Policies

At Siccar Point Energy we hold a central value to make health, safety of all people working in our business and on our assets, and care for the environment, a fundamental principle of our business. We believe that prioritising and delivering on health, safety and environment leads to a healthy business and contributes to improvements in the industry as a whole. Siccar Point Energy believes in leading by example and holding each other accountable and this approach and belief is underpinned by the following guiding principles:

• A culture of care is fundamental to delivering on our promises, and by caring for those we work with and who work on our assets, we can reduce the hazards and consequences that our activities expose them to
• Ensure risks related to health, safety and the environment are adequately identified, controlled or mitigated and that risk-related decision making is done with competence and authority
• We work in a hazardous industry and place particular focus on understanding, controlling and mitigating major accident hazards and their effects
• Reduce and mitigate permitted, unplanned and fugitive emissions and waste in our operations and in our design and construction of new wells and facilities
• Our employees and wider work force working on our assets are expected to communicate successes, risks and failures and undertake safe intervention of tasks not adequately controlled, no matter where or by whom
• Seek continual learning and improvement through the industry and its regulators
• Ensure appropriate levels of competence in our employees and wider workforce and exercise and train for emergency situations
• Communicate, monitor and measure our objectives and expectations to employees and the wider workforce
• Ensure our stakeholders are aware of and actively engaged in our activities that may affect them in respect of health, safety and the environment
• Engage the supply chain to maximises their contribution to the vision of care in a manner that in no way abrogates our own duty and responsibilities in respect of what they deliver for us
• Our employees and others who work on our assets have self-responsibility to take reasonable care of their own health and safety and that of their fellow works and take reasonable action to care for the environment in which they are working, in particular through complying with all applicable work instructions, procedures and permits

This policy forms part of our overall Management System that aligns wider regulatory compliance with our policies, standards and ways of working and are fundamental to achieving good care of the environment in which we work.

Approved by Jonathan Roger,

Chief Executive Officer

15 June, 2020

Introduction

This policy applies to Siccar Point Energy (Holdings) Limited, a company registered in England and Wales, and the entities listed in Appendix 1, collectively referred to as the “group”.

The group was established on 25 June 2014, to build a full cycle, North Sea exploration, development and production business. Following the completion of two material acquisitions the group has now established a high quality portfolio of long life, low unit cost, production, development and exploration assets in the UK Continental Shelf.

This policy has been published in accordance with Schedule 19 of the Finance Act 2016.

Management & Governance

The group pursues a tax policy that is principled, transparent and sustainable in the long term and the group takes its tax compliance responsibilities seriously. We adhere to relevant tax law and our priority is timely and full compliance.

The group’s Senior Accounting Officer is the CFO and sits on the Board of Directors.

Tax Planning

We engage in efficient tax planning that supports our business and reflects commercial and economic activity. We do not engage in artificial or aggressive tax arrangements.

Tax incentives and exemptions are sometimes implemented by the UK government in order to support investment, employment and economic development. Where they exist, we seek to apply them in the manner intended.

We conduct transactions between group companies on an arm’s length basis.

Risk Tolerance

Our tax affairs are in the main prepared and reviewed by our in-house finance team and also external professional advisors. We undertake management reviews at CFO level. Processes relating to different taxes are reviewed regularly. We monitor for business and legislative changes which may impact processes and procedures and where there is uncertainty or complexity further advice is sought from external professional advisors where appropriate.

Ultimate responsibility for tax policy, strategy and governance rests with the Board of Directors, with the CFO responsible for implementation.

Engagement with HMRC

The group and our external professional advisors seek to build and maintain relationships with the UK fiscal authority that are honest, constructive and based on mutual respect. We work collaboratively wherever possible to resolve disputes and to achieve early agreement and certainty.

Our activities are subject to several different taxes including:

• Corporation Tax
• Employment Taxes
• VAT
• Customs Duties
• Insurance Premium Tax

This tax policy is approved and owned by the Board of Directors and overseen by the CFO.

