Stakeholder Engagement | Gazprom Group’s Sustainability Report

Stakeholder Engagement Principles

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The main principles of the Gazprom Group’s stakeholder engagement are inclusivity, materiality, impact, and responsivenessAs set out in the internationally recognized AA1000 ACCOUNTABILITY PRINCIPLES (AA1000AP, 2018) and AA1000 Stakeholder Engagement Standard (AA1000SES, 2015).

Inclusivity

Taking into account Gazprom’s stakeholders’ points of view as to the significance and impact of a particular matter in order to enable the Group to develop an expedient and commensurate response method.

Materiality

Identifying and ranking relevant and significant matters and underlying factors that make an impact on Gazprom and its stakeholders.

Impact

Monitoring, measuring and assessing the impact of Gazprom’s principles, activities and results of operations on the economy, environment, society, stakeholders and the Group itself.

Responsiveness

Taking into account material topics and corresponding impacts in making decisions, taking actions and planning day-to-day operations of the Gazprom Group (including communications).

Gazprom Group’s Stakeholders

The Gazprom Group identifies ten stakeholder groups:

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The results of the survey conducted among the Task Force members formed the basis for the stakeholder mapping that shows: (1) the degree to which the Company’s operations impact stakeholders’ decisions and actions and (2) the degree to which stakeholders’ decisions and actions impact the Company’s operations. The Task Force members ranked both indicators on a three-point scale from 1.0 (low level) to 3.0 (high level) based on their own experience and competencies. The survey covered 24 people.

1 — Shareholders

2 — Business partners

3 — Foreign regulators of energy markets

4 — Investors

5 — Local communities

6 — NGOs and educational institutions

7 — Government and local authorities

8 — Personnel

9 — Consumers

10 — Media

Alexey Finikov

Deputy Head of Department — Head of Directorate; responsible for shaping and implementing the investor relations strategy of PJSC Gazprom, collects investor feedback and articulates the Company’s approaches to sustainable development.

Stakeholder Engagement

Stakeholder Engagement Formats

In implementing its information policy, PJSC Gazprom is guided by the principles of regularity, prompt disclosure, accessibility, reliability, completeness, balance, neutrality, and security.

Concept and Principles of Information Disclosure

Information disclosure means ensuring that information is available to an unlimited number of individuals or entities (shareholders, investors, organizations acting as regulators of relevant markets, government authorities, mass media, and other stakeholders).

The key principles of information disclosure concerning the Company’s activities are: regularity and promptness, accessibility, reliability and completeness, balance and neutrality, and security.

The principle of regularity and promptness means the disclosure of information about material events and facts concerning the Company’s activities on a regular basis and in the shortest possible time.
The principle of accessibility means the use of channels and ways of disseminating information about the Company that give shareholders and other stakeholders free and non-discriminatory access to the information disclosed. Copies of documents are provided upon request to shareholders and other persons/entities authorized to their receipt in line with the current laws of the Russian Federation for a fee not exceeding the costs incurred by the Company to make such copies.
The principle of reliability and completeness means the provision of reliable information about the Company’s activities sufficient to provide an unbiased view of the issue in question and to make managerial and investment decisions.
The principle of balance means the Company’s commitment to observe a reasonable balance between the Company’s transparency and the protection of its commercial interests.
The principle of neutrality means that the Company creates an environment that excludes the possibility of giving any of its shareholders or investors preferential access to the information about the Company’s activities.
The principle of security means that the Company applies each and every organizational, legal and technical measure and tool permitted by Russian laws to protect the information constituting state and trade secrets, as well as insider information.

Regulation on Disclosure of Information by PJSC Gazprom approved by Resolution of the Board of Directors of PJSC Gazprom No. 2921 dated March 29, 2017 (as amended by Resolution of the PJSC Gazprom Board of Directors No. 3152 dated August 22, 2018).

The main channels to inform stakeholders are press releases and press trips, responses to media requests, press conferences and media scrums, publications on the official website and social media. In 2020, amid the lockdown restrictions, the communication with media representatives continued across all the traditional formats, with the exception of public meetings, such as press conferences and press trips.

In June 2020, PJSC Gazprom launched its official Telegram channel for a broad audience of stakeholders.

Documents governing PJSC Gazprom’s information disclosure:

Regulation on Disclosure of Information by PJSC GazpromApproved by resolution of the PJSC Gazprom Board of Directors No. 2921 dated March 29, 2017 (as amended by resolution of the PJSC Gazprom Board of Directors No. 3152 dated August 22, 2018);
order of OJSC Gazprom No. 12 dated February 4, 2002 “On Approval of the Regulation on the Procedure for the Preparation of Information Materials for the Media and their Submission to the Media”As amended by orders of OJSC Gazprom No. 20 dated February 25, 2005, and No. 202 dated July 7, 2009;
order of PJSC Gazprom No. 764 dated November 20, 2017 “On Arranging Information Disclosure by Way of Messaging at PJSC Gazprom”As amended by orders of PJSC Gazprom No. 415 dated July 17, 2018, and No. 476 dated October 23, 2019.

