Comparison of HSESAP Revisions 2 and 3

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1 The structure of HSESAP Revision 3 is considerably modified from Revision 2. The following summary is provided to identify the comparative location of key information and any changes following the revision of HSESAP for operations phase. Links are provided to current Company Standards and old Part 2 Tables (which are annotated to indicate the new location of each requirement). HSESAP Revision 2 Part 1 HSESAP Revision 3 Section Title Section Title 1 INTRODUCTION 1 INTRODUCTION 1.1 PURPOSE AND SCOPE 1.1 Purpose and Scope HSESAP Part Structure HSESAP Annexes HSESAP Part BACKGROUND TO SAKHALIN ISLAND AND THE PROJECT 1.3 Background to Sakhalin Island and the Project 1.3 COMMITMENTS TO RUSSIAN AND 3.1 Commitments to Russian and International INTERNATIONAL STANDARDS 1.4 SAKHALIN ENERGY S SUSTAINABLE DEVELOPMENT POLICY Standards 2.2 Sakhalin Energy s Sustainable Development Policy 1.5 OPERATING PHILOSOPHY 2.1 Sakhalin Energy s General Business Principles 1.6 OPEN COMMUNICATION Communication and consultation 1.7 MANAGEMENT SYSTEMS COMMON TO HSE AND SOCIAL HSESAP OBLIGATIONS 2.5 Sakhalin Energy s Management System Organisation and Leadership Organisation, resourcing, roles and Planning and Internal Monitoring Objectives and annual improvement plans Commitments to Company Standards HSE and Social Matrix Methodology for Classifying and Remediating Incidents and Breaches The IMPACT Action Tracking System Corrective and preventative actions External Assurance HSE Assurance Standard 2 MANAGEMENT OF HSE 2 MANAGEMENT OF HSE AND SOCIAL 2.1 INTRODUCTION 2.2 OBJECTIVES OF HSE-MS Framework and content of the management 2.3 STRUCTURE OF THE SAKHALIN ENERGY HSE MANAGEMENT SYSTEM system 2.4 HSE POLICY 2.3 Sakhalin Energy s HSE Policy and Commitment 2.5 HSE ROLES AND RESPONSIBILITIES WITHIN THE COMPANY Organisation, resourcing, roles and 2.6 LEGAL INFORMATION DATABASE 3.1 Commitments to Russian and International Standards 2.7 PROCURING HSE AWARENESS Organisation, resourcing, roles and Commitments to Company Standards Awareness, training and competence

2 HSESAP Revision 2 Part 1 HSESAP Revision 3 Section Title Section Title 2.8 HAZARD AND EFFECTS Hazard and risk management MANAGEMENT 2.9 RISK ASSESSMENT MATRIX (RAM) 2.10 OTHER USES OF THE RISK ASSESSMENT MATRIX BY THE PROJECT 2.11 PLANNING AND PROCEDURES Objectives and annual improvement plans Awareness, training and competence Communication and consultation Commitments to Company Standards 2.12 MONITORING 2.13 MONITORING OF CONTRACTOR 2.14 ACTION TRACKING SYSTEM (IMPACT) 2.15 INCOMING MONITORING INITIATIVES HSE Management of Contractors Standard Corrective and preventative actions Methodology for Classifying and Remediating Incidents and Breaches 2.16 AUDIT 2.17 IMPLEMENTATION OF AUDIT RECOMMENDATIONS HSE Assurance Standard 2.18 LENDER RIGHTS OF AUDIT 2.19 SAKHALIN ENERGY S ASSURANCE PROCEDURE 3 SOCIAL ISSUES 2 MANAGEMENT OF HSE AND SOCIAL 3.1 INTRODUCTION 3.2 PROJECT BENEFITS 1.3 Background to Sakhalin Island and the Project 3.3 SOCIAL ASSESSMENT, GUIDELINES ETC APPLICABLE TO THE PROJECT Hazard and risk management 3.4 SOCIAL IMPACT MANAGEMENT SYSTEM: OVERVIEW Framework and content of the management system 3.5 LEADERSHIP AND RESPONSIBILITIES Organisation, resourcing, roles and 3.6 PLANNING 2 MANAGEMENT OF HSE AND SOCIAL Policy 2.4 Sakhalin Energy s Social Performance Policy Standards Social Performance Standard Assessments Hazard and risk management Company Commitments Social Performance Standard Key Performance Indicators Social Performance Standard 3.7 IMPLEMENTATION Organisation, resourcing, roles and

