negative impacts on the activity of PJSC LUKOIL as a large producer of fossil fuels and an emitter of greenhouse gases, in the form of increased costs and a decrease in efficiency. In addition, PJSC LUKOIL operates in regions where the potential physical impact of climate change is rather unpredictable and can cause significant negative impacts.”188 Statements on Human Rights “The ethical standards of LUKOIL Group cover all aspects of business ethics, including: • Respect for human rights (including labor rights, the rights of local communities and small indigenous peoples, and freedom of association and trade union activity) • Zero tolerance towards and combatting corruption and fraudulent activities • Adherence to the rules of fair competition The corporate documents contain the Company’s official position, rules of conduct, and obligations in relation to both mutual relationships with the personnel of the Company and interaction with external stakeholders. The documents set forth an intention to apply the rules of conduct (including with regard to respect for human rights) to relations with partners, suppliers, and contractors through respective notifications.”189 “LUKOIL recognizes the importance of observing human rights, and undertakes in its activity to be guided by the provisions of the United Nations Universal Declaration of Human Rights.”190 “The Company seeks to uphold the fundamental principles in labor relations and environmental protection that are enshrined in the UN conventions and the International Labour Organization (ILO).”191 “As an international company that operates in countries with various political systems and cultural traditions, LUKOIL recognizes the importance of respecting and observing fundamental human rights declared by the United Nations, including labor rights, the right to a healthy environment, and the rights of small indigenous peoples and special groups. The Company acts in strict compliance with the Social Charter of Russian Business and the Universal Declaration of Human Rights, according to which every individual enjoys all the rights and freedoms proclaimed therein. The Company's commitments under the UN Global Compact apply to all areas of our activity, and involve making respective notifications to the organizations with which LUKOIL Group entities interact.”192 Lukoil Group (2018), Synergy of Achievements and Responsibility: Sustainability Report 2018, p. 34, available at http://www.lukoil.com/FileSystem/9/344313.pdf (last accessed on 12 September 2019). 189 Id., p. 22. 190 Id. 191 Id. 192 Lukoil Co., Human Rights, available at https://csr2018.lukoil.com/strategy/ethics/human-rights (last accessed on 12 September 2019). 188 Annex D: Corporate Statements on Climate Change and Human Rights | 48

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