Report - COP Prototype

2022 Communication on Progress

Rosneft Oil Company

Published date

August 1, 2022

No. of questions

Supplemental files

Rosneft_UN_en_2022.pdf Rosneft Public position in the field of human rights Declaration_Rosneft_HR_eng.pdf Code of suppliers Regulations of Rosneft Oil Company on Rosneft Board Committees Rosneft_UN_en_2021.pdf Approaches to Human rights 2021 Code of business and Corporate ethics Rosneft_CSR2020_ENG.pdf Company policy risk management and internal control system .pdf Sustainable Development Policy Company policy on combatting corporate fraud and services involvement in corruption.pdf Rosneft_CSR2020_ENG.pdf Position paper Approaches to Human rights Rosneft Public position in the field of Human rights.pdf Public position biodiversity.pdf Public position preservation of water resources.pdf Public position waste management and remediation.pdf Rosneft_UN_en_2022.pdf RN policy on combatting Corp fraud and involvement in corruption Standard of Rosneft Internal control rules for the prevention, detection and suppression of illegal use of insider information in Rosneft and (or) market manipulation Code of business and Corp ethics

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

Optional comment

Sustainability reports https://www.rosneft.com/Development/Sustainability_Reports/ CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf Annual reports https://www.rosneft.com/Investors/Reports_and_presentations/Annual_reports/ https://www.rosneft.com/upload/site2/document_file/a_report_2021_eng.pdf https://www.rosneft.com/upload/site2/document_file/a_report_2020_eng.pdf Rosneft Contributing to Implementation of UN SDG Goals https://www.rosneft.com/Investors/Rosneft_contributing_to_implementation_of_UN/ https://www.rosneft.com/upload/site2/attach/3/23/Rosneft_UN_en_2022.pdf https://www.rosneft.com/upload/site2/attach/3/23/Rosneft_UN_en_2021.pdf Sustainability targets https://www.rosneft.com/about/Development_prospects_and_strategy/ Board Audit Committee https://www.rosneft.com/governance/Internal_control_and_audit/ Company policy on SUSTAINABLE DEVELOPMENT https://www.rosneft.com/upload/site2/document_file/development_policy_eng.pdf HSE Policy ROSNEFT https://www.rosneft.com/upload/site2/document_file/development_policy_eng.pdf Company Policy on combating corporate fraud and involvement in corruption activities https://www.rosneft.com/upload/site2/document_file/P3-1103_P-04_eng.pdf

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Rosneft: Contributing to Implementation of UN SDGs 2021 https://www.rosneft.com/upload/site2/attach/3/23/Rosneft_UN_en_2021.pdf CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf Annual report 2021 https://www.rosneft.com/upload/site2/document_file/a_report_2021_eng.pdf Rosneft oil company: Approaches to human rights observance https://www.rosneft.com/upload/site2/attach/0/15/01/Position_paper_Human_rights_en.pdf Rosneft Public position in the field of human rights https://www.rosneft.com/upload/site2/attach/3/02/Human_rights_Rosneft_eng.pdf Declaration on human rights for interacting with suppliers https://www.rosneft.com/upload/site2/attach/3/02/Declaration_Rosneft_HR_eng.pdf Code of suppliers of goods, works and services in the area of human observance https://www.rosneft.com/upload/site2/document_file/rn_code_of_suppliers_human_rights_en.pdf Code of business and corporate ethics ROSNEFT OIL COMPANY https://www.rosneft.com/upload/site2/document_file/P3-0106_P-01eng.pdf Company policy on SUSTAINABLE DEVELOPMENT https://www.rosneft.com/upload/site2/document_file/development_policy_eng.pdf HSE Policy ROSNEFT https://www.rosneft.com/upload/site2/document_file/development_policy_eng.pdf Company Policy on combating corporate fraud and involvement in corruption activities https://www.rosneft.com/upload/site2/document_file/P3-1103_P-04_eng.pdf

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Code of business and corporate ethics Rosneft oil company https://www.rosneft.com/upload/site2/document_file/P3-0106_P-01eng.pdf http://zakupki.rosneft.com/safety_hotline

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Annual Report 2021 www.rosneft.com/upload/site2/document_file/a_report_2021_eng.pdf CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf Rosneft: Contributing to Implementation of UN SDGs 2021 https://www.rosneft.com/upload/site2/attach/3/23/Rosneft_UN_en_2021.pdf Company policy on sustainable development https://www.rosneft.com/upload/site2/document_file/development_policy_eng.pdf

