Helical is committed to ethical behaviour and recognises the risk of the being drawn in bribery or corruption due to the nature of its business and is committed to complying with all relevant national and international laws and conventions relating to bribery and corruption.

As part of the Company's code of conduct all employees are expected to follow the Company's anti-bribery and corruption policy.

The Chief Executive of the Company is responsible for periodically reviewing any potentially high risk projects or transactions to ensure that they comply with this policy. The Chief Executive will decide what constitutes a high risk project or transaction but the criteria include: the country in which the project is taking place, the nature of the contract and the counterparties of the contract. The Chief Executive reports the detail of his reviews to the Board on an annual basis or more frequently if appropriate.

Any contravention of the Company's policy is reported to the Board of directors and appropriate action as decided by the Company's management will be taken.

As at January 2009 no violation of the policy has ever been identified.