In order to ensure efficient interaction between employees and managers at the Gazprom Group, corporate communications are in place, such as intranet portals and information-and-reference systems, including corporate ones, hot lines, e-mail newsletters, and videoconferences with remote corporate units. The Group has corporate media: 64 newspapers and 5 magazines, 1 TV program, 3 in-house TV channels, 2 radio stations, and 1 corporate online media outlet.

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In 2020, ESG surveys among major shareholders and investors were held with assistance from The Bank of New York Mellon – the issuing bank of American depositary receipts (ADRs) for PJSC Gazprom’s shares.

The information obtained in the management’s communications with shareholders and investors across various formats was submitted to the PJSC Gazprom Board of Directors as part of the materials prepared on the agenda item “On the outcomes of the measures to streamline the relationship with the shareholders and investors of Gazprom”Minutes of PJSC Gazprom Board of Directors’ meeting No. 1344 dated December 24, 2020, agenda item No. 1. It is also taken into account in the preparation of activities aimed at further enhancing the Company’s corporate governance.

The Gazprom Group has relevant engagement mechanisms in place for each stakeholder group.

The system of stakeholder engagement at the Gazprom Group

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Stakeholder Groups	Corporate units / Bodies Responsible for Engagement	Engagement Mechanisms	Examples of Engagement in 2020
Shareholders	Coordinating Committee for Shareholder and Investor Relations of PJSC Gazprom¹ PJSC Gazprom unit performing the Corporate Secretary functions Relevant units of PJSC Gazprom;	Implementation of the Shareholder and Investor Relations Action Plan² In-person events and teleconferences Information disclosure Responses to inquiries, including as part of annual General Shareholders Meetings Online and offline communications on arising issues	Annual General Shareholders Meeting in absentia, with electronic voting³ Information disclosure in the form of the Issuer’s Quarterly Reports, Annual Report, Environmental Report, Gazprom Group’s Sustainability Report, and financial statements under the IFRS and RAS Publishing databooks “Gazprom in Figures”, “Analyst Data Book” (Gazprom Neft), “Gazprom Neft Statistic Data”, and “Gazprom Energoholding Group of Companies in Questions and Answers” Placing corporate periodicals, including Gazprom magazine, in the public domain ESG opinion surveys of shareholders
Investors	Coordinating Committee for Shareholder and Investor Relations of PJSC Gazprom PJSC Gazprom unit performing the Corporate Secretary functions Relevant units of PJSC Gazprom	Implementation of the Shareholder and Investor Relations Action Plan In-person events and teleconferences Information disclosure Online and offline communications on arising issues	PJSC Gazprom’s annual Investor Day (the US and the UK, February 2020). The event in New York involved over 70 representatives of the investor community, with the online broadcast viewed by more than 100 people. The event in London was visited by over 130 investors and shareholders offline and over 120 attendees online. The Company’s top management held a total of over 35 meetings with investors in these two cities PJSC Gazprom’s representatives taking part in online events dedicated to the Chinese gas market (led by UBS) and the European gas market (led by Morgan Stanley, Gazprombank, and Goldman Sachs) First webinar for the international investor community regarding the Chinese gas market, with 136 attendees (July 2020) PJSC Gazprom taking part in private investor events arranged by VTB Capital and Aton Over 70 meetings of the Gazprom Group management and representatives with attendees from over 140 Russian and international institutional investment funds (online) Four conference calls on the publication of the Gazprom Group’s consolidated financial statements under the IFRS, attended by the Company’s management, following the publication of quarterly and annual IFRS reports Annual end-of-year online meeting between the Company’s management and investment analysts to discuss the preliminary results of the reporting year (December 2020) Opinion survey on the development level of the Company’s corporate governance
Business partners	Relevant units of PJSC Gazprom Relevant units of subsidiaries	Contractual relations Cooperation agreements Joint Coordination Committees and Joint Task Forces between PJSC Gazprom and foreign partners Conferences and forums Industry unions and associations Pre-qualification of prospective suppliers and contractors	Implementation of joint projects Meetings of Joint Coordination Committees and Joint Task Forces focused on key areas of cooperation Interaction within the framework of economic and energy forums and conferences Interaction with the Russian Gas Society (Union of Oil and Gas Industry Companies) within the framework of the implementation of the Target Program for the Enhancement of the Legal and Regulatory Framework in Gas Supply as regards making improvements to laws and regulations relating to gas supply Cooperation, working meetings, and participation in joint task forces with Russian oil and gas companies 809 companies, including 577 SMEs, were included in the Gazprom Group’s Register of Potential Bidders as of February 1, 2021, after the pre-qualification procedure
Personnel	Department in charge of HR management	System of internal communications Feedback Top management addresses to employees Satisfaction surveys Assessment, training and professional development	Conferences to summarize the results of implementation of the General Collective Agreement of PJSC Gazprom and its subsidiaries⁴ Workshop meetings for personnel of HR departments Regular meetings of representatives of the workforce and the management to resolve topical issues Training newly hired employees
Government and local authoritiesя	Department in charge of government relations in the Russian Federation Regional Policy Commission	Signing agreements with the regions of the Russian Federation Presentations on the Gazprom Group’s activities to senior government officials Cooperation under business contracts, agreements and partnership memoranda	Signing of contracts, agreements and memoranda on cooperation with constituent entities of the Russian Federation (the Komi Republic, Astrakhan Region, and Sakhalin Region) Participation in parliamentary hearings, forums, round tables and task force meetings held by federal and regional executive authorities and public organizations Participation in the development of roadmaps Participation in expert review of draft laws, preparation of proposals, comments and amendments thereto Implementation of the Gas Infrastructure Expansion Program in the regions of the Russian Federation, including the holding of conferences and meetings on gas infrastructure expansion issues Cooperation with regional governments of the Russian Federation under agreements on promoting the use of natural gas as a motor fuel Signing of the Gas supply and gas infrastructure expansion programs for 2021–2025 between PJSC Gazprom and 67 regions of the Russian Federation