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Regulation of Rosneft Oil Company on Rosneft Board Committees https://www.rosneft.com/upload/site2/document_file/PZ-01_R-0105_YL-001_en.pdf CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf Annual Report 2021 www.rosneft.com/upload/site2/document_file/a_report_2021_eng.pdf Rosneft: Contributing to Implementation of UN SDGs 2021 https://www.rosneft.com/upload/site2/attach/3/23/Rosneft_UN_en_2021.pdf

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

6.1. During the assessment of risk, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

7.1. During the due diligence process, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

Optional comment

Rosneft Public Statement in the field of human rights https://www.rosneft.com/upload/site2/attach/3/02/Human_rights_Rosneft_eng.pdf Company Policy on combating corporate fraud and involvement in corruption activities https://www.rosneft.com/upload/site2/document_file/P3-1103_P-04_eng.pdf https://www.rosneft.com/Development/Corruption_control/ http://zakupki.rosneft.com/safety_hotline Rosneft: Contributing to Implementation of UN SDGs 2021 https://www.rosneft.com/upload/site2/attach/3/23/Rosneft_UN_en_2022.pdf CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

Optional comment

CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf Rosneft: Contributing to Implementation of UN SDGs 2021 https://www.rosneft.com/upload/site2/attach/3/23/Rosneft_UN_en_2022.pdf Code of business and corporate ethics Rosneft oil company https://www.rosneft.com/upload/site2/document_file/P3-0106_P-01eng.pdf

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Optional comment

CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	11
Male (%)	100
Female (%)	0
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	9
Above 50 years old (%)	91
From minority or vulnerable groups (%)	0
Executive (%)	9
Independent (%)	36

Optional comment

https://www.rosneft.com/governance/board/

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

Sustainability reports https://www.rosneft.com/Development/Sustainability_Reports/

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Optional comment

Sustainability reports https://www.rosneft.com/Development/Sustainability_Reports/ CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf

Human Rights
Materiality / Saliency
1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?
Freedom of association and the effective recognition of the right to collective bargaining
Child labour
Forced labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)
Freedom of expression
Access to culture
Access to water and sanitation
Digital security / privacy
Rights of women and/or girls
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Other
Optional comment
Rosneft oil company: approaches to human rights observance https://www.rosneft.com/upload/site2/attach/0/15/01/Position_paper_Human_rights_en.pdf Rosneft Public position in the field of human rights https://www.rosneft.com/upload/site2/attach/3/02/Human_rights_Rosneft_eng.pdf Declaration on human rights for interacting with suppliers https://www.rosneft.com/upload/site2/attach/3/02/Declaration_Rosneft_HR_eng.pdf Code of suppliers of goods, works and services in the area of human observance https://www.rosneft.com/upload/site2/document_file/rn_code_of_suppliers_human_rights_en.pdf CODE OF BUSINESS AND CORPORATE ETHICS ROSNEFT OIL COMPANY https://www.rosneft.com/upload/site2/document_file/P3-0106_P-01eng.pdf Rosneft: Contributing to Implementation of UN SDGs 2021 https://www.rosneft.com/upload/site2/attach/3/23/Rosneft_UN_en_2021.pdf CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf
Response
8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.
In 2021 the Company developed a Code of Suppliers of goods, works and services of Rosneft in the field of human rights. The Code is aimed at forming a strong business relationship between PJSC Rosneft and its suppliers. By adopting the Code, suppliers support the Company’s position in the field of human rights undertake to extend the Code’s provisions to the entire supply chain of goods, works and services. Rosneft: Contributing to Implementation of UN SDGs 2021 https://www.rosneft.com/upload/site2/attach/3/23/Rosneft_UN_en_2021.pdf CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf The Code of Suppliers of goods, works, and services of Rosneft in the field of human rights was circulated to all companies and entrepreneurs registered on TEK-Torg in Rosneft’s section, and posted on the websites of TEK-Torg and the Company. The Company expects its suppliers and contractors to implement a similar code and adhere to it in their operations. To this end, information about the Supplier Code is included in the agendas of seminars and roundtables, and relevant criteria are being developed for specific procurements. The Company is currently considering a possibility of incorporating the Supplier Code into the standard contract form. A survey of suppliers on the adoption of the Code is slated for 2022. All employees of the Company and Group Subsidiaries have been briefed on the Code of Business and Corporate Ethics, including its provisions on respecting human rights. Our foreign assets rely on the Company’s standard approaches in developing their internal procedures in line with local legislation. In addition, Rosneft expects all of its business partners, suppliers, and contractors to recognise the fundamental human rights and freedoms and adhere to the basic human rights principles in their operations. Personnel training on human rights matters is integrated into corporate training courses offered by the Company. A human rights module is also part of a mandatory classroom compliance training course. In 2021, the key human rights topics included in training programmes were:-human rights: approaches, -terms and definitions; -civil society and rule of law; -human rights protection; -labour law in foreign countries; - business ethics; - cultural change management; designing effective social communications. >65 thousand – total number of Rosneft employees who completed training in human rights policies and procedures in 2021. In line with the Russian President’s Decree No. 478 On National Anti- Corruption Plan for 2021–2024 dated 16 August 2021, Rosneft developed its Comprehensive Anti-Fraud and Anti- Corruption Programme for 2021–2024. As part of the programme, in the reporting period, the Company implemented the following:• updated its employees on typical;-violations of anti-fraud and anti-corruption rules (including management of conflicts of interest) on a quarterly basis; • informed relevant units about new anti-corruption regulations and government initiatives; • assessed the risk of corporate fraud and corruption on a quarterly basis in line with the approved methodology; • conducted anti-corruption audits of draft internal regulations; • published the quarterly All About Compliance information bulletin, and distributed the bulletin devoted to the International Anti-Corruption Day to all Rosneft employees on 9 December 2021.... In 2021, Rosneft launched a project to automate the management of conflicts of interest. .. A project was also launched to automate the collection of ethical declarations and conflict of interest disclosures... The Company operates a 24/7 Security Hotline to report on suspected and actual cases or indications of corporate fraud and corruption... The Company has the Ethics Hotline in place to collect feedback on ethics issues. All queries are registered, analysed and sent for review to relevant units of the Company. In 2022, the Company will work on unifying and categorising local regulations to create a comprehensive call classifier for our hotlines.

