back end of april .update??, page-11

hi big fish 72 you seem to have your finger on the pulse re your correspondence with DR.

PART 1
Acquisition of new assets

Before deciding to get involved in a new exploratory block or a new block under development, we assess the existing and potential risks. In these assessments we pay special attention to risks relating to corruption or insufficiently justified payments, the existence of environmental liabilities, the safety of the existing facilities and the presence of communities in the affected area.

This process of due diligence is regulated by company policy and involves the participation of different areas of the company in the preliminary assessment process. This assessment assumes particular importance in socially or environmentally sensitive areas, such as those where indigenous communities are present, where there is a great deal of biodiversity or where there are exceptional safety concerns.

The audit and control department, at the request of the business units and the legal services department, takes part in the audits prior to the acquisition of assets. These audits include a thorough review of the processes for negotiating and signing contracts, paying particular attention to possible risks of corruption or failure to adhere to the guidelines described in the United States' Foreign Corrupt Practices Act.

PART 2
Partner relations

Our relations with partners, in cases where we establish partnerships or joint ventures, are regulated by Joint Operating Agreements (JOA). The purpose of a JOA is to outline the responsibilities and limits that each of the partners will have in the operation and management of an asset.

A large part of the activities we undertake are carried out with partners. These relationships are formalized through Joint Operating Agreements (JOA). Two or more companies can enter into a JOA in order to share the exploration and/or production costs of an oil and gas field. One of the parties assumes responsibility for day-to-day operating, and all the other parties to the JOA jointly monitor the activities on a periodical basis. All the member partners in the JOA likewise share the costs and profits generated, proportionately to their holding. This way, companies have the option of diversifying their risks and extending their project portfolio.

In those activities where ?????? is the operating partner, we implement our regulations and standards. Aware of how important it is that our partners uphold similar ethical, social and environmental standards to our own in the activities in which ?????? is not the operating partner, we use our capacity of influence to ensure our regulations and management systems are implemented or that principles and systems are followed that are equivalent to ours.

We form technical committees to discuss the most relevant matters with our partners relating to how activities are undertaken, the resolution of problems and unforeseen circumstances, implementation of best practices, approval of work plans and operations monitoring. Through said technical committees we inform our partners of our requirements as regards corporate responsibility. These sessions enable us to share experiences, analyze the impacts of the project and to plan mitigation and corrective measures.

To learn whether the practices employed by our partners are in line with our regulations, the company asks its partners to fill out the Foreign Corrupt Practices Act (FCPA) due diligence questionnaire, which includes specific questions on policies and practices to combat corruption.

In addition, association contracts include a specific clause (Conduct of the Parties) which commits the signing parties to reject any type of payment, gift, bribe or favorable treatment in exchange for the other person or entity obtaining a benefit or carrying out an activity that may go against the principles described in the OECD Convention on Combating Bribery of Foreign Public officials and the US FCPA.

PART 3

Joint operations

In activities where ?????? is not the operating partner, we undertake to use our influence to ensure that our partners implement our management policies and systems, or that they abide by ethical, social and environmental principles and systems that are equivalent to ours.

??????'S ethical, social, environmental and safety requirements are communicated to partners mainly through meetings and technical committees in which projects are reviewed. These sessions enable us to share experiences and analyse the impact of the project.

We take advantage of our participation in these meetings to transmit our regulatory requirements to our partners and explain our expectations regarding how activities should be carried out and our relationship with the location.

Acquisition of new assets

Before deciding to acquire an asset, the existing and potential risks are assessed, paying special attention to risks relating to corruption or insufficiently justified payments, the existence of environmental liabilities, or the presence of communities in the area of influence.

The company carries out a due diligence process, including the evaluation and management of risks that may arise in commercial operations involving the acquisition or exchange of assets, mergers, alliances or joint ventures. These evaluations are especially important in socially or environmentally sensitive areas, such as where there are indigenous communities, a high level of biodiversity, or unusual safety situations.

The Audit and Control Department, at the request of the business units and legal services, will collaborate in the audits conducted before acquiring assets. These audits will include an exhaustive review of the contract negotiation and signature process, paying special attention to possible risks of corruption or breach of FCPA principles.
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is this your intimation of the process still to be finalised as per your correspondence with DR.

WG