Appendix 1

List of entities:

Siccar Point Energy (Holdings) Limited

Siccar Point Energy Finance Limited

Siccar Point Energy Limited

Siccar Point Energy U.K. Limited

Siccar Point Energy E&P Limited

Siccar Point Energy Bonds plc

The Siccar Point Energy Group has a zero tolerance approach to modern slavery and is committed to ensuring that there is no modern slavery or human trafficking in any part of its business, including its supply chain. The Group complies with all requirements of the Modern Slavery Act 2015.

Siccar Point Energy has the following measures in place to reduce the risk of modern slavery affecting its business and supply chain:

Policies and Procedures

Siccar Point Energy has policies on critical supply chain guidance, anti-bribery and corruption and whistle-blowing which focus on maintaining positive relationships with all counterparties, including business partners, suppliers and the wider communities in which we work.

The policies promote working within the laws and regulations of the countries in which we operate (including, by implication, those relating to forced/involuntary labour and human trafficking), promoting high ethical standards and a culture whereby people are empowered to report issues of concern. Business integrity is a key standard for selection of partners, contractors and other organisations with which the Siccar Point Energy Group works. This policy is communicated to all employees and compliance with its requirements is a condition of employment with the Group.

The Group is committed to providing safe and healthy working conditions for its personnel. Our template contractual terms require the highest standards of business ethics, compliance with applicable laws and commitment to health, safety and the protection of the environment. Siccar Point Energy conducts its business as a responsible corporate citizen.

Supply Chain

Our suppliers are local, national and international. We look to procure products and services from high quality and high integrity suppliers. We achieve this through a robust selection process and ongoing management of suppliers who fully comply with our safety, environment, technical standard and ethical standards.

Contractual Terms

Siccar Point Energy’s template contractual terms for suppliers require the highest standards of business ethics, compliance with all applicable laws and commitment to health, safety and the protection of the environment and personnel.

Reporting Concerns

By encouraging a culture of openness within our organisation Siccar Point Energy aims to prevent malpractice. We encourage all employees to raise issues which concern them at work through the Whistleblower Policy details of which are available on the Siccar Point Energy intranet.

Risk Assessment

Siccar Point Energy has undertaken an internal risk assessment to identify and assess potential risks in our supply chain relating to modern slavery and human trafficking. The Siccar Point Energy Group does not operate in jurisdictions or in a sector which has particular risks associated with slavery and human trafficking but, to the extent risks have been identified, appropriate steps have been taken to mitigate and monitor such risks as outlined above.

Siccar Point Energy is committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business, and that the same high standards are applied by our business partners. The Siccar Point Energy Group has a robust set of guidelines and policies in place that inform our work, and ensure that we are considering the impact of our corporate behaviour as appropriate.

At the time of writing, Siccar Point Energy is not aware of any current or recent incidents, nor accusations of forced/involuntary labour or human trafficking in our operations or those of our business partners.

This statement was reviewed and approved by the board of Siccar Point Energy E&P Limited, as our primary operating company, but also applies to all other companies within the Siccar Point Energy Group: Siccar Point Energy (Holdings) Limited, Siccar Point Energy (Finance) Limited), Siccar Point Energy U.K. Limited, Siccar Point Energy Limited and Siccar Point Energy Bonds plc.

Approved by Jonathan Roger,

Chief Executive Officer

22 Mar, 2019

It is our policy to conduct all of our business in an honest and ethical manner. The Employer takes 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.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated with immediate effect.

This policy does not form part of any employee’s contract of employment and the Employer may amend it at any time. It will be reviewed regularly.

Who must comply with this policy?

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

What is bribery?

Bribe means a financial or other induce mentor reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, facilitation payments, the award of a contract or any other advantage or benefit.

Bribery includes offering, promising, giving, accepting or seeking a bribe.

All forms of bribery are strictly prohibited. If the individual is unsure about whether a particular act constitutes bribery, they must raise it with their Line Manager or the General Counsel.

Specifically, the individual must not:

• give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
• accept any offer from a third party that the individual knows or suspects is made with the expectation that it will provide a business advantage for them or anyone else; or
• give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure.

The individual must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

Gifts and Hospitality

This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.

A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process). Travel and accommodation costs should be met by the Company.

Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in the Employer’s name, not the individuals name.

Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.

All gifts and hospitality given or received (other than hospitality with a value of less than £50 per head e.g. business lunches and dinners) should be reported to the Office Coordinator who will maintain a register of gifts and hospitality. All gifts received (other than promotional branded gifts) should be handed to the Office Coordinator who will periodically arrange for them to be raffled in aid of a charity selected by the Company.

Record-keeping

The individual must declare and keep a written record of all hospitality or gifts given or received by emailing the Office Coordinator, stating what has been received, from whom it has been received and the perceived value of the hospitality or gift. The individual must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with the Employer’s expenses policy and record the reason for expenditure.

All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

In addition, the individual may be asked from time to time to confirm by email that they have complied with this Policy.

How to raise a concern

If an individual is offered a bribe, or is asked to make one, or if they suspect that any bribery, corruption or other breach of this policy has occurred or may occur, the individual must notify their Line Manager or the General Counsel or report it in accordance with the Whistle blowing Policy as soon as possible.

Changes to this Procedure

Any changes to this procedure will be notified to employees by way of intranet announcements or otherwise in writing. It is their duty to familiarise their selves with and implement any such changes.

Approved by Jonathan Roger,

Chief Executive Officer

1 May, 2017

Purpose

The Employer believes that the pursuit of equal opportunity for all in the workplace is based on sound moral and business grounds. The Employer is committed to employing the best people and creating an atmosphere in which people can achieve their potential. One way of achieving this is to treat all employees or potential employees fairly.

Compliance with this policy should assist the Employer to put this commitment into practice, and also ensure that employees do not commit unlawful acts of discrimination.

The Employer operates a policy of providing equal opportunities in recruitment, training and promotion whatever the colour, race, religion or belief, ethnic or national origin, sex, sexual orientation, gender, marital status, age or disability of an employee, having regard to the individual’s aptitudes and abilities and the requirements of the job. The Employer is opposed to all forms of unlawful and unfair discrimination in employment and against customers/ contacts/suppliers.

The Employer is committed to the promotion of equal opportunities and to ensure that the human resources, talent and skills of all employees are maximised. The Employer’s policy is to treat all employees with respect and dignity and to ensure that decisions are taken without reference to irrelevant or discriminatory criteria.

The Employer will take every possible step to ensure that decisions on recruitment, selection, training, conditions of work, pay and benefits, promotion, career, management and every other aspect of employment are justifiable and based solely on objective criteria.

There may be circumstances where the Employer has a legal duty to ensure that a job holder is of a specified gender or where health and safety requirements apply. In these instances, the Employer will follow the provisions in the legislation.

The Employer will ensure that the policy is communicated to all employees and made known to job applicants.

This policy does not form part of the contract of employment and the Employer may amend it at any time.

Making the policy work

The Board of Directors has overall responsibility for the effective operation of the Employer’s Equal Opportunities policy and for ensuring compliance with the anti-discrimination laws.

Managers and supervisors have particular responsibility for the practical application of this policy and for ensuring a harmonious working environment. They should endeavour to address and eliminate any situation involving bullying, harassment or any other forms of discrimination (with support from Human Resources). The Employer undertakes to provide the necessary support and training which will include awareness of discrimination legislation and its impact on decisions they make.

Each employee has personal responsibility for the practical application of this policy and to ensure that the Employer achieves its equality objectives. The successful implementation of this policy depends on everyone treating each other with the respect and dignity they would rightly expect from others.

What the Law says

The Employer recognises its obligations under the Equality Act 2010. The Employer is committed to ensuring that no individual is discriminated against on the grounds of sex, sexual orientation, marriage and civil partnership, pregnancy and maternity, age, gender reassignment, race, disability, sexual orientation or religion or belief. These are known as “protected characteristics”.

What is discrimination?

Discrimination can be direct or indirect and it can occur intentionally or unintentionally.

Direct discrimination: occurs where the individual is treated less favourably than others because of a protected characteristic. For example, paying someone less because of their sex or rejecting an application for employment because someone is disabled. Direct discrimination can occur even where it is unintentional.