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
2021
Forced labour
2021
Child labour
2021
Non-discrimination in respect of employment and occupation
2021
Occupational safety and health
2021
Working conditions (wages, working hours)

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
The Company operates in compliance with the laws ensuring freedom of association and rights to collective bargaining.
Forced labour
In its employment practices, Rosneft complies with applicable Russian and international laws and never uses forced, compulsory or child labour. The Company takes a zero tolerance approach to discrimination on the basis of gender, age, ethnic origin, religion, race, or any other grounds. Rosneft and Group Subsidiaries never use child labour • in whatever circumstances.Foreign assets operate in line with the corporate procedures and local legislation.
Child labour
In its employment practices, Rosneft complies with applicable Russian and international laws and never uses forced, compulsory or child labour. The Company takes a zero tolerance approach to discrimination on the basis of gender, age, ethnic origin, religion, race, or any other grounds. Rosneft and Group Subsidiaries never use child labour • in whatever circumstances.Foreign assets operate in line with the corporate procedures and local legislation.
Non-discrimination in respect of employment and occupation
The Company complies with Russian laws on the protection of the disabled. We employ the disabled who also enjoy equal access to education.
Occupational safety and health
The requirements of the Golden Safety Rules are mandatory for all employees and contractors of the Company. The Company’s HSE policystates that any employee who sees violations of the Golden Safety rules must immediately take action to stop the job and correct violations. Managers at all levels act in accordance with the Company’s uniform “Leadership Principles” in the field of HSE rules and provide safe working conditions for all employees of the Company and contractors.
Working conditions (wages, working hours)
Rosneft oil company: approaches to human rights observance https://www.rosneft.com/upload/site2/attach/0/15/01/Position_paper_Human_rights_en.pdf ENSURING FAIR REMUNERATION AND WORKING CONDITIONS In all the regions the Company operates exclusively in accordance with the requirements of the legislation. Rosneft strives to maintain the amount of remuneration at a level that exceeds the average wage in the regions where the Group's companies operate. The Company annually analyzes the salary rates in the countries of its presence, hiring consultants if necessary. The average monthly salary in the Group's companies exceeds the minimum wage, which cannot be lower than the subsistence rate established in accordance with the interchapter 133 of the Labor Code of the Russian Federation, as well as the average salary* in most regions of its presence. The Company conducts an annual indexation of wages. Overtime work is paid in accordance with the interchapter 152 of the Labor Code of the Russian Federation. The specific amount of payment for overtime work can be defined by a collective agreement, a local regulatory act or an employment contract. By the request of the employee, increased pay for overtime work can be compensated by providing additional time off, but not less than the duration worked overtime. Work performed in excess of the norm of working time on weekends and non-working days and holidays is paid at a higher rate or compensated by providing another day off in accordance with the interchapter 153 of the Labor Code of the Russian Federation. In accordance with the interchapter 91 of the Labor Code of the Russian Federation, the working time does not exceed 40 hours per week. The duration of overtime work, in accordance with the interchapter 99 of the Labor Code of the Russian Federation, does not exceed 4 hours for each employee for two consecutive days and 120 hours per year. The work of employees, working on rotation is regulated by the chapter 47 of the Labor Code of the Russian Federation. The Company expects that business partners, including suppliers and contractors, work in strict accordance with the law.

