Corporate Ethics

The Code of Corporate Ethics of PJSC Gazprom has been in effect since 2012, in the version approved in 2014 (as subsequently amended), and reflects Russian and international best practices in corporate governance.

The document sets forth PJSC Gazprom’s corporate values and the key rules of business conduct derived from those values regarding the prevention of conflicts of interest and corruption, in particular restrictions on joint work of relatives, employee engagement with PJSC Gazprom’s competitors and their serving on elected government bodies, and gift acceptance.

Key documents governing corporate ethics matters

• Code of Corporate Goverment of PJSC Gazprom;
• Code of Corporate Ethics of PJSC GazpromApproved by resolution of the Board of Directors of PJSC Gazprom No. 2309 dated February 25, 2014.;
• Anti-Corruption Policy of PJSC Gazprom;
• Regulation on Hot Line for Fighting Fraud, Corruption, and Embezzlement at the Gazprom GroupApproved by order of OJSC Gazprom No. 423 dated September 4, 2014.;
• Code of Conduct for Suppliers (Contractors, Service Providers) of PJSC Gazprom and Gazprom Group EntitiesApproved by resolution of PJSC Gazprom No. 300 dated August 9, 2024..

The Code of Corporate Ethics of PJSC Gazprom has been in effect since 2012, in the version approved in 2014 (as subsequently amended), and reflects Russian and international best practices in corporate governance.

The Code is mandatory for all of PJSC Gazprom’s employees. Since 2019, the Code of Ethics also applies to the members of the Board of Directors, with relevant amendments made to the Regulation on the Board of Directors of PJSC GazpromApproved by resolution of the annual General Shareholders Meeting of PJSC Gazprom dated June 30, 2016, minutes No. 1 (as amended).. Every year, the Company’s executives, including members of the Management Committee, make formal written commitments to comply with the Code of Ethics.

Starting from 2021, measures have been taken to maximize the involvement of Gazprom’s counterparties that are not part of the Gazprom Group in its corporate values system, including by integrating a clause requiring them to comply with the Code of Ethics into the contracts.

In 2024, the Code of Conduct for Suppliers (Contractors, Service Providers) of PJSC Gazprom and Gazprom Group EntitiesResolution of PJSC Gazprom No. 300 dated August 9, 2024. was approved. The document enables Gazprom’s corporate values to reach counterparties that are not part of the Gazprom Group.

The Code’s provisions are grounded in the general principles of civil law — the equality of commercial participants, freedom of contract, and the unimpeded exercise of civil rights.

Employees of Gazprom Group entities regularly complete an e-learning course on Corporate Ethics with a final knowledge assessment test. In 2025, 94,664 employees completed the course.

The standing Corporate Ethics Commission of PJSC Gazprom oversees compliance with the requirements and provisions of the Code of Ethics. The commission consists of seven members appointed by PJSC Gazprom’s order.

• Advising employees on the interpretation and implementation of the Code of Ethics;
• reviewing inquiries in a timely manner and based on the applicable laws of the Russian Federation, with assistance from dedicated units, subsidiaries, and entities, if necessary; taking response measures within its remit in case of violations of the Code of Ethics;
• identifying potential conflicts of interest involving sole executive bodies of entities controlled by PJSC Gazprom and providing recommendations on eliminating and mitigating negative implications of identified conflicts of interest;
• arranging for the Company’s executives, including members of PJSC Gazprom’s Board of Directors and Management Committee, to submit formal written commitments to comply with the Code of Ethics on an annual basis.

The Ethics Commission’s performance is reported to the Chairman of the Management Committee of PJSC Gazprom on an annual basis. Information on PJSC Gazprom’s compliance with corporate ethics standards is reported to the Board of Directors on a regular basis (at least once every three years).

PJSC Gazprom employees may contact their immediate supervisor or the Ethics Commission for guidance on the Code of Ethics, to report known violations of ethical standards, or in the event of a conflict of interest. If the immediate supervisor fails to take measures to prevent or eliminate the conflict of interest or the measures taken are insufficient, employees are to inform the Commission thereof.

Employee sanctions for violating the Code of Ethics include:

• public censure;
• denouncement;
• loss of bonuses (in line with the Company’s internal documents);
• disciplinary action (in cases where there is evidence of a disciplinary offence).

Entities controlled by PJSC Gazprom have their own corporate ethics commissions, which review employee inquiries in accordance with their own corporate ethics codes.

The Gazprom Group has corporate mechanisms for identifying, preventing, and resolving conflicts of interest among members of PJSC Gazprom’s governance bodies.

