Responsibility

Business Ethics

Kosmos and its employees face many decisions during day-to-day activities. It is the responsibility of every employee to uphold our Business Principles and Code of Conduct, as well as to report any concerns they may have regarding the conduct of others.


Anti-Corruption

We have zero tolerance of corruption and maintain robust compliance policies and methodology. This includes the Kosmos Anti-Corruption Compliance Policy and related procedures, which were updated in 2013 to align more closely with the U.K. Bribery Act of 2010 as well as best practices in anti-corruption compliance. We are continuously monitoring and improving our performance.

All Kosmos employees, board members and individual contractors are required to attend anti-corruption training yearly and certify that they have read, understood and will comply with our Anti-Corruption Compliance Policy. To further ensure comprehension, all of our employees are required to pass a test on the Anti-Corruption Compliance Policy.

 


Vendor Selection & Supply Chain

We exercise care in the selection of vendors, suppliers and contractors, and we impose the same high standards of conduct that we observe in our own company. Our contractor vetting process includes background checks and thorough onboarding to ensure alignment with Kosmos’ values and polices.

In addition to providing all third parties with copies of our Anti-Corruption Compliance Policy, we routinely conduct in-country contractor and supplier training on compliance and supplement in-person training with online training portals. We also conduct rigorous due diligence on potential partners.


Whistleblower Hotline

Kosmos uses an anonymous Whistleblower Hotline as a vehicle for employees, third parties and others to report, without risk of retaliation, violations of any Kosmos policy, including the Anti-Corruption Compliance Policy. All reports go directly to the Chief Compliance Officer, the Director of Internal Audit, or the Chairman of the Audit Committee, as appropriate.

If you believe that any practice raises questions as to compliance with our policies or applicable law, you can report it through the following website or number: kosmosenergy.alertline.com or 1-888-419-0569 (toll free, if called from within the United States).