Optional comment

Rosneft: Contributing to Implementation of UN SDGs 2021 https://www.rosneft.com/upload/site2/attach/3/23/Rosneft_UN_en_2021.pdf

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	68

Optional comment

CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)	44

Optional comment

CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	24.2
Non-executive board	0

Optional comment

CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf Website “Corporate governance” https://www.rosneft.com/governance/management/

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)
The Company has transparent approach to remuneration, evaluation, motivation and promotion, and follows the principle of equal pay for work of equal value. Employees in the same positions and professions are paid equally, and there is no pay gap between men and women per- forming identical functions. CSR 2020 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2020_ENG.pdf

Optional comment

CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury	0.64

Optional comment

CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf Number of lost time occupational injuries (including fatalities) at ROSNEFT and its CONTRACTORS per 1 million man-hours worked (LTIF)

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate	1.01

Optional comment

CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf Number of occupational recordable injuries (including fatalities, lost time injuries and injuries requiring medical treatment) at Rosneft and its contractors per 1 million man-hours worked (TRIR)

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

The Company provides internal trainings every year. To improve transparency, awareness and risk management in 2021the Company employees received information on typical corp. fraud and corruption violations (including conflict of interest management) on a quarterly basis. Rosneft: Contributing to Implementation of UN SDGs 2021 https://www.rosneft.com/upload/site2/attach/3/23/Rosneft_UN_en_2021.pdf

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2021
Water
2021
Oceans
2021
Forests / Biodiversity / Land Use
2021
Air Pollution
2021
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2021
Energy & Resource Use
2021

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

Rosneft Oil Company: Sustainable approach to preservation of water resources https://www.rosneft.com/Investors/ESG/Public_papers/Rosneft_Oil_Company_Sustainable_approach_to_preservation_of_water_resources/ Saving the planet for the benefit of the current and future generations: Rosneft commitment to preserving biodiversity https://www.rosneft.com/Investors/ESG/Public_papers/Saving_the_planet_for_the_benefit_of_the_current_and_future_generations/ Saving the planet for the benefit of the current and future generations: Rosneft waste management and remediation https://www.rosneft.com/Investors/ESG/Public_papers/Saving_the_planet_for_the_benefit_of_the_current_and_future_generations_Rosneft_waste_management_and_remediation/ https://www.rosneft.com/upload/site2/document_file/P2-04_02_P-01_V-1-00_eng.pdf COMPANY’S POLICY IN THE AREA OF ENHANCEMENT OF ENERGY EFFICIENCY AND ENERGY SAVING

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

website: Development Prospects and Strategy https://www.rosneft.com/about/Development_prospects_and_strategy/ Rosneft Oil Company: Sustainable approach to preservation of WATER resources - https://www.rosneft.com/Investors/ESG/Public_papers/Rosneft_Oil_Company_Sustainable_approach_to_preservation_of_water_resources/ Saving the planet for the benefit of the current and future generations: Rosneft commitment to preserving biodiversity-https://www.rosneft.com/Investors/ESG/Public_papers/Saving_the_planet_for_the_benefit_of_the_current_and_future_generations/ Saving the planet for the benefit of the current and future generations: Rosneft waste management and remediation https://www.rosneft.com/Investors/ESG/Public_papers/Saving_the_planet_for_the_benefit_of_the_current_and_future_generations_Rosneft_waste_management_and_remediation/

