It is Company policy that all employees are responsible for assuring that the work place is free from sexual harassment. The Company does not condone or excuse sexual harassment of any kind. Sexual harassment by management and supervisory staff, co-workers, and non-employees over whom the Company exercises some measure of control will not be tolerated on or off Company premises.

Because of the Company’s strong disapproval of offensive or inappropriate sexual behavior with respect to the work place, all employees must avoid any action or conduct which could be viewed as sexual harrassment. Therefore, under this policy, the following acts are specifically prohibited:

Granting or denying job benefits based on receptivity of sexual advances or threatening or insinuating either expressly or implying that an employee’s refusal to submit to sex;

Sexual advances, requests for sexual favors, and verbal or physical conduct of a sexuall harassing nature;

Intimate relationships between supervisory and subordinate employees on or off Company premises which may affect the supervisor’s treatment of the employee with respect to his or her terms and conditions of employment.

A working environment of unwelcome sexual conduct that has the purpose or effect of unreasonably interfering with an affected person’s work performance or creating an intimidating, hostile or offensive work environment; and

Sexual slurs, vulgar jokes, display of sexually explicit pictures, or other sexually offensive conduct.

Any employee who has a complaint of sexual harassment with respect to the workplace by anyone including supervisors, co-workers, visitors, contractors, customers or any other person over whom the Company exercises some measure of control should immediately bring the problem to the attention of a CITGO Manager or Supervisor, or the Human Resources Department.

All complaints will be promptly handled on a confidential basis. The Company will retain confidential documentation of all allegations and investigations and will take appropriate corrective action to remedy all violations of this policy. Corrective action may include disciplinary action up to and including termination of employment or termination of the business relationship for persons found to have engaged in sexual harassment.