Whistle Blowing/Grievance Procedure

Purpose
A Whistle Blowing/Grievance procedure has been developed by Sakhalin Energy to provide an independent channel enabling employees, contractors, suppliers and their staff, Joint Venture Partners and members of the Community to raise any concerns or make suggestions if they believe the Company's business practices or development of the Sakhalin-2 Project is having a detrimental impact on the community, the environment or on their quality of life.

Application
The procedure can be used by anyone.

Procedure

1. The procedure, which provides several ways in which you can report a grievance, is set out in a Public Grievance Leaflet, a link to which may be found below:

Send a completed Grievance Form or write to the address shown below;
Contact your Community Liaison Officer (CLO). Open a list of CLO contacts;
Send an email to the following address Grievancereport@Sakhalinenergy.ru;
Call Sakhalin Energy directly on a confidential phone line at +7 4242 66 2400. (For security reasons, there are no recorders or caller identification devices attached. If the phone is not answered, please call back);
Or report your concerns via a confidential website www.seicconfidential.com which is completely anonymous.

Address your grievance to the Compliance Manager,
Sakhalin Energy Investment Company Ltd.,
35 Dzerzhinskogo St., Yuzhno-Sakhalinsk, Russian Federation, 693020.

2. Once you have disclosed your concerns, the following steps will be taken:

Receipt will be acknowledged (if you have disclosed your identity)
We will work to understand the cause of your grievance.
Once we have investigated your grievance, we will write to you with the results of the investigation and of our proposed course of action, should we believe any to be necessary
Should the grievance relate to a breach of our business principles it will be reported to "The Business Integrity Committee" and an initial assessment on what action is appropriate will be decided.
Before initiating any further investigations, the Whistle Blowing Focal Point will discuss with you the way in which the matter will be progressed.
You will be provided with feedback on actions taken

Assurances
Details of submissions and allegations will remain confidential.

Communication
Information on the Whistle Blowing/Grievance Procedure shall be made known to contractors and suppliers with a request to disseminate to their key personnel. The procedure shall also be made known to Joint Venture Partners and the Community.

Further Information
To download a copy of the Public Grievance Leaftet in English click here