Business Ethics

Kosmos and its employees face numerous decisions in their day-to-day activities, both in our Dallas office and international locations. It is the responsibility of every employee to uphold the Kosmos 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 and 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. A risk-based vetting process of third parties who will work on our behalf is conducted by our compliance group. It includes due diligence questionnaires supported by an online system used to track due diligence queries. We conduct background due diligence when appropriate to make sure we have obtained full disclosure. 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 as we seek to expand our exploration portfolio. In some cases, we have decided against pursuing opportunities in which we were uncomfortable with potential partners' ethical standards.

Whistleblower Hotline

Kosmos uses a 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. There are several reporting avenues including an anonymous hotline. 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).

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