Statoil’s Anti-Corruption Compliance Programme Stockholm 14 November 2012 Erik I. Nürnberg, Senior Legal Counsel The Anti-Corruption Compliance Programme Jakarta, 21 October 2015 Countering Illicit Financial Flows in the Extractive Industry

Classification: Internal Classification: Internal Classification: Internal

Classification: Internal (Restricted Distribution) Statoil operates in challenging countries

The global legal framework for our business 4-4- Classificati on: Internal Norwegian law (Civil Penal Code §§276a-c) The US FCPA (part of Securities and Exchange Act) The UK Bribery Act 2010 In addition to all applicable local law

Anti-corruption work in Statoil Our starting point Classif ication: Interna l Statoil believes that a zero-tolerance policy on corruption is essential to sustainable business. Statoil confirms in its Code of Conduct that it opposes all forms of corruptions and will make active efforts to ensure that it does not occur in the group’s business activities. Statoil defines corruption to also include facilitation payments and trading in influence.

Prevention Board and management commitment Clear policies and standards Communication and training Ethics Committees Risk assessment and due diligence Contractual standards Detection ReportingNon-retaliation policy Advisory function Compliance network Verifications Audits Internal controls Supplier follow up Response Incident handlingDisciplinary actionsLearning/ rectificationInvestigationsSelf reporting 6 - Anti-corruption efforts headed by Legal Our work – three pillars

Anti-Corruption Compliance Program Pieces of the Pie Top Level Commitme nt Risk Assessment Policies and Procedures Accounting and financial controls Communication Monitoring and Review Due Diligence Classif ication: Interna l

CEO Eldar Sætre “A t Statoil, the way we deliver is as important as what we deliver.”

Anti-Corruption Compliance Program Pieces of the Pie Top Level Commitment Risk Assessment Policies and Procedures Accounting and financial controls Communication Monitoring and Review Due Diligence Classif ication: Interna l

Ethics Code of Conduct Our staring point Classif ication: Interna l Applies to: o The organization and to it’s individual employees o Board members o Hired personnel, consultants, intermediaries, lobbyists and others who act on Statoil’s behalf Includes: o Code of business practice o Code of personal conduct o Practice and follow-up

Anti-Corruption Compliance Program Pieces of the Pie Top Level Commitment Risk Assessment Policies and Procedures Accounting and financial controls Communicatio n Monitoring and Review Due Diligence Classif ication: Interna l

Training and communication Visible and repeated Mandatory e-learning for all employees Tailor-made workshops for employees, suppliers and business partners Ethics committees Engagement in compliance networks Involvement in contract negotiations, projects and business development work 12 -Classification: Internal Classification: Internal

Anti-Corruption Compliance Program Pieces of the Pie Top Level Commitment Risk Assessment Policies and Procedures Accounting and financial controls Communication Monitoring and Review Due Diligence Classif ication: Interna l

Classification: Internal Classification: Internal Classification: Internal Monitoring and follow-up Examples of what we do − Regular follow-up of partners through company representatives − Local compliance officers − Annual risk assessment − Financial and accounting controls − Audits & verifications − Ethics Helpline and regular reporting lines − Revenue transparency reporting

Statoil has reported payments to governments on a country-by-country basis for a decade Disclosing payments to governments is important to prevent corruption and tax evasion – it enables communities to hold governments accountable For a decade, Statoil has voluntarily disclosed payments to governments on a country-by-country basis in the Annual Sustainability Report Statoil has a strong legacy of being open about payments to governments: −We have been rated as the «World’s most transparent company» by Transparency International due to our voluntary disclosures −We are a supporting company of the Extractive Industries Transparency Intiative (EITI) and hold a seat on the global EITI Board In 2014, we reported payments to governments on a project-by-project basis, aligned with the new requirements in Norway 15

The Norwegian transparency rule In December 2013, amendments to the Norwegian Accounting Act (Regnskaploven) and the Norwegian Securities Act (Verdipapirhandelloven) were passed, requiring disclosure of payments to governments for large extractive and logging companiesRegnskaplovenVerdipapirhandelloven Payments to governments must be disclosed at project and country level (similar to EU), and to each government entity: −Tax, royalties, bonuses, fees, production entitlements, dividends, infrastructure improvements and transferal of shares/ownership rights In addition, ‘contextual information’ must be disclosed: −investments, revenues, purchase of goods and services and production volumes per country −All subsidiaries, including the country of origin, number of employees and each subsidiary’s intercompany interest expenses to other subsidiaries in other jurisdictions Reporting period Filing March

Payments to Governments (link)link Classification: Internal

Classification: Internal

Classification: Internal

Classification: Internal Classification: Internal (Restricted Distribution) Classification: Internal Classification: Confidential Classification: Internal Classification: Internal (Restricted Distribution) Classification: Internal Classification: Confidential Classification: Internal Thank you