4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

	Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Climate Action	#website: Development Prospects and Strategy https://www.rosneft.com/about/Development_prospects_and_strategy/) “Rosneft-2030” – climate priorities horizons: Short-term: 5% reduction in absolute greenhouse gases emissions (Scope 1 and 2) by 2025. Mid-term: More than 25% absolute GHG emissions (Scope 1 and 2) reduction by 2035; Methane intensity reduction to less than 0.2% by 2030; Zero routine flaring of associated petroleum gas by 20302; Less than 20 kg СО2-e/boe intensity of Upstream GHG emissions (Scope 1 and 2) by 2030 or earlier; Long-term: carbon neutrality (Scope 1 and 2) by 2050
Energy & Resource Use	COMPANY’S POLICY IN THE AREA OF ENHANCEMENT OF ENERGY EFFICIENCY AND ENERGY SAVING https://www.rosneft.com/upload/site2/document_file/P2-04_02_P-01_V-1-00_eng.pdf Energy Saving and Energy Efficiency The cornerstone of the Energy Management System is Rosneft’s Energy Saving Programme drafted for every five-year period and updated annually. As contemplated by the Energy Saving Programme for 2021–2025, the five- year fuel and energy savings should total 2.6 mln tonnes.
Water	#Rosneft Oil Company: Sustainable approach to preservation of WATER resources - https://www.rosneft.com/Investors/ESG/Public_papers/Rosneft_Oil_Company_Sustainable_approach_to_preservation_of_water_resources/) 10% reduction in the consumption of fresh water by 2030 (for current operations) due to an increase in the reused water and improved efficiency of water treatment.
Forests / Biodiversity / Land Use	#Saving the planet for the benefit of the current and future generations: Rosneft commitment to preserving biodiversity-https://www.rosneft.com/Investors/ESG/Public_papers/Saving_the_planet_for_the_benefit_of_the_current_and_future_generations/ ) COMPANY GOALS AND APPROACH TO PRESERVING BIODIVERSITY Rosneft: voluntary exclusion of activity areas When planning new projects in all regions of its operations, the Company will make every effort to avoid activities or any impact on the specially protected natural areas - 1a and 1b protected area categories under the International Union for Conservation of Nature (IUCN) classification as well as the UNESCO heritage sites. In accordance with legislative requirements the Company commits to not conducting crude oil exploration activities in ice areas of the Arctic seas without a stringent environmental review held in advance, as well as monitoring and an independent verification of operations. The Company is not engaged in offshore production activities in the Arctic seas. https://www.rosneft.com/Investors/ESG/Public_papers/Saving_the_planet_for_the_benefit_of_the_current_and_future_generations_Rosneft_waste_management_and_remediation/) As part of the Rosneft Environmental Development Concept, the Company set a “zero legacy”target by 2035 -Remediating 100% of the legacy polluted land. -Eliminating 100% of the legacy oily waste.
Air Pollution	Rosneft: Contributing to Implementation of UN SDGs 2021 https://www.rosneft.com/upload/site2/attach/3/23/Rosneft_UN_en_2021.pdf Within the framework of the Concept of Environmental Development of PJSC Rosneft until 2035, the following goals are set: ■ 15% reduction in total non-greenhouse gas emissions; ■ 15% reduction in emissions of sulfur dioxide and nitrogen oxides by 2035.
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)	https://www.rosneft.com/Investors/ESG/Public_papers/Saving_the_planet_for_the_benefit_of_the_current_and_future_generations_Rosneft_waste_management_and_remediation/) As part of the Rosneft Environmental Development Concept, the Company set a “zero legacy”target by 2035 -Remediating 100% of the legacy polluted land. -Eliminating 100% of the legacy oily waste. Within the framework of the Concept of Environmental Development of Rosneft Company has set the following goals until 2035 -reclamation of 100% of polluted lands of “historical heritage” by 2035; - liquidation of 100% of oil- containing waste of historical heritage by 2035; - implementation of the principles of the closed loop economy during the implementation of current activities and new projects. The Rosneft–2030 Strategy defines a set of development areas, minimizing the Company’s environmental footprint including  progressive implementation of the principles of the circular economy;  application of biodiversity conservation approaches (“net positive impact”);  100% utilization of oily waste and 100% legacy remediation.
Oceans

4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

	Progress is reviewed against goals annually or more frequently	Progress is reported internally to the most senior level	Progress is reported externally	Other (Please provide additional information)
Climate Action
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

Emissions (tCO2e)

