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Rosneft Oil Ojsc

rosn · LSE Industrials
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Industry Industrial - Machinery
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FY2022 Annual Report · Rosneft Oil Ojsc
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Rosneft is the leader 
of the Russian oil 
industry.

We strive to be first 
in all aspects of our 
activities. We are planning 
the future of the Company 
by leveraging the latest 
technology and preventing 
adverse effects on society 
and the environment.

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

ABOUT THE 
COMPANY

01

2 
4 
6 
8 
9 
12 
14 
16 
25 

  Message from the CEO and Chairman of the Management Board

Rosneft operations
Rosneft-2030 Strategy
Long-Term Development Programme and progress report
KPI structure
Investment programme

  Operating and financial results
  Health, safety and environment
  Carbon management

CORPORATE 
GOVERNANCE

02

26 
32 
37 
38 
40 
52 
56 

  Corporate governance
  General Shareholders Meeting

Anti-corruption efforts
Audit Commission
Risk Management and Internal Control System
Shareholder relations,key events in 2022

  Dividend Policy

APPENDICES

03

1

 
 
 
 
 
 
 
 
 
Message from 
the CEO and Chairman 
of the Management Board

Igor SECHIN
Chief Executive Officer and Chairman of the Management Board

Dear shareholders,

The Company’s preparedness 
to respond to any challenges 
was another advantage that enabled 
us to ramp up hydrocarbon production 
despite all the headwinds. Sakhalin-1 
is a great example of this approach. 
When the previous operator 
left the project, it took us close 
to no time to recover production, 
resume tanker shipments, restart 
the drilling programme and thus 
save over 3.000 jobs for highly 
skilled professionals. Thanks 
to a coordinated response and precise 
management decisions, in the fourth 
quarter of 2022, the Company 
increased average daily hydrocarbon 
production at Sakhalin-1 to a record 
high of 5.50 mmboe.

In 2022, Rosneft clearly demonstrated 
that its industry leadership 
is underpinned by commitment 
to the Company’s own strategic 
vision and a steadfast management 
approach. The robust business model 
and well-informed corporate policy 
made the Company impervious 
to negative external factors 
and market fluctuations, while also 
making it possible to independently 

define operating priorities 
and achieve goals. Our strong 
operating and financial performance 
is a tangible proof of this affirmation.

In 2022, the Company’s hydrocarbon 
production increased by 2.3% 
to 5.10 mmboe per day, mainly due 
to the success of our gas programme. 
As a result, gas production rose by 15% 
to reach the historic high of 74.4 bcm.

The use of in-house innovations 
and the reliance on a comprehensive 
exploration approach helped 
maintain the high quality 
of geological exploration and enabled 
the Company to discover seven 
new fields and 153 hydrocarbon 
deposits in 2022. The largest 
of them – the Madachagskoye 
field on the Pechora Sea shelf 
with 82.3 mmt in recoverable 

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

AB1C1+B2C2 oil reserves – also 
proved to be Russia’s largest 
discovery of the year.

The Russian market has always 
been the Company’s No. 1 priority 
in terms of petroleum product 
supplies. In this context, the fact that 
Rosneft set a new record by growing 
domestic sales of petroleum products 
to 42.1 mmt in 2022 is of particular 
significance to us.

In the international market, Rosneft 
continued to stick to the multi-vector 
development model and promoted 
mutually beneficial cooperation 
with all stakeholders. Thanks 
to the strategic pivot to the East 
in the late 2010s, the Company 
significantly increased energy 
supplies to the Asia-Pacific Region 
last year. The key driver behind 
this success was the integrated 
model to build partnerships across 
the supply chain – from production 
and oilfield services to processing 
and fuel sales to end consumers.

In this context, let me highlight 
a number of 2022 milestones. 
In February, Rosneft entered 
into a new ten-year contract 
with China National Petroleum 
Corporation (CNPC) to supply 
additional 100 mmt of crude oil 
to China. The companies also signed 
an agreement envisaging cooperation 
in various areas of the promising 
low-carbon energy sector. One 
of the new tools to amplify 
the dialogue with international 
partners was transition to settlements 
in roubles and the national currencies 
of friendly countries. In September, 
the Company successfully completed 
the offering of its debut CNY-
denominated bonds. This offering 
became the largest corporate issue 
in the Russian market with a record 

low coupon rate. In addition 
to that, Rosneft launched supplies 
of proprietary catalysts to a number 
of Asian countries. The Company 
is not planning to stop at that, 
with work underway to further 
diversify sales channels and regions.

