors, employees must act in the best interests of Xtreme. Examples of a conflict of interest include, but are not limited to: gifts received by vendors, solicitors, or any agent that currently has or may have a working relationship with Xtreme. Real, perceived, or potential conflicts must immediately be fully disclosed to the employee’s supervisor or through other available reporting channels. Xtreme will investigate all reports concerning a conflict of interest and where appropriate will maintain the confidentiality of the reporter.


Xtreme is committed to increasing its value to customers, employees, shareholders, and other stakeholders through strategic investments in North America and internationally. Xtreme employees will fulfill this commitment while upholding the highest level of ethical conduct and meeting responsibilities as good corporate citizens. To achieve these objectives, Xtreme employees must:

  • Adhere to Xtreme or local jurisdictional standards, whichever are higher, for the safe operation of facilities, for the delivery of quality products and services, and the protection of the environment.
  • Treat all customers and suppliers in an honest and fair manner. Payments to suppliers must be for goods or services provided to Xtreme, approved at the appropriate level, and for no other purpose than that described in the documents supporting the transaction.
  • Conduct business with integrity and operate in compliance with all applicable laws and government regulations in the jurisdictions in which Xtreme conducts business.
  • Safeguard (including non-disclosure) Xtreme’s proprietary information, assets, and resources, as well as those of other organizations which have been entrusted to Xtreme.
  • Maintain all records accurately to clearly represent the relevant facts and the true nature of conditions and transactions.
  • Provide political contributions only where they are legal and in accordance with local custom or tradition. All contributions by Xtreme must be limited to amounts small enough to avoid suggestions of special consideration.
  • Provide a working environment in which all individuals are treated fairly and with respect and dignity. Workplace discrimination against any employee for any reason including race, color, sex, religion, national origin, age, disability, genetic information or any other reason prohibited by Federal, State or Local laws will not be tolerated.
Insider Trading

Insider Trading

Confidential Xtreme information (including, but not limited to, potential acquisitions, pending contracts or unannounced projects) may not be given or released, without proper authority, to anyone not employed by Xtreme, or to an employee not requiring the information to fulfill work-related commitments. All employees must comply with Xtreme’s Disclosure and Insider Trading Policy. Employees must respect financial disclosure laws. It is illegal to communicate or give a “tip” on inside information to others so that they may buy or sell stocks or securities.

Business Relationships

Business Relationships

Xtreme, as a company operating in a number of locations, must conduct business with the highest level of integrity and in full compliance with all regulations and laws in the appropriate jurisdiction.

Xtreme will not seek any advantage through improper use of business courtesies or other inducements. Good judgment and moderation must be exercised to avoid misinterpretation and adverse effect on the reputation of Xtreme or its employees. The direct or indirect offering, giving, soliciting, or receiving of any form of questionable consideration is prohibited.

All payments related to international transactions must be conducted according to the Foreign Corrupt Practices Act and all other laws and regulations that exist in both the U.S. and the respective country in which business is being conducted. Accordingly, these payments must be properly documented by written agreement, and recorded in the accounts in a manner that discloses their nature.

Compliance When In Doubt

Compliance When In Doubt

As a condition of employment, employees are expected to comply with this Corporate Code of Conduct and the underlying policies and procedures. When in doubt, employees have the responsibility to seek clarification or advice from management. It is important that documentation is created at the time of disclosure and resolution.

All employees, Xtreme, and its other stakeholders benefit from good ethical practices. Employees who suspect misconduct, fraud, or abuse of Xtreme assets or other violations of this code of conduct are responsible for reporting such matters to their supervisor, or to the CFO. Employees may, in sensitive situations, also anonymously report a violation of this Corporate Code of Conduct using the Silent Whistle Alert Line.


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