54200000

Scope 2 Emissions

Full

None

Emissions (tCO2e)

18500000

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

283000000

Optional comment

CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf Scope 3: Rosneft continues to disclose Scope 3 emissions in line with the GHG Protocol (2011) developed by the World Resources Institute and the World Business Council for Sustainable Development (WBCSD) and the IPIECA/API guidance Estimating Petroleum Industry Value Chain (Scope 3) Greenhouse Gas emissions – Overview of Methodologies (2016). The Company notes that Scope 3 emissions are estimated values for indirect emissions, that are beyond the Company’s control, unlike Scope 1 and Scope 2 emis- sions that are within the Company’s direct control. Rosneft’s Scope 3 emissions reporting is primarily based on estimates of Category 11 (Use of Sold Products) using the IPIECA/API guidance, which includes the estimate of direct end use phase emissions of final products. Rosneft sells substantial volumes of crude oil and gas as feedstock to third parties. Such third parties may also subsequently report Scope 3 emissions from products derived from this feedstock, which can potentially result in double counting across the industry (i.e. with emissions reported by both the buyer and the seller). As per the IPIECA/API Scope 3 guidance, Rosneft applies emission factors commonly referred to by the industry and excludes estimated emissions from petrole- um products that are utilised in its own operations, as these are recognised in its Scope 1 reporting. The Company applies internationally accepted percentages to produce calculations and exclude emissions from non-fuel uses. In incorporating the IPIECA/API guidance, estimated Scope 3 emissions from Category 4 (Upstream Transportation and Distribution); Category 9 (Downstream Transportation and Distribution) and Category 10 (Processing of Sold Products) are excluded to avoid potential double counting within the Company, as the majority of these Scope 3 emissions are expected to belong to Category 11 (Use of Sold Products). Rosneft’s total Scope 3 emissions associated with the use of sold petroleum products (as reported above) together with the estimated Scope 3 emissions from oil and gas feedstock was 666 mln of CO2-equiv. in 2021 (670 mln of CO2-equiv. in 2020 as updated).

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

In 2020 Rosneft’s R&D costs amounted to RUB 26.8 bln. CSR2020 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2020_ENG.pdf

Optional comment

In 2020 Rosneft’s R&D costs amounted to RUB 26.8 bln. CSR2020 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2020_ENG.pdf

8. Has the organization acted to support climate change adaptation and resilience?

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

Unknown

Optional comment

CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf Currently the volume of generated renewable energy accounts for an insignificant part of total energy volume.

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

Rosneft: continuously improving fuel quality and sustainability across the value chain https://www.rosneft.com/Investors/ESG/Contributing_to_the_UN_Sustainable_Development_Goals_case_studies/environmental_improvement/

Sector-specific: Water

12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

Water withdrawal (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	446100
Groundwater:	85200
Surface water:	237400
Rainwater:	8800
Wastewater:	114700
Percentage of water withdrawn in regions with high or extremely high water stress (%)
CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf As part of the Aqueduct project, the Company regularly evaluates the sufficiency of water resources across the regions where it operates. Most of the Rosneft’s operational activities are carried out in regions where there is a sufficient water supply; however, irrespective of the supply level, the Company takes a number of steps to ensure sustainable use of water resources and protection of water bodies. The Company follows applicable laws in its water use, ruling out any possibility of water shortages for local communities.

Water consumption (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	446100
Groundwater:	85200
Surface water:	237400
Rainwater:	8800
Wastewater:	114700
Percentage of water consumed in regions with high or extremely high water stress (%)
CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf As part of the Aqueduct project, the Company regularly evaluates the sufficiency of water resources across the regions where it operates. Most of the Rosneft’s operational activities are carried out in regions where there is a sufficient water supply; however, irrespective of the supply level, the Company takes a number of steps to ensure sustainable use of water resources and protection of water bodies. The Company follows applicable laws in its water use, ruling out any possibility of water shortages for local communities.

13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

Water intensity of products (cubic meter/$):

Unknown

Not applicable (Please provide additional information)

CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf As part of the Aqueduct project, the Company regularly evaluates the sufficiency of water resources across the regions where it operates. Most of the Rosneft’s operational activities are carried out in regions where there is a sufficient water supply; however, irrespective of the supply level, the Company takes a number of steps to ensure sustainable use of water resources and protection of water bodies. The Company follows applicable laws in its water use, ruling out any possibility of water shortages for local communities.

