Statoil ’s Anti-Corruption Compliance Programme

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

2. Classification: Internal 2011-08-22

3. Statoil operates in challenging countries

4. 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 The global legal framework for our business

5. Anti-corruption work in StatoilOur starting point • 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.

6. Anti-corruption efforts headed by LegalOur work – three pillars

7. Anti-Corruption Compliance ProgramPieces of the Pie Top Level Commitment Risk Assessment Accounting and financial controls Communication Monitoring and Review Due Diligence Policies and Procedures

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

9. Anti-Corruption Compliance ProgramPieces of the Pie Top Level Commitment Risk Assessment Accounting and financial controls Communication Monitoring and Review Due Diligence Policies and Procedures

10. Ethics Code of ConductOur staring point Applies to: • The organization and to it’s individual employees • Board members • Hired personnel, consultants, intermediaries, lobbyists and others who act on Statoil’s behalf Includes: • Code of business practice • Code of personal conduct • Practice and follow-up

11. Anti-Corruption Compliance ProgramPieces of the Pie Top Level Commitment Risk Assessment Policies and Procedures Accounting and financial controls Monitoring and Review Due Diligence Communication

12. Training and communicationVisible 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

13. Anti-Corruption Compliance ProgramPieces of the Pie Monitoring and Review Top Level Commitment Risk Assessment Policies and Procedures Accounting and financial controls Communication Due Diligence

14. Monitoring and follow-upExamples 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 Classification: Internal 2011-08-22

15. 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

16. The Norwegian transparency rule Reporting period 2013 2015 2016 Filing March 2015 • 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 companies • 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 andtransferal 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

17. Payments to Governments (link)

20. Thank you Classification: Internal (Restricted Distribution) 2010-12-03Classification: Internal 2010-12-01Classification: Confidential 2010-10-26Classification: Internal 2010-10-24