Page 1
Page 2
Page 3
Page 4
Page 5
Page 6
Page 7
Page 8
Page 9
Page 10
Page 11
Page 12
Page 13
Page 14
Page 15
Page 16
Page 17
Page 18
Page 19
Page 20
Page 21
Page 22
Page 23
Page 24
Page 25
Page 26
Page 27
Page 28
Page 29
Page 30
Page 31
Page 32
Page 33
Page 34
Page 35
Page 36
Page 37
Page 38
Page 39
Page 40
Page 41
Page 42
FRAMEWORK CORPORATE RESPONSIBILITY POLICIES AND STRATEGY ETHICAL CONDUCT We are committed to compliance with applicable laws and aim to align our conduct with international standards of good practice. Corruption in some resource-rich countries has prevented their citizens from benefiting fully from the fruits of their countrys natural resources. We have zero tolerance of corruption and have and will maintain a robust compliance program. We are politically neutral and will not provide funding for candidates or party political entities. Transparency Kosmos aims to be a leader in transparency. We report publicly on the material aspects of our performance and advocate for transparency in our dealings with host governments. Through such disclosures we aim to strengthen investor confidence as well as stakeholders access to information about our company. Many people question the contributions our industry makes to oil and gas producing countries around the world. It is in our best interest to increase knowledge and understanding about these contributions and to support greater accountability for how the revenues are spent. As such we publish material payments to governments wherever we operate and support implementation of the Extractive Industries Transparency Initiative EITI internationally and in our countries of operation. We also share publicly the key terms of our agreements with governments. To this end all of our existing Petroleum Agreements PAs and Production Sharing Contracts PSCs are filed with the U.S. Securities and Exchange Commission. We have also published these contracts on our website to make them easily accessible to interested parties. In 2014 we made a policy decision to disclose payments to governments at a project level as laid out in the new European Union Accounting Directive an initiative that aims to improve corporate accounting practices and transparency. Our project level disclosures are available on our website httpwww.kosmosenergy. comresponsibilitytransparency.php. We believe that this type of disclosure is beneficial to investors civil society and local communities and reflects evolving international expectations. Compliance Training All Kosmos employees board members and contractors are required to attend anti-corruption training yearly and certify that they have read understood and will comply with our robust Anti- Corruption Compliance Policy which we have published on our website. To ensure comprehension and compliance all employees are required to pass a test on the Anti-Corruption Compliance Policy. Our Compliance Committee reviews requests for payments on behalf of as well as gifts and travel provided to government officials to ensure that these requests conform to our policies. Our Internal Audit team conducts an annual audit of the companys compliance with its business ethics policies. Kosmos maintains an anonymous Whistleblower Hotline as a means for employees third parties and others to report without risk of retaliation violations of any Kosmos policy. There are several channels through which to make a report. All reports go directly to the Chief Compliance Officer the Director of Internal Audit and the Chairman of the Audit Committee. We annually disclose the number of alerts lodged via the hotline and in 2014 decided to take the additional step of disclosing the result of any investigations while still remaining careful to protect the identity of any involved parties. Please see Performance Data on page 38 for more information. OUR WORKPLACES We aim to recruit the most appropriately skilled individuals and to provide stimulating and rewarding careers. We will not tolerate unfair discrimination and are committed to recruiting and promoting people on the basis of their potential and performance. 8