10 The 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. ANTI-CORRUPTION All Kosmos employees, board members, and key contractors are required to attend yearly anti- corruption training, and certify that they have read, understood, and will comply with our Anti- Corruption Compliance Policy. To further ensure comprehension, all employees are required to pass a test on the substance 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 all 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, without risk of retaliation, potential violations of any Kosmos policy. TRANSPARENCY Kosmos continues to be an industry leader in promoting transparency by disclosing the terms of our petroleum agreements and reporting payments made to our host governments around the world. We are a Supporting Company of the Extractives Industries Transparency Initiative (EITI). Kosmos is a member of the EITI steering committees in Ghana and Mauritania, and plays an active role in the EITI process in São Tomé and Príncipe, Senegal, and Suriname. We advocate for the adoption of EITI by our host governments. 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 is proud to be the first U.S. oil and gas company to disclose project-level payments to governments despite not being legally obligated to do so. 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. “At Kosmos, we work every day to ensure that our business partners, whether vendors, service companies, or other energy companies, are aligned with our culture of ethical business practices. Nothing is more important than knowing that our business partners share our commitment to corruption-free, fair, safe, and legal transactions.” ALISSA EASON Vice-President, Legal and Contracts ETHICAL CONDUCT 2 BUSINESS PRINCIPLE