Local communities	Relevant units of PJSC Gazprom Regional Policy Commission Environmental departments of subsidiaries PR departments of subsidiaries	Open public hearings Information centers Community councils at the Group's companies in the areas of their operations Information disclosure Charity and sponsorship projects Series of environmental awareness events Group-wide and areas-of-operation opinion surveys Signing contracts to assist non-profit organizations and public law institutions	Holding public hearings on environmental impact assessment (EIA) Charity and volunteering (annual support of culture and arts, projects to preserve historic and cultural heritage, professional and amateur sports, education, healthcare, urban infrastructure development projects; implementation of the Gazprom for Children and Football for Friendship programs, annual New Year initiative run by PJSC Gazprom for children who need social support) Cooperation with representatives of indigenous minorities of the North): organization of national festivals; preservation of lifestyle, traditional habitat, national crafts, etc. 6 special practical events as part of the Friends of St. Petersburg project for students of educational institutions specializing in arts, architecture and conservation 1 tour of the permanent exposition of the Central Naval Museum with young experts in the history of the National Navy from the Nakhimov Naval School and Peter the Great Naval Corps – St. Petersburg Naval Institute taking part, with a quiz on Admiral Kruzenstern Activities of community councils (e.g. the Amur Gas Processing Plant construction project: ongoing communicationwith the local community activists; joint events aimed at integration of foreign employees; implementation of social-and-economic and cultural projects and initiatives, etc.)
Foreign regulators of energy markets	Department in charge of foreign economic activity Relevant units of subsidiaries	Information disclosure Consultations Participation in international energy conferences and webinars	Submission of regular reporting materials which cover the terms of signed gas supply contracts and addenda thereto and those of transactions carried out on the Electronic Trading Platform of Gazprom Export LLC, as well as updates on actual gas supplies to the European Union (EU) countries to the Agency for the Cooperation of Energy Regulators (ACER) and Energie-Control Austria (E-Control) Participation in public consultations on approval of mandatory fees to fund ACER’s activities associated with collecting, handling, processing and analysing the information provided by participants of energy markets (or their representatives) pursuant to the requirements of Article 8 of Regulation (EU) No. 1227/2011 of the European Parliament and of the Council of the European Union dated October 25, 2011 on wholesale energy market integrity and transparency (REMIT) Participation in public consultations held by energy market participants (transmission operators, national regulators and other entities) on regulatory initiatives and changes in the energy market regulatory framework, introduction of new rules and regulations of the energy market operation, in particular, information exchange requirements, conditions of cooperation between gas transmission system operators, new rules as to the quality parameters of gas supplied, prescriptive technical standards, technical and commercial conditions for natural gas transportation and storage, regulation and taxation of energy exports and imports, and anti-monopoly regulation Participation in economic and energy forums and gas and energy conferences (the European Gas Conference, the Flame natural gas & LNG conference, World Energy Week, Eurasian Economic Forum in Verona, etc.)
NGOs and educational institutions	Relevant units of PJSC Gazprom Environmental departments of subsidiaries PR departments of subsidiaries Social services and units of subsidiaries	Joint programs and research activities Open public hearings Information disclosure Conferences, on-the-job training and internship programs Cooperation with anchor universities Development of training materials and learning aids	Participation in the Carbon Disclosure Project (CDP), the initiative of the international investor community on disclosure of information on greenhouse gas (GHG) emissions and climate change risks Participation in industry events for young people (young scientists, specialists and students of Russian and foreign universities) Setting up special classes at secondary schools, opening specialized departments at Russian universities Organization of work experience practice for students of secondary vocational education institutions and higher education institutions at subsidiaries Public assurance of the Gazprom Group’s Sustainability Report by the Council on Non-Financial Statements of the RUIE
Media	Department in charge of information and communication policy PR departments of subsidiaries	Information disclosure In-person events and teleconferences Responses to inquiries Development of official websites and other means of communication Implementation of joint projects with the media Meetings of top management with media representatives Holding of events for representatives of the blogger community Implementation of PJSC Gazprom’s own special projects Implementation of projects related to education and cultural education	182 official press releases 6 interviews with the top management of PJSC Gazprom About 1,000 explanations, comments and answers to journalists’ questions 18 online and offline media events 5 tours taking bloggers to PJSC Gazprom’s charity sites 6 special projects with mass media, bloggers and opinion leaders
Consumers	Department in charge of gas and liquid hydrocarbons marketing Relevant units of subsidiaries	Contractual relations Meetings Conferences and forums Claims management system Satisfaction surveys Information disclosure	Marketing incentives to encourage consumers’ equipment and vehicles conversion to natural gas (First Time, First Gas; First Time, First Gas NEW; EcoGas: Cost Saving for You!+; EcoCity; Additional Benefit; Pure Saving; Clean City) About 10,600 vehicles were converted to natural gas under a government subsidies program (and 2,485 of them – with the use of marketing progams) Information support to customers via official websites of the Group’s companies Customer satisfaction monitoring as related to quality of products and services on production, transportation and processing of gas, gas condensate, oil and petroleum products