3 HSESAP Revision 2 Part 1 HSESAP Revision 3 Section Title Section Title 3.8 TRAINING Awareness, training and competence CLO Organisation s Role in the Project Communication and consultation Issues Management Hazard and risk management Grievances Communication and consultation Commitments to Company Standards Addressing Grievances Management of Change Management of change Land Acquisition, Resettlement and Supplemental Assistance Resettlement Management Social Investment Social Investment Strategy 3.9 MONITORING Social Performance Monitoring 3.10 AUDITING Social Performance Monitoring HSE Assurance Standard 3.11 MANAGEMENT REVIEW Management review 3.12 SAKHALIN ENERGY ASSURANCE PROCESS HSE Assurance Standard 4 CONTRACTOR MANAGEMENT HSE Management of Contractors Standard 5 REPORTING TO AND AUDITING BY LENDERS HSE and Social Performance Reporting to Lenders HSE Assurance Standard 5.1 REPORTING 5.2 INFORMATION DELIVERABLE DURING CONSTRUCTION 5.3 REPORTING AFTER COMPLETION OF CONSTRUCTION 5.4 LENDER PROJECT MONITORING VISITS 5.5 AUDITS 5.6 PROVISION OF ENVIRONMENTAL AND SOCIAL REPORTS TO PHASE 2 SENIOR LENDERS HSE and Social Performance Reporting to Lenders HSE Assurance Standard HSE and Social Performance Reporting to Lenders 5.7 REPORTS PREPARED BY THE ENVIRONMENTAL CONSULTANT 5.8 NOTIFICATION OF ENVIRONMENTAL INCIDENTS AND SIGNIFICANT HSE OR SOCIAL HARM 5.9 THE MANAGEMENT OF CHANGE Management of change Sakhalin Energy s Change Management Procedure Changes to the HSESAP 3.4 Changes in Commitments 6 METHODOLOGY FOR DEALING WITH SERIOUS HSE AND SOCIAL INCIDENTS AND HSE AND SOCIAL COMPLIANCE BREACHES Methodology for Classifying and Remediating Incidents and Breaches 7 PROJECT EXPANSIONS Project Expansions HSES Procedure

4 HSESAP Revision 2 Part 2 Tables 2.1 Hydrocarbon Spill Prevention, Preparedness and Response Loss Prevention in Design and Construction Oil Spill Preparedness and Response Specification Soil and Groundwater Standard Soil and Groundwater Operational Controls Soil and Groundwater Assurance Offshore Aqueous Discharges Specification Waste Minimisation, Diversion and Disposal Maritime HSE Specification 2.2 Solid Waste Management Waste Management Standard International Requirements for Waste Management Waste Management Standards Comparison Waste Minimisation, Diversion and Disposal Approved Waste Storage Facilities Approved Waste Diversion and Disposal Facilities Waste Containers, Labeling and Transport Waste Tracking and Reporting Waste Management Assurance Maritime HSE Specification Site Decommissioning Specification HSE Monitoring Specification Onshore Biodiversity Offshore Biodiversity Biodiversity Standard International Requirements for Biodiversity Wetlands Specification Steller s Sea-Eagles and Endangered Birds Marine Mammals Specification Fisheries, Hunting and Gathering Specification Dredging Specification Non-native Invasive Species Specification Maritime HSE Specification Biodiversity Management Assurance Site Preparation and Construction Specification Onshore Pipelines Right of Way Specification River Crossings Specification Hydrostatic Testing Specification HSE Monitoring Specification Water Use and Aqueous Discharges Standard Offshore Aqueous Discharges Specification Onshore Aqueous Discharges Specification Waste Minimisation, Diversion and Disposal

