The Company’s integrated risk management system outlines.

Risk Management

In order to establish uniform requirements for identifying, assessing and minimizing HSE risks as well as personnel’s approach to managing them, the Company has formalized the processes aimed at systematically identifying hazards, assessing risks, and taking adequate measures to prevent and reduce them. This has allowed the Company to significantly reduce the likelihood of industrial accidents, major equipment failures as well as other incidents and their accompanying environmental impacts.

The Company’s integrated risk management system outlines a standardized procedure for identifying and assessing risks, preparing risk management measures, making sure such measures are duly implemented and recorded, including with respect to risks related to environmentally sensitive areas where the company operates.

Oil Spill Response Plan

The Company’s Oil Spill Response Plan has been developed by the Russian Navy Central Research and Design Institute (CNIIMF), announced with the Federal Marine and River Transport Agency of the Ministry of Transport of the Russian Federation and the Ministry of Energy of the Russian Federation, and approved by the Russian Federation Ministry of Emergency Situations. In August 2013, an abstract of the Company’s Oil Spill Response Plan was published on the corporate website by LLC NPO Tyumen Geotech.

The Plan provides for different risk scenarios and gives estimates of personnel and equipment required for emergency response units in different situations. The Company has also established professional oil spill containment and response units and arranged efficient communication with the governmental emergency response bodies. The Company has procured a special equipment that allows it to respond to possible oil spills in the Arctic region and skim spilled oil in ice conditions. At the Prirazlomnaya site, the Company frequently conducts training sessions and large-scale exercises designed to ensure the highest level of coordination between its response team members in the event of an emergency situation. Training sessions are held on the sea covered by ice as well as onshore to protect the shoreline around the town of Varandey.