General Business Principles

SPD has as its core values honesty, integrity and respect for people. SPD also firmly believes in the fundamental importance of the promotion of trust, openness, teamwork and professionalism, and in pride in what it does. Our underlying corporate values determine our principles. These principles apply to all transactions, large or small, and describe the behavior expected of every employee of SPD in the conduct of its business.

1. Purpose

The purpose of SPD is to engage efficiently, responsibly and profitably in the oil business, to develop oil and gas from Salym group of oilfields. SPD seeks a high standard of performance and aims to maintain a long-term position in its competitive environments.

2. Goal

The goal of SPD is to become the best operator in Western Siberia with no harm to people and the environment.

3. Responsibilities

SPD recognizes the following areas of responsibility:

a. To Russia
To respect SPD obligations as stipulated by the License Agreements.

b. To shareholders
To protect shareholders’ investment and provide an acceptable return.

c. To employees
To respect the human rights of its employees, to provide its employees with good and safe conditions of work, and good and competitive terms and conditions of service, to promote the development and best use of human talent and equal opportunity employment, and to encourage the involvement of employees in the planning and in the application of these principles within SPD.

d. To those with whom we do business
To seek mutually beneficial relationships with partners, contractors and suppliers and to promote the application of these principles in so doing. The ability to promote these principles effectively will be an important factor in the decision to enter into or remain in such relationships.

e. To society
To conduct business as responsible corporate members of society, to observe the laws of the Russian Federation, to express support for fundamental human rights in line with the legitimate role of business and to give proper regard to health, safety and the environment consistent with our commitment to contribute to sustainable development.

These five areas of responsibility are seen as inseparable. Therefore it is the duty of management continuously to assess the priorities and discharge its responsibilities as best it can on the basis of that assessment.

4. Economic Principles

Profitability is essential to discharging these responsibilities and staying in business and it is a measure of SPD efficiency. It is essential to the allocation of the necessary resources and support the continuing investment required to develop and produce future energy supplies.

Criteria for investment decisions are not exclusively economic in nature, but also take into account social and environmental considerations and an appraisal of the security of the investment.

5. Business Integrity

SPD insists on honesty, integrity and fairness in all aspects of their business and expects the same in the relationships with all those with whom it does business. The direct or indirect offer, payment, soliciting and acceptance of bribes in any form are unacceptable practices. Employees must avoid conflicts of interest between their private financial activities and their part on the conduct of company business. All business transactions on behalf of SPD must be reflected accurately and fairly in the accounts of the company in accordance with established procedures and be subject to audit.

6. Political activities:

a. Of company
SPD acts in a socially responsible manner within the laws of the Russian Federation and the Netherlands in pursuit of its legitimate commercial objectives. SPD does not make payments to political parties, organizations or their representatives or take any part in party politics. However, when dealing with the Government, SPD has the right and the responsibility to make its position known on any matter, which affects itself, its employees, its customers, or its shareholders. SPD also has the right to make its position known on matters affecting the community, where it has a contribution to make.

b. Of employees
Where individuals wish to engage in activities in the community, including standing for election to public office, they will be given the opportunity to do so where this is appropriate in the light of local circumstances.

7. Health, Safety and the Environment

Consistent with SPD’s commitment to contribute to sustainable development, SPD has a systematic approach to health, safety and environmental management designed to ensure compliance with Russian law and to achieve continuous performance improvement.

SPD requires contractors to manage HSE in line with this policy.

To this end SPD manages these matters as any other critical business activity, sets targets for improvement, and measures, appraises and reports performance.

8. The Community

The most important contribution SPD can make to the social and material progress of the Russian Federation is in performing its basic activities as effectively as possible. In addition, SPD takes a constructive interest in societal matters, which may not be directly related to the business. SPD will contribute to the local community development through participation in social, education and charity programs.

9. Competition

SPD supports free enterprise. It seeks to compete fairly and ethically and within the framework of applicable competition laws; it will not prevent others from competing freely with it.

10. Communication

SPD recognizes that in view of the importance of the activities in which it is engaged and its impact on the national economy and individuals, open communication is essential. To this end, SPD will have a comprehensive information programme and will provide full relevant information about its activities to legitimately interested parties, subject to any overriding considerations of business confidentiality and cost.