Improvements in operating 
efficiency in 2022 came as a result 
of implementing the most 
preferable technical solutions 
and best domestic technologies 
in all areas of the Company’s 
operation. The use of best available 
equipment and techniques is fully 
in line with Rosneft’s strategic 
goals in the areas of carbon 
management, promoting sustainability 
and preserving the environment 
for future generations.

In addition to the consistent efforts 
to implement circular economy, 
restore natural resources and protect 
ecosystems, the Company comes 
up with initiatives designed to set 
new green trends. In 2022, Rosneft 
launched an ambitious forest 
and carbon management project 
with a potential absorption capacity 
of 10 mmt of CO2-equiv. Also, 
over the past three years alone, 
the Group Subsidiaries have planted 
more than 18 million seedlings 
and young trees. 

Rosneft’s strong financial 
performance was driven 
by the combination of a large-scale 
investment programme and tight 
expense management. In 2022, 
the Company’s capital investments 
grew to exceed RUB 1.1 trln. While 
the global oil and gas sector faces 
massive underfunding, Rosneft 
continues to deliver on its flagship 
Vostok Oil megaproject, which I 
believe will fundamentally transform 
the energy market and have 

a stabilising effect throughout 
the world. Apart from that, 
the Company managed to keep 
the growth of unit production costs 
below the producer price inflation 
levels.

As a result, Rosneft’s revenue 
and EBITDA in 2022 increased 
by 3.2% and 9.5% respectively, 
whereas its debt and trade liabilities 
went down by RUB 0.7 trln. 
In 2022, the net income of Rosneft 
attributable to shareholders 
amounted to RUB 813 bln.

For many years now, the Company’s 
attractive dividend policy has been 
one of its key draws. According 
to the policy, dividends are paid 
to shareholders twice a year 
and make up at least 50% of net 
income. In 2022, Rosneft paid annual 
dividends for 2021 in the amount 
of RUB 250 bln and approved 
the payment of interim dividends 
in the amount of RUB 216 bln. 
The net profit achieved in 2022 
is a reliable foundation for us 
to pay full-year dividends 
and honour all our commitments 
to the shareholders.

I am convinced that in 2023, we 
will maintain strong performance 
across the board, keep the Company 
going despite external pressure, 
and strengthen our fundamental 
role in the market as the leader 
of the energy industry.

2

3

Rosneft 
operations

Rosneft is Russia’s leading 
petroleum company in terms 
of launching new projects.

Rosneft is the largest 
refiner in Russia.

Production assets

Refining and processing assets

AVERAGE HYDROCARBON PRODUCTION 
GROWTH IN 2012–2022, %

6.6

2.3

a
n

i

h
C
o
r
t
e
P

1.4

0.3

n
o
r
v
e
h
C

s
a
r
b
o
r
t
e
P

-1.3

-1.3

l
i

b
o
M
n
o
x
x
E

-3.1

P
B

l
l

e
h
S

Source: company reports

4

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

HYDROCARBONS PRODUCTION IN 2022, MMBOE PER DAY

5.1

4.6

3.7

l
i

b
o
M
n
o
x
x
E

a
n

i

h
c
o
r
t
e
P

Liquid hydrocarbons

Gas

Source: company reports for 2022

2.9

2.9

2.7

2.4

n
o
r
v
e
h
C

l
l

e
h
S

s
a
r
b
o
r
t
e
P

P
B

5

Rosneft-2030  
Strategy

Reliable energy and global 
energy transition strategy

Higher
efficiency

Operational 
leadership

Lower 
carbon footprint

Strategic objectives 
and priorities

Achievements in 2022

Increasing production to 330 mmtoe

2,3% growth in hydrocarbon production

Increasing gas share in total 
output to 25% 

15% growth in natural gas production vs 2021 

Higher dividends and returns 

9.5% EBITDA increase

Retaining leadership in terms of unit 
production costs 

Efficient cost control1

Pursuing biodiversity 
conservation (net positive impact)

Overall approaches developed to preserve 
biodiversity across the Company’s footprint 