In accordance with Clause 5.5, Article 5 of the Regulation on the Board of Directors of PJSC Gazprom:

• Members of the Board of Directors shall not use their position or information about the Company for their own benefit or allow its use by third parties for their own benefit;
• Members of the Board of Directors shall refrain from actions that will or may lead to a conflict of interest;
• In case of a conflict of interest involving a member of the Board of Directors:
• • The member of the Board of Directors who has a conflict of interest must report it to the Board of Directors by sending a notice to the Chairman of the Board of Directors. The notice must detail the conflict of interest and its grounds.
  • The Chairman of the Board of Directors then sends the notice about the conflict of interest to all members of the Board of Directors prior to deciding on the item in which the member of the Board of Directors has a conflict of interest.
  • The member of the Board of Directors may abstain from voting on the item in which they have a conflict of interest. The Chairman of the Board of Directors may suggest that the member of the Board of Directors having a conflict of interest does not attend the discussion of the relevant item if the nature of the item under discussion or the specific nature of the conflict of interest so require.
• If the member of the Board of Directors who has a conflict of interest abstains from voting or attending the discussion of the relevant agenda item at a meeting of the Board of Directors, this is reflected in the minutes of the meeting of the Board of Directors.

In accordance with Clause 45.1, Article 45 of PJSC Gazprom’s Articles of Association, members of the Board of Directors must notify the Company within two months from the date when they became aware or should have become aware of the circumstances due to which they may be deemed interested in the Company’s transactions:

• of legal entities in which they, their spouses, parents, children, full and half siblings, adoptive parents and adoptees and/or their controlled entities are controlling persons or have the power to issue binding orders;
• of legal entities in the governing bodies of which they, their spouses, parents, children, full and half siblings, adoptive parents and adoptees and/or their controlled persons hold positions;
• of known actual or potential transactions in which they may be deemed interested.

An interested party transaction would not give rise to a conflict of interest if it complies with Chapter XI of the Federal Law On Joint Stock Companies.

In accordance with Articles 5–8 and 10 of the Code of Corporate Ethics, Clause 3.4, Article 3 and Clause 5.6, Article 5 of the Regulation on the Management Committee of PJSC GazpromApproved by resolution of the annual General Shareholders Meeting of PJSC Gazprom dated June 30, 2016, minutes No. 1 (as amended).:

• Members of the Management Committee must not use their position or information about the Company for their own benefit or allow its use by third parties for their own benefit, and must refrain from actions that will or may lead to a conflict of interest.
• Members of PJSC Gazprom’s Management Committee are subject to restrictions of the Code of Corporate Ethics on nepotism, employee engagement with PJSC Gazprom’s competitors, their serving on elected government bodies, acceptance of gifts, etc.
• Members of PJSC Gazprom’s Management Committee may only serve on governing bodies of other organizations with the consent of the Company’s Board of Directors.
• Similar to other PJSC Gazprom employees, in the event of a conflict of interest members of the Management Committee may contact the Ethics Commission.

The Anti-Corruption Policy of PJSC Gazprom reflects the commitment of the Company’s management and employees to the ethical standards of conducting legal, open and honest business, improving the corporate culture, following the best corporate governance practices, and maintaining a good business reputation. This document outlines the goals and competencies of governance bodies in preventing and combating corruption, while also introducing comprehensive anti-corruption measures and liability for non-compliance with policy requirements.

Key principles of the Anti-Corruption Policy

• Compliance with applicable laws
• Leadership by example
• Employee engagement
• Proportionality between anti-corruption procedures and corruption risks
• Efficiency of anti-corruption procedures
• Responsibility and inevitability of punishment
• Business transparency
• Permanent control and regular monitoring

The governance bodies’ members and all employees of Gazprom Group entities must comply with the Policy.

The decrease in processed reports in 2025 compared with the previous year reflects the blocking of mass advertising mailings and spam.

In 2025, Gazprom conducted due diligence checks on counterparties’ reliability, solvency, and financial health. The checks identified potential counterparties unable to meet PJSC Gazprom’s supply, work, or service requirements, as well as companies whose engagement could have created reputational risks or harmed the Company’s economic security. Findings were shared with procurement committee members at PJSC Gazprom and across the Gazprom Group.

Employees of Gazprom Group entities undergo training in anti-corruption programs developed by Gazprom Corporate Institute, the Center for Entrepreneurial Risks, and other institutions.

PJSC Gazprom’s Personal Data Processing PolicyApproved by order of No. 453 dated December 12, 2024. outlines the legal grounds, purposes, and methods of personal data processing, categories and scope of processed personal data, and data subjects’ rights, and details measures to ensure the data operator’s compliance with obligations regarding the processing and protection of personal data in accordance with Russian laws.