Commitment

We believe the only way to do business is with integrity and mutual respect, reflected in all Company relationships, including those with shareholders, suppliers, employees, governments, regulators and communities. We endeavour to comply with established standards of ethical behaviour in all aspects of our activities at and for the Company. These standards apply to relationships both within and outside the Company. For example, Talisman employees must adhere to the Company’s Insider Trading Policy and must never pursue improper personal gain or compensation from employment activities, Company property, information or position.

To help our employees meet those expectations, Talisman has clearly defined its corporate position regarding conflicts of interest, confidentiality of corporate information, compliance with laws, integrity in business dealings, compliance with accounting policies, public disclosure and compliance with Anti-Bribery Legislation within our revised Policy on Business Conduct and Ethics.

Compliance with Anti-Bribery Legislation

In 2003, Talisman updated its Compliance Guidelines for Anti-Bribery Legislation to reinforce Talisman’s commitment to complying with the Corruption of Foreign Public Officials Act (Canada) (CFPOA), the Foreign Corrupt Practices Act (FCPA) and other similar legislation applicable to Talisman, its subsidiaries around the world and its officers, directors, employees and agents. The revised guidelines complement Talisman’s Policy on Business Conduct and Ethics by providing information on such topics as anti-corruption laws and anti-bribery prohibitions, accounting and record-keeping requirements, penalties and enforcement, CFPOA and FCPA prohibitions, questionable payments and legally permitted exceptions. The new guidelines are available to all employees on Talisman’s internal website.

Political Contributions

“We expect high standards of ethical business conduct from all employees in the performance of their company responsibilities.”
Talisman provided contributions to governing and opposition parties at the federal and provincial levels in Canada in 2003. At the federal level, Talisman contributed $10,000 to the Liberal Party of Canada, as well as $10,000 each to the Paul Martin and John Manley leadership campaigns. Talisman also contributed $5,000 to the Progressive Conservative Party of Canada. Smaller contributions totaling $17,200 in aggregate were provided to governing and opposition parties in Alberta, British Columbia, Saskatchewan and Ontario. No political payments or contributions were made in international operating areas. Talisman’s Chief Executive Officer, in accordance with the Company’s established guidelines, must authorize all political contributions made on Talisman’s behalf.

Effective January 2004, the Canadian federal government’s Bill C-24 bans political contributions by corporations, except for an annual maximum of $1,000 collectively to a party’s candidates, nomination contestants or electoral district associations. In the past, we have had a policy of contributing $20,000 per year to the governing federal party, with lesser amounts to opposition parties. We have also purchased tables at various federal party fundraising events. In accordance with the new law, Talisman’s policy has been revised to preclude all of these activities at the federal level.