4.7. Control of Contractors in Relation to Occupational, Industrial, and Fire Safety

Safety of Gazprom facilities operation depends to a large extent upon contractor companies that provide services and carry out repair and construction works on behalf of the Group.

Incidents and lack of normal workplace conditions and amenities at contractor companies create risks of delays in repairs and construction and subsequent risk of late commissioning of production facilities and deter highly qualified professionals.

Gazprom requires that the suppliers and contractors strictly adhere to the established occupational, industrial and fire safety standards and procedures while performing the works at Gazprom facilities. During the bidding and procurement stage, the participants are checked for availability of the documents certifying their compliance with occupational, industrial and fire safety requirements.

The subsidiaries and entities of PJSC Gazprom have developed documents regulating the procedures for access to the facilities and control of contractors based on the operational and regional specifics. The contractual documents were amended to include the new requirements that contractors need to comply with.

Prevention of accidents and workplace injuries is one of the key conditions for collaboration with contractors. The contractor companies are notified of and advised on the ISPSM requirements, the identified risks and changes affecting the safety during the introductory briefings, as well as when the work permits (safe work permits, clearance certificates) are issued. PJSC Gazprom, its subsidiaries and contractorsFor PJSC Gazprom subsidiaries that are part of the Unified Gas Supply System (involved in production, transportation, storage and processing), the main contractor organizations are subsidiaries enabling operation of the UGSS, which are covered by the ISPSM. They include, in particular, the subsidiaries and entities performing overhauls, construction, survey and design works, supplying energy resources and providing motor and railway transportation and special machinery and equipment. have arranged exchange, collection and analysis of statistics of incidents at contractor companies.

Representatives of the contractor companies participate in PJSC Gazprom meetings and workshops on implementation of the process safety policy, process safety culture improvement, and development of management leadership skills.

The control over the activities of contractor companies is performed in line with STO Gazprom 18000.3-004-2020 Integrated System of Process Safety Management. Organizing and Conducting AuditsApproved by order of PJSC Gazprom No. 94 dated March 2, 2020; in effect starting from March 12, 2020 instead of STO Gazprom 18000.3-004-2014. based on the developed program of internal audits of the ISPSM.

Apart from the ISPSM audits, the activities of contractor companies are overseen as part of administrative and production control within subsidiaries.

All contracts concluded by Gazprom Neft with its contractors include the requirements on compliance with the rules and regulations established in the regions of operations, as well as the corporate industrial, occupational, and environmental safety requirements. Entering into contracts for essential technical operations is preceded by an evaluation of the technical condition of the equipment, the qualification of the personnel, and the implemented process safety management systems of the contractor.

Gazprom Neft informs its contractors of the applicable rules, norms, and procedures and holds joint meetings to find the best solutions on how to improve the safety of the works.

As works are carried out, there is continuous monitoring of their compliance with the safety requirements and the contractor performance in terms of safety. If deviations are identified, the parties cooperate to remedy them.

Each year, Gazprom Neft’s contractors take part in Safety Days held by the Group.

Gazprom Energoholding implements a number of measures to promote responsibility among contractors for maintaining a safe working environment and occupational health and safety procedures at the facilities of Gazprom Energoholding. These include mandatory occupational safety induction training, preparation of workplaces with issuance of safe work permits, and checks of whether staff members have received safety training and certification. Occupational Health and Safety Days are another means of encouraging contractors’ employees to comply with the requirements of the occupational safety system.

Gazprom Neftekhim Salavat includes the Procedure of Cooperation in Relation to Compliance with Environmental, Industrial, Occupational, Fire, Road Traffic Safety, Internal Labour Rules and Regulations, On-Site and Access Authorization Procedures into all contracts with contractors.

The local regulations governing the performance of contractor works at the plant facilities are available on the website of Gazprom Neftekhim Salavat, as is required by the Procedure of Cooperation.

Gazprom Neftekhim Salavat also conducts audits of high-hazard operations carried out by contractor companies. The identified deficiencies are recorded in a certificate of high-hazard operations inspection to be subsequently remedied.

There is also a telephone hotline in place for contractor employees.

Pursuant to the instruction of the PJSC Gazprom Management Committee, in 2020, it is planned to start using the INTERGAZCERT voluntary certification system for authorizing contractors to perform works or render services at PJSC Gazprom’s facilities, as well as for controlling their compliance with the process safety requirements.