T he Business Principles are supported by robust compliance policies and methodology, including our Anti- Corruption Compliance Policy and Procedures, which align with the U.S. Foreign Corrupt Practices Act (FCPA) of 1977, the U.K. Bribery Act of 2010, as well as best practices in anti-corruption compliance. Kosmos regularly evaluates its anti-corruption measures and performance. All Kosmos employees and key contractors are required to attend anti-corruption training, and certify annually that they have read, understood, and complied with our Anti-Corruption Compliance Policy. To further ensure comprehension, employees are given a test to verify their understanding of the policy. We exercise care in the selection of vendors, suppliers, and contractors, and we impose the same high standards of conduct that we observe in our own company. We use a risk-based process to evaluate third parties who will work on our behalf. We conduct background due diligence when appropriate to make sure we have obtained full disclosure. In addition to providing third parties with copies of our Business Principles and Anti-Corruption Compliance Policy, we routinely conduct in- country training for key contractors and suppliers on compliance and supplement in-person training with online training modules. Kosmos conducts an annual internal audit of the company’s compliance with its business ethics policies and periodically conducts audits on third parties. We maintain and respond to a Whistleblower Hotline as a vehicle for employees, third parties and others to report anonymously, without risk of retaliation, potential violations of any Kosmos policy. As part of its commitment to transparency, Kosmos aspires to go beyond a box-checking exercise by making information publicly available and increasing our engagement with stakeholders at every level to ensure they have the depth of knowledge needed to hold governments and industry accountable for managing oil and gas revenues appropriately. In 2014, we made a policy decision to disclose payments to governments at the project level, as laid out in the European Union Accounting Directive, which is designed to improve corporate accounting practices and transparency. We believe this type of disclosure is beneficial to investors, civil society, and local communities, and reflects evolving international expectations. Kosmos was the first U.S. oil and gas company to disclose project- level payments to governments despite not being legally obligated to do so at the time. Following our secondary listing on the London Stock Exchange in 2017, Kosmos is now required to report under U.K. regulations. We believe our approach to transparency helps us better manage social and political issues, establishing Kosmos as a partner of choice and mitigating barriers to growth. 10 11 Kosmos aspires to be a leader in transparency and anticorruption. We have set a high standard for transparent behavior by disclosing the terms of our petroleum agreements and reporting payments made to our host governments – including specific entities – at the project level and in aggregate. We are open about our business dealings with host governments because transparency builds trust and accountability. All of our petroleum agreements with host governments are available on our website at www.kosmosenergy.com. The “Performance Data” on page 65 of this report lists the payments we made to governments in 2018. Kosmos has met with stakeholders around the world who want to better understand how the oil and gas industry works. To that end, we have organized and facilitated workshops in nearly every country where we operate to deepen the knowledge of various government agencies, parliamentarians, civil society organizations, and media outlets working to promote good governance and transparency in the oil and gas sector. We strongly support the work of the Extractive Industries Transparency Initiative (EITI), a leading global standard that strengthens governance by promoting transparency and accountability in the oil, gas, and mining sectors. The EITI requires participating governments to establish a multi-stakeholder steering group comprised of representatives of governments, business, and civil society to oversee a process in which companies declare material payments to government, and the government declares all material receipts from extractive companies. These figures are reconciled, and any discrepancies are identified and investigated by an independent expert. We have been a Supporting Company of the EITI since 2012. Kosmos has operations in six countries that have implemented or are in the process of implementing the EITI: Côte d’Ivoire, Ghana, Mauritania, São Tomé and Príncipe, Senegal, and Suriname. In these countries, we engage with the EITI through feedback and dialogue in the multi-stakeholder groups. Kosmos is a member of the EITI steering committee in Ghana, Mauritania, Suriname, and as of 2018, in São Tomé and Príncipe as well. We play an active role in the EITI process in other countries. We advocate for the adoption of EITI by our host governments. When we operate in countries that are not yet members of the EITI, we actively promote the EITI and the transparent management of any revenues from natural resources. 2 BUSINESS PRINCIPLE A Kosmos employee leads a capacity building workshop for Senegalese stakeholders on the oil and gas value chain in partnership with the Natural Resource Governance Institute (NRGI). TRANSPARENCY AND DISCLOSURES IN AN EVOLVING REGULATORY ENVIRONMENT KOSMOS WAS THE FIRST U.S. OIL AND GAS COMPANY TO DISCLOSE PROJECT- LEVEL PAYMENTS TO GOVERNMENTS DESPITE NOT BEING LEGALLY OBLIGATED TO DO SO. BUSINESS PRINCIPLE IN ACTION: Ethical Conduct