b'2 E at every level to ensure they have the depth of knowledge needed to hold governments and industry BUSINESS accountable for managing oil and PRINCIPL gas revenues appropriately.In 2014, we made a policy decision to disclose payments to governments at the project level, as laid out in the European Union Accounting Directive, which is designed to improve corporate accounting practices and transparency. We believe this type of disclosure is beneficial to investors, civil society, and local communities, and reflects evolving international expectations. Kosmos was the first U.S. oil and gas company to disclose project-Ethical level payments to governments despite not being legally obligated to do so at the time. Following our secondary listing on the London Conduct Stock Exchange in 2017, Kosmos is now required to report under U.K. regulations.KOSMOS WAS THE T he Business Principleswork on our behalf. We conductFIRST U.S. OIL AND are supported by robustbackground due diligence when compliance policies andappropriate to make sure we haveGAS COMPANY TO methodology, including our Anti- obtained full disclosure. In additionDISCLOSE PROJECT-Corruption Compliance Policy andto providing third parties withLEVEL PAYMENTS TO Procedures, which align with thecopies of our Business PrinciplesGOVERNMENTS DESPITE U.S. Foreign Corrupt Practices Actand Anti-Corruption Compliance (FCPA) of 1977, the U.K. Bribery ActPolicy, we routinely conduct in- NOT BEING LEGALLY of 2010, as well as best practices incountry training for key contractorsOBLIGATED TO DO SO.anti-corruption compliance.and suppliers on compliance and Kosmos regularly evaluatessupplement in-person training with its anti-corruption measuresonline training modules.We believe our approach to and performance. All KosmosKosmos conducts an annualtransparency helps us better employees and key contractors areinternal audit of the companysmanage social and political issues, required to attend anti-corruptioncompliance with its business ethicsestablishing Kosmos as a partner training, and certify annually thatpolicies and periodically conductsof choice and mitigating barriers they have read, understood, andaudits on third parties. We maintainto growth.complied with our Anti-Corruptionand respond to a Whistleblower Compliance Policy. To furtherHotline as a vehicle for employees, ensure comprehension, employeesthird parties and others to report are given a test to verify theiranonymously, without risk of understanding of the policy. retaliation, potential violations of We exercise care in the selection ofany Kosmos policy.vendors, suppliers, and contractors,As part of its commitment to and we impose the same hightransparency, Kosmos aspires standards of conduct that weto go beyond a box-checking observe in our own company.exercise by making information We use a risk-based process topublicly available and increasing evaluate third parties who willour engagement with stakeholders 10'