Sector-specific: Forest, biodiversity, and land use

14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

	Number	Unknown	Not applicable (Please provide additional information)
Sites
CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf The Company does not carry out exploration in protected areas. When operating in environmentally sensitive areas and near specially protected natural areas, the Company takes all possible preventive measures to avoid environmental impacts and ensure biodiversity conservation, including in the Yamal-Nenets Autonomous Area, Krasnoyarsk Territory, Arkhangelsk Region and the Republic of Sakha. In addition, the Company’s production facilities are situated near the Verkhnee Dvuobye wetlands, Yugansky Nature Reserve in the Khanty-Mansi Autonomous Region – Yugra, various protected areas in the Samara Region, including I.I. Sprygin Zhiguli State Nature Biosphere Reserve, More-Yu wildlife sanctuary, Pym-Va-Shor nature monument in the Nenets Autonomous Area, as well as wetlands of the Krasnodar Territory. The Company engages in activities related to oil and gas production, treatment and transportation in areas traditionally used by indigenous peoples of the North, and carries out retail sales of petroleum products near protected areas, including the Utrish State Nature Reserve, Losiny Ostrov National Park, Samarskaya Luka National Park, Tunkinsky and Pribaikalsky national parks, Baikal Nature Reserve, Teberda Nature Reserve, Kumysnaya Polyana park, and Vysokovsky Bor nature monument. The Company operates in full compliance with applicable laws on environment protection
Hectares

15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

Conversion of natural resources (hectares)

11509

Unknown

Not applicable (Please provide additional information)

Optional comment

CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf

16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

	No	No, but we plan to in the next 2 years	Yes
Forest ecosystem restoration
Other ecosystem restoration
Reforestation
Rosneft: Contributing to Implementation of UN SDGs 2021 https://www.rosneft.com/upload/site2/attach/3/23/Rosneft_UN_en_2021.pdf The Company’s low-carbon development initiatives include: Development and implementation of climate projects related to forest conservation and afforestation to offset carbon emissions that are difficult to avoid in operations.In 2021 Rosneft planted more than 9.3 mln trees as part of the forest preservation and afforestation initiative. Saving the planet for the benefit of the current and future generations: Rosneft waste management and remediation https://www.rosneft.com/Investors/ESG/Public_papers/Saving_the_planet_for_the_benefit_of_the_current_and_future_generations_Rosneft_waste_management_and_remediation/
Natural regeneration
Agroforestry
Set-aside land
Biodiversity offsetting
Saving the planet for the benefit of the current and future generations: Rosneft commitment to preserving biodiversity https://www.rosneft.com/Investors/ESG/Public_papers/Saving_the_planet_for_the_benefit_of_the_current_and_future_generations/ Rosneft: Contributing to Implementation of UN SDGs2021 https://www.rosneft.com/upload/site2/attach/3/23/Rosneft_UN_en_2021.pdf In 2021, the Company released over 120 million fingerlings into water bodies of the Russian Federation for the purpose of reproducing aquatic bioresources.
Other (please specify in text box)

Sector-specific: Air pollution

17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

	Emissions (tCO2e)	Unknown	Not applicable (Please provide additional information)
NOx	60000
SOx	76000
Volatile Organic Compounds (VOC)	322000
Hazardous air pollutants (HAP)
Particulate matter (PM10)	65000
Persistent organic pollutants (POP)
Other (please specify in text box)

Optional comment

CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

Environmental protection is an integral part of Rosneft’s corporate culture. the Company strives to achieve world leadership in minimizing its environmental footprint. That is why in its operations the company pays close attention to environmental safety, rational use, conservation and restoration of natural resources. Rosneft’s environmental objectives 2035 minimizing environmental footprint through utilizing best available technologies thus increasing the efficiency of waste disposal process, land reclamation, wastewater treatment and emissions’ reduction; Rosneft environmental vision 2035 The vision sets the following environmental development objectives : 100% remediation of historically contaminated land 100% processing of historically accumulated oily waste 10% reduction of fresh water consumption by 2030 15% reduction of the total volume of non-GHG emissions 15% reduction of sulphuric dioxides and nitrogen oxides emissions. In 2021 Rosneft Board of Directors approved the new strategy “Rosneft-2030: Reliable Energy and Global Energy Transition” . It targets the reduction of the carbon footprint while further improving operational and financial efficiency of the company. Rosneft also sets a Net Zero 2050 target (scope 1 and 2 operational emissions) to be achieved through emissions ‘ reduction, low-carbon power generation, zero routine flaring, use of energy -saving , carbon capture and storage technologies and natural carbon offsets. The Gas Investment Programme, focused on the rational use of APG, and the Energy Saving Programme, will mainly leverage GHG reductions.