5 HSESAP Revision 2 Part 2 Tables 2.5 Management of Land Land Management Standard International Requirements for Land Management Site Preparation and Construction Soil Reclamation and Site Reinstatement Onshore Pipelines Right of Way River Crossings Site Decommissioning Land Management Assurance FERC Upland Erosion Control, Revegetation and Maintenance Plan Biodiversity Standard Wetlands Specification Oil Spill Preparedness and Response Specification Hydrostatic Testing Specification Onshore Aqueous Discharges 2.6 Community Health Community Health in Construction 2.7 Occupational Health and Safety Occupational Health and Sanitation Standard International Requirements for Health and Sanitation Hazardous Activities Standard International Requirements for Hazardous Activities 2.8 Emissions to Atmosphere Air Emissions and Energy Management Standard International Requirements for Air Emissions and Energy Management Air Emissions Standards Comparison Air Emissions and Energy Management Assurance International Requirements for Waste Management HSE Monitoring 2.9 Chemicals Management Chemicals Management Specification Soil and Groundwater Operational Controls Specification 2.10 Social Performance Standard International Requirements for Social Performance Social Performance Monitoring Specification 2.10A Public Consultation and Disclosure Public Consultation & Information Disclosure Specification 2.10B Commitments to Resolving Grievances Addressing Grievances Specification 2.10C Russian Content, Employment and Russian Content and Employment Specification Business Opportunities 2.10D Impact on Indigenous Peoples Indigenous Peoples Specification 2.10E Commitments Relating To Land Clearance Cultural Heritage Specification Site Preparation and Construction Specification 2.10F Commitments relating to Land Resettlement Management Specification Acquisition, Resettlement and Compensation 2.10G Social Investment Social Investment Strategy Specification 2.11 Road Safety Road Transport HSE Management Standard International Requirements for Road Transport

6 HSESAP Revision 2 Annex A Part 1 Annex A: Project Compliance with Annex A International Standards (HSESAP Part 1 pages ) International Requirements for Managing Risk International Requirements for Social Performance International Requirements for Biodiversity A1 Indigenous Peoples International Requirements for Social Performance A2 Cultural Property International Requirements for Social Performance A3 Resettlement International Requirements for Social Performance A4 Occupational Health Safety International Requirements for Health and Sanitation International Requirements for Hazardous Activities A5 Hazardous Materials International Requirements for Health and Sanitation International Requirements for Hazardous Activities International Requirements for Asset Integrity and Process Safety International Requirements for Soil and Groundwater A6 Waste International Requirements for Waste Management A7 Air Emissions International Requirements for Air Emissions and Energy Management A8 Discharges to Water International Requirements for Water Use and Aqueous Discharges A9 Soil conservation International Requirements for Land Management FERC Upland Erosion Control, Revegetation and Maintenance Plan HSESAP Revision 2 Annex B B Convention comparison tables (Habitats, Shipping, Social matters, Ratified conventions) International Requirements for Biodiversity (Annex B1; Annex B2; Annex B4 Habitats Biological Diversity and Heritage, Protection of Water Resources, Shipping (safety), Convention on Transboundary Effects of Industrial Accidents, Bilateral Agreements) International Requirements for Social Performance (Annex B3; Annex B4 Social/Consultation) International Requirements for Air Emissions and Energy Management (Annex B4 Air Quality) International Requirements for Waste Management (Annex B4 Waste) International Requirements for Land Transport Safety (Annex B4 UN ADR Agreement on the International Carriage of Dangerous Goods by Road) HSESAP Revision 2 Annex C C Monitoring HSE Monitoring Specification Social Performance Monitoring Specification

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