¹ Established by order of OJSC Gazprom No. 292 dated November 17, 2008.

² Approved by order of PJSC Gazprom No. 124 dated March 25, 2019.

³ In line with the recommendations of the Bank of Russia’s Corporate Governance Code approved by the Bank of Russia’s Board of Directors (Letter No. 06-2/2463 dated April 10, 2014).

⁴ Approved by the conference of employees of OJSC Gazprom and its subsidiaries on November 23, 2012; extended in 2018 for the 2019–2021 period.

Dmitry Filatov

Head of PR and Media Relations Division, PJSC MOEK; in cooperation with his colleagues, has successfully implemented a project for streamlining stakeholder outreach on social media, which made it possible to respond to consumer queries in real time, promptly inform customers about technical failures and the progress of repairs, and communicate with debtors and communities across the Company’s areas of operation.

Stakeholder Engagement Formats

Information Requests from Stakeholders in 2020

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In the reporting year, the requests from stakeholders (including the media and investment community) were received on the following topics:

Topics and concerns raised by stakeholders

Impact of the epidemiological situation on business processes (measures taken by Gazprom to ensure reliable energy supplies to consumers and protect employees amid the pandemic)
Risks of further expansion of sanctions against Gazprom, its subsidiaries and organizations, and specific projects
Risks of increasing tax burden
Composition of the Gazprom Board of Directors
Unfavourable environment in the global oil and gas market and measures taken by the management in response to it
Hydrogen energy development outlook
Strengthening competition in the European gas market, possible reduction of the Gazprom Group’s sales in Europe
The Company’s strategy against the backdrop of the global climate agenda evolution

For more details on the Gazprom Group’s actions taken to combat COVID-19, see Section Response to COVID-19 Pandemic and its Consequences

For more information on expanding gas infrastructure across Russian regions, see Subsection Gas Infrastructure Expansion in Russian Regions

For more information on hydrogen energy, see Section Climate Protection Measures

Public Consultations on the Draft Report

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In the course of the preparation of the 2020 Report, remote public consultations were held to make sure that the information disclosed is relevant for stakeholders. A total of 15 representatives of stakeholders took part in the consultations. In the course of the public consultations, 101 comments were received, including 41 suggestions to include additional information in the Report and 54 follow-up questions on the information provided in the Report. As part of the consultation process, representatives of stakeholders were given explanations on 62 comments, with another 21 comments reflected directly in the Report. 17 comments received will be handled by the Task Force for the Report preparation at its meeting in the following reporting period.

For the table of questions and recommendations from stakeholders based on the public consultations on the Report for 2019, see Appendix