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

2021

Optional comment

Company Policy on combating corporate fraud and involvement in corruption activities https://www.rosneft.com/upload/site2/document_file/P3-1103_P-04_eng.pdf Rosneft: Contributing to Implementation of UN SDGs 2021 https://www.rosneft.com/upload/site2/attach/3/23/Rosneft_UN_en_2021.pdf CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Optional comment

Company policy on combatting corporate fraud and involvement in corruption activities https://www.rosneft.com/upload/site2/document_file/P3-1103_P-04_eng.pdf Rosneft: Contributing to Implementation of UN SDGs 2021 https://www.rosneft.com/upload/site2/attach/3/23/Rosneft_UN_en_2021.pdf CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf

Prevention

3. Who receives training on anti-corruption and integrity?

Optional comment

CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf Sustainability reports https://www.rosneft.com/Development/Sustainability_Reports/

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years
In 2021 there were no confirmed cases of corruption in which the Company was held liable by the regulators. CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf
Confirmed during the current year, and related to this year
In 2021 there were no confirmed cases of corruption in which the Company was held liable by the regulators. CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

Optional comment

Company policy on combatting corporate fraud and involvement in corruption activities https://www.rosneft.com/upload/site2/document_file/P3-1103_P-04_eng.pdf CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

Optional comment

CSR2021 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2021_ENG.pdf Rosneft is focused on building a transparent, productive and mutually beneficial partnership with a wide range of stakeholders and sees it as the basis for accomplishing strategic goals and growing the business. The Company organises its dialogue with stakeholders around various formats and mechanisms. In its relations with stakeholders the Company is guided by the law and high business ethics standards. Rosneft has in place the Company Policy on Sustainable development and the code of Business and Corporate Ethics. COMPANY POLICY ON SUSTAINABLE DEVELOPMENT https://www.rosneft.com/upload/site2/document_file/development_policy_eng.pdf CODE OF BUSINESS AND CORPORATE ETHICS ROSNEFT OIL COMPANY https://www.rosneft.com/upload/site2/document_file/P3-0106_P-01eng.pdf

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

Rosneft: Contributing to Implementation of UN SDGs 2021 https://www.rosneft.com/upload/site2/attach/3/23/Rosneft_UN_en_2021.pdf The Company annually collects declarations on assets and liabilities of its executives/ employees, as well as declarations on the income, assets and liabilities of their spouses and minor children, who are included on the list of persons obliged to submit such declarations; an annual campaign is conducted to collect ethical declarations of the Company executives/ employees in order to monitor their compliance with restrictions, prohibitions and requirements of anti-corruption legislation; an anti-corruption clause is signed with newly hired employees of the Company and when appointing employees to new positions. This anti-corruption clause is included in employment contracts as well, in terms of compliance with restrictions, prohibitions and requirements aimed at prevention of conflicts of interest. All the Rosneft subsidiaries have established operating commissions to resolve conflicts of interest. The Company consistently conducts training of its employees, including those whose job duties include participation in combatting corruption. Newly hired employees undergo training in the field of combatting corporate fraud and corruption as well. The following information is available on the Company’s official website in the “Anti-Corruption” subsection:  the Company’s statement on zero tolerance of corruption;  basic provisions of Russian and applicable international anti-corruption legislation;  local regulatory documents of the Company on combatting corruption (Rosneft Code of Business and Corporate Ethics, Company Policy on Combatting Corporate Fraud and Involvement in Corruption Activities);  Security Hotline contact details;  Information on interaction with law enforcement bodies. CSR 2020 https://www.rosneft.com/upload/site2/document_file/Rosneft_CSR2020_ENG.pdf In 2020, the Company approved and implemented the Regulations on Coordinating Anti-Fraud and Anti- Corruption Processes, including the following procedures: • assessment of corporate fraud and corruption risks; • protection of whistleblowers; • reporting of suspected corporate frauds or corruption and investigations; • training and communications in combating corporate fraud and corruption; • monitoring and controlling the process of countering corpo- rate fraud and corruption. In 2020, the Company also updated the Procedure for Documenting and Reporting Business Expenses and Other Transactions with Employees.