Association and Perception: direct discrimination can also occur if a person is discriminated against because of the protected characteristic of another person, for example an employee with a disabled child being subject to unpleasant comments about disabled people. Or discrimination can arise where the person doesn’t actually have the protected characteristic, but they are perceived as having it, and they are discriminated for that. For example, a job application of a white woman is rejected because the employer wrongly assumes she is Asian because she has an Asian name.

Indirect Discrimination: recognises that some practices which appear to treat people equally can nevertheless adversely affect a particular group (with a protected characteristic) more than others. Where this is the case, the practice will be unlawful unless it can be objectively justified. For example, scheduling all training sessions for a Saturday morning, although applied to everyone, may adversely affect employees of a particular religion.

Discrimination also includes victimisation and harassment.

Victimisation: occurs where an individual is treated less favourably than others because they have made or supported a complaint or raised a grievance under the Equality Act 2010, or because they are thought to have done so. For example, a female employee who had brought an equal pay claim being overlooked for a promotion because she had brought the claim.

Harassment: is unwanted conduct which has the effect or purpose of creating an intimidating, hostile, degrading, humiliating or offensive environment for someone or violating their dignity, which relates to a person’s protected characteristic. More information on this is included in the Employer’s Anti-Harassment and Bullying Policy.

Disability issues

The Employer is committed to ensuring that disabled people, including job applicants and employees, are not treated less favourably or disadvantaged by comparison to people who are not disabled in relation to their work or working environment.

If the employee is disabled, or becomes disabled in the course of their employment with the Employer, the employee is encouraged to tell the Employer about their condition. This will enable the Employer to support the employee as much as possible, and to make reasonable adjustments where appropriate.

The employee may also wish to inform their line manager of any reasonable adjustment to their working conditions or duties of their job which they consider to be necessary, or which would assist the employee in the performance of their duties. The Employer will consider such proposals carefully and will accommodate these, where possible and proportionate to the needs of the employee’s job.

Recruitment and selection

The Employer’s recruitment process will result in the selection of the most suitable person for the job in respect of experience and qualifications. The Employer will ensure that individuals are recruited and selected on objective criteria having regard to their relevant aptitudes, potential, skills and abilities. In particular, no applicant will be placed at a disadvantage by requirements or conditions which are not necessary to the performance of the job or which constitute discrimination.

Implementing equality and diversity

The Employer states its wholehearted support for the principles and practices of equal opportunities and will actively promote equal opportunities throughout the Employer’s organisation. In support of equality and diversity in the workplace, the following activities regularly take place within the Employer:

• the provision of opportunity between women and men will be monitored through the collection and analysis of statistical data on the sex, marital status and family status of all full time and part time employees and job applicants;
• the Employer will provide suitable and relevant equal opportunity training as necessary for all staff, including line supervisors and managers to enable staff to implement and uphold the Employer’s commitment to equality of opportunity;
• the Employer provides standard benefit packages for each grade of staff, regardless of protected characteristics. Remuneration is determined by reference to grade, position and performance;
• the Employer has developed a range of policies designed to help parents combine work and family life. Within these policies, the following elements are covered:
  • Maternity
  • Paternity
  • Shared Parental Leave
  • Parental Leave

Harassment / dignity at work

The Employer recognises the problems that sexual, racial and other forms of harassment may cause at work and is committed to ensure that such unacceptable behaviour does not take place. All forms of harassment are abhorrent and will not be tolerated by the Employer.

The Employer has a separate policy on Anti-Harassment and Bullying.

Grievance and disciplinary procedures

The Employer can only act to prevent individuals from breaking the Employer’s policy if it knows about the conduct. If the employee believes they have experienced discrimination, harassment or victimisation in any form the employee can raise the matter informally with their manager or with a member of HR. The employee can also raise the matter formally through the Employer’s Grievance Procedure or the complaint’s procedure in the Employer’s Anti- Harassment and Bullying Policy. All complaints will be dealt with seriously, properly and confidentially and every effort will be made to secure a satisfactory resolution.

Approved by Jonathan Roger,

Chief Executive Officer

1 May, 2017