Protection of the health and safety of our employees, all those affected by our business and the protection of the environment, are critical to the overall success of our company and command equal prominence with other business considerations in the decision-making process.

Caithness Petroleum has defining policies that have been developed from the best practices of other leaders in the field. The Company expects that its suppliers and partners share the same values and objectives.

It is the Company’s objective to comply with all applicable legal and other requirements. This Policy is available to the public on request from the Company’s Head Office.

Safety Policy
The Company’s philosophy and policy on safety is that:

• All injuries and occupational illnesses are preventable,
• All operating exposures can be controlled,
• Working safely is a condition of employment,
• Employees must receive safety training,
• Safety performance must be audited,
• All deficiencies must be corrected promptly,
• People are the most important element in an effective safety, health and environmental programme,
• Off-the-job safety is an important part of the safety effort,
• And finally, safety is good business.

Health Policy
The Company’s occupational health programme shall protect employees from health hazards that may be associated with the Company’s work and the working environment. The Company shall be active in health promotion, aiming at preventing health risks associated with the general living environment and life style. The Company’s policy on health is to ensure:

• A good working environment for every employee,
• Clear personnel policy in relation to health,
• The avoidance of any illnesses which can be related to the work performed.

As an operator, the Company will verify that all contractor personnel have adequate health organisations supporting their activity.

HSE performance will be routinely monitored and reported regularly to the Board of Directors of the Company, who will ensure that the necessary resources are provided to support this policy fully.

Minimising the environmental impact of our activities is fundamental to Caithness and the communities where we operate. We will achieve this by:

• Continually assessing our activity to minimise the environmental impact,
• Operating in a safe manner whilst maintaining a pollution contingency plan,
• Foster open communication on our environmental performance, and
• Complying with all the applicable international standards and local laws and regulations where we operate.

Best Practice in Exploration

We demand commitment to quality and safety in every aspect of our business. We have stringent, robust operational standards, which are transparent and promoted throughout the company. All our staff and all our subcontractors are made aware of these standards and are required to conform to them if they are to work with our company.

Onshore

For all onshore exploration, we first conduct an environmental impact assessment, consulting the appropriate specialists and stakeholders to identify existing environmental sensitivities, review any possible impacts of our exploration and take decisions based upon minimising this impact.

For example, in preparation for our drilling programme based in Caithness, Scotland, we consulted with Scottish Natural Heritage, the Royal Society for the Protection of Birds, and the Highland Council to ensure that our plans did not impact any sites of scientific, environmental or archaeological interest. We also completed a noise survey and designed our site to ensure that our operations would create minimum disturbance for the local community.

Offshore

We apply the same rigorous standards as we do for our onshore activities. We work with relevant local and national Governments to ensure that we follow agreed Health and Safety standards, wherever we operate.

Our Health Safety and Environmental Management System has been fully certified by Lloyds of London. We believe rigorous testing and preparation, in addition to sensitive implementation, leads to an outstanding safety record.

Some examples of work we have undertaken in this respect include:

• Environmental studies to ensure the acoustic effects of seismic acquisition on marine life is minimal in the areas of the North Sea where we operated;
• Engagement with the local fishing community to minimise or offset any potential loss of earnings resulting from our offshore operations;
• Use of marine mammal observers and passive acoustic monitoring systems during offshore operations to minimise our impact on local marine wildlife.

Our People

We aim to attract, retain, train and develop our people to be the best in the industry. Whether they are colleagues or contractors, we ask them to share in Caithness Petroleum’s corporate responsibility values.

As a local employer across national borders, we seek to use local talent, local suppliers and support the local economies in which we operate.

Conduct

We promote harmonious working relationships with the local communities in which we operate. We only operate in stable and transparent economic environments to minimise risk to our stakeholders.

Caithness has a dedicated Anti Bribery and Corruption Policy in place which demands the highest standard of behaviour and conduct of its directors, officers and employees, together with all contractors and suppliers. It is our policy to conduct all our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to prevent any bribery and corruption.

Caithness’s policy is to conduct business in an honest way, and to prevent the use of corrupt practices including tax evasion.

Caithness is committed to maintaining the highest standard of corporate governance, to pursue growth for the benefit of its shareholders, employees and other stakeholders. The Company will comply with the laws and regulations of the countries in which it operates and will conduct all its activities with honesty, fairness and integrity. Business integrity is a key standard for selection of partners, contractors and other organisations with whom the Company works.

Caithness is an equal opportunities employer and will recruit, employ and develop employees in line with best practice and based on the qualifications, experience and skills required for the work.

Caithness Petroleum’s Diversity Policy has the following principal objectives:

• To build a diverse and inclusive workforce by attracting, developing and retaining high performing individuals regardless of personal characteristics;
• Commit to incorporating diversity and inclusion in the Company’s work practices and culture; and
• Ensuring that employees are treated fairly and equally, enabling them to reach their full potential.

Caithness is fully committed to upholding its responsibilities towards its staff, contractors and third parties who may be impacted by its activities, and to adhere to all applicable local legislation as well as the principles for business and human rights embodied in international initiatives, such as the United Nations Guiding Principles on Business and Human Rights. Adhering to and implementing this policy is a requirement of anyone who works for or on behalf of the Company.

Caithness is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains, consistent with the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers and other business partners.

Caithness operates a Whistle-Blowing Policy and has a culture of openness so that we can identify and eliminate any malpractice. The Company encourages all employees and contractors to report any situation where they have reasonable belief that there has been a breach, or potential breach, of the Company’s policies or standards.