APPROVED
Resolution of the Board of Directors of
of Achim Development LLC
Minutes No. 07/2023 dated May 05, 2023
Effect by
Order of Achim Development LLC
No. 234 dated July 05, 2023

ENVIRONMENTAL POLICY
of Achim Development LLC

1. GENERAL PROVISIONS

Achim Development LLC (hereinafter, the “Company”) is a joint venture of PJSC Gazprom, Wintershall Dea AG, and Gazprom Capital, LLC, engaged in the implementation of projects for the development of sites 4A and 5A of the Achimov deposits of the Urengoy oil, gas, and condensate field, production, preparation for transport and transportation of natural gas and unstable gas condensate via field pipelines and branch pipelines.

Taking into account the geographical location of the Company’s gas condensate fields and the inevitable impact of the ongoing production processes on the nature of the Far North, rational use of natural and energy resources, and compliance with the environmental protection obligations assumed is a priority in the Company’s activities.

2. STRATEGIC OBJECTIVE

The Company realizes the importance of taking into account the needs of future generations and sets achievement of sustainable development as a strategic goal, which is a balanced and socially acceptable combination of economic growth and preservation of a favorable environment.

To achieve the strategic goal, the Company has introduced, is maintaining and constantly improving the environmental management system as part of the overall management system, in accordance with the requirements of GOST R ISO 14001 (ISO 14001) as well as the requirements and provisions of the Russian and international standards aimed at improving environmental activities.

3. LIABILITIES

Within the framework of the environmental management system, the Company assumes the following obligations to be fulfilled and will demand their fulfillment by its partners, contractors, and counterparties:

3.1. Comply with the adopted obligations in the field of environmental protection and energy saving, based on an analysis of the needs and expectations of stakeholders.

3.2. Ensure reduction of negative impact on the environment, including:

Take measures to reduce greenhouse gas emissions, preserve climate and biodiversity:

Ensure energy efficiency of the production processes and equipment; 

Carry out activities aimed at compensation for damage to the components of the environment.

3.3. Provide for minimization of risks of negative impact on the environment at all stages of the implementation of investment projects.

3.4. Respect the interests and rights of indigenous minorities of the Extreme North to maintain their traditional way of life and preserve their original habitat.

3.5. Ensure the maintenance and continuous improvement of the processes and mechanisms of the environmental management system to improve its key indicators of environmental performance.

3.6. Ensure the involvement of the Company employees in the activities in response to key environmental risks, improvement of key environmental performance indicators, and management mechanisms.

3.7. Support and improve the competence of the Company employees in the field of environmental protection:

3.8. Provide the required resources for the implementation of this Environmental Policy of Achim Development LLC (hereinafter, the “Policy”).

3.9. Ensure that this Policy is communicated to the Company employees.

3.10. Ensure that the Company employees and other stakeholders can access this Policy.

3.11. Revise this Policy in case of changes in the conditions, activities, and priorities of the Company.