The Anti-Corruption Policy is an essential part of Ventura Offshore’s compliance program, reflecting the senior management's commitment to ensuring compliance in its activities and establishing internal rules that must be observed by employees, representatives, and associates of Ventura Offshore when acting on its behalf.

The Anti-Corruption Policy complies with Brazilian laws as well as foreign laws that set international parameters for corporate conduct, such as the Foreign Corrupt Practices Act (FCPA) of the United States and the UK Bribery Act of the United Kingdom.  This Policy must be applied in conjunction with the principles and rules established in the Code of Ethical Conduct and in its other policies and procedures.