Grievance Procedure

When implementing the Human Rights Policy, the Company pays a special attention to the mechanisms for resolving grievances and keeping an open dialogue with the staff, contractors, and the public.
The following procedure to resolve grievances of the population is developed and implemented in the Company.

Any actual or potential problem that leads to the expression of dissatisfaction or concern is considered as a grievance.

The procedure involves six steps and specific terms of resolving grievances.

Step 1: Receipt of the grievance
Receipt of the grievance by one of the channels listed in the Methods of Filing a Grievance diagram.
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Step 2: Assessment of the grievance, its registration, and the appointment of responsible persons.
Upon the receipt of the grievance, the Grievance Committee of Sakhalin Energy shall designate persons responsible for its resolution and interaction with the initiator. Information about the grievance goes to the Incident Tracking System, which allows to monitor the stages of grievance resolution and will automatically notify the person responsible for the resolution of the grievance and his/her line manager.
Step 3: Written notification
The Company shall send the initiator of the grievance a letter with the registration number of t he grievance and the data of the contact person.
Step 4: Investigation, resolution, and communication
The Company reveals the reasons for the grievance and takes steps towards its resolution. If the grievance is not resolved within the prescribed period (45 business days), the Incident Tracking System notifies the responsible persons and their line managers of the delay. If there are objective reasons for not resolving the grievance on time, an agreement to extend the resolution of the grievance shall be signed between the Company and the grievance initiator.
Step 5: Closure of the grievance
If the grievance initiator agrees that the grievance is resolved, the Company proposes to sign a letter of satisfaction with the results and the process of interaction. If the grievance remains unresolved, it is considered again and the possibility of further measures to resolve it shall be discussed with the grievance initiator.
Step 6: Follow-up activities (monitoring)
Monitoring the results of the grievance resolution: if the grievance initiator does not object, the Company can contact him/her to make sure that its activities do not cause further concern.

The Grievance Procedure requires that all issues related to grievances shall be dealt with confidentially. The identity of the initiator and the contents of the grievance shall not be disclosed to third parties without the prior written consent of the initiator.

General statistics and the results of the grievance resolutions are included in the annual sustainable development reports.

Sakhalin Energy is one of the five companies in the world that were selected by the UN to test the Guiding Principles on Business and Human Rights, the so-called Ruggie Principles, in the part of corporate mechanisms for handling grievances. The Guiding Principles were endorsed by the UN Human Rights Council in its Resolution 17/4 of 16 June 2011.