100% waste disposal 
and remediation of legacy lands

16% reduction in the area  
of legacy lands

1.  Growth of unit production costs below the producer price inflation levels

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

ON THE PATH TOWARDS  
CARBON NEUTRALITY

2022

11%  reduction in absolute GHG emissions vs 20201 

2.8 mmt of СО2-equiv. 
reduction in emissions 
as part of green power 
purchases

0.9 mmt of СО2-equiv.  
reduction in emissions 
as part of the Energy Saving 
Programme

STRATEGIC TARGETS

2025

5% reduction in absolute
GHG emissions

2030

<0.2% methane emissions 
intensity 

0 routine flaring
of associated petroleum gas

<20 kg of СО2-equiv. 
per boe 
GHG emissions 
in Upstream

2035

> 25% reduction in absolute
GHG emissions vs 20201 

2050

Carbon neutrality

GHG reduction targets are set against the base year of 2020.
GHG reduction and carbon neutrality targets cover 100% of Scope 1 and 2 emissions 
in the Company’s reporting perimeter.

6

1 The Strategy’s base year.

7

Long-Term Development 
Programme 
and progress report

For the Programme’s key outcomes 
in 2022, see the 
and Financial Results section.

 Operating 

TSATR – Audit Services LLC, 
an independent auditor, completed its 
engagement and provided assurance 
about Rosneft’s Programme Progress 
Report and achievement of the key 
performance indicators in 2022. 
The opinion was received on 28 April 
2023.

Originally developed in 20141, 
the Long-Term Development 
Programme (the Programme) 
is subject to annual updates2.

In 2022, we revised the Programme, 
taking into account the Company’s 
performance, action plans 
to achieve certain strategic goals, 
and updated initiatives drafted 
pursuant to the Russian Government’s 
directives3. The updated Programme 
was approved by the Company’s 
Board of Directors (Minutes No. 13 
dated 27 December 2022).

The Programme details 
the Company’s strategic focus areas, 
targets and goals for all business 
areas and corporate functions. It 
also includes a list of key initiatives 
to achieve the Company’s strategic 
goals.

The main priorities, key performance 
indicators (KPIs) and actions 
plans under the current Innovation 
Development Programme, Import 
Substitution and Equipment 
Localisation Programme, and Energy 
Saving Programme take into account 
the Programme provisions 
and are integrated into the current 
version of the document. 
Performance indicators include 
an integrated KPI for innovations. 
Rosneft’s Investment Programme 
aims to help the Company achieve its 
strategic objectives in key business 
areas stipulated in the Strategy 
and the Programme (
Programme in 2022 section).

 Investment 

We completed the Programme’s key 
initiatives planned for core businesses 
and functional units in 2022. 

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

KPI structure

The Company’s KPI system seeks to decompose the Company’ Development Strategy 
and its Long-Term Development Programme into specific KPIs, cascade them 
to all management levels, evaluate progress against targets, and create incentives 
for efficient management decision-making. A strong motivation tool for employees, 
KPIs ensure a step-by-step achievement of the Company’s strategic goals.

KPI PROGRESS

Long-Term Development 
Programme

The Company’s  
Strategy 

Consolidated 
business plan

Business plans 
of business units

Business plans 
of Group Subsidiaries

 ● Corporate KPIs
 ● Individual KPIs of the 

Chief Executive Officer
 ● Bonus disqualification 
(blocking) indicators

 ● Bonus disqualification 

(blocking) indicators set 
for heads and employees 
of business units

 ● Individual KPIs 

of the Company’s top 
managers responsible 
for the performance 
of businesses

 ● Collective KPIs of Group 

Subsidiaries

 ● Individual KPIs of Group 
Subsidiaries’ senior 
management

 ● Bonus disqualification 
(blocking) indicators

KPI progress

1. 

In accordance with Instruction of the President of the Russian Federation Vladimir Putin No. Pr-3086 dated 27 December 2013; approved 
by Rosneft’s Board of Directors on 9 December 2014 (Minutes No. 12).

2.  In accordance with the Russian Government Directive No. 4955p-P13 dated 17 July 2014.
3.  No. 4955p-P13 dated 17 July 2014, No. 7558p-P13 dated 12 November 2014, No. 1346p-P13 dated 5 March 2015, No. 2303p-P13 dated 
16 April 2015, No. 7389p-P13 dated 31 October 2014, No. 1472p-P13 dated 3 April 2016, No. 4531p-P13 dated 28 June 2016, No. 4750p-
P13 dated 4 July 2016, No. 830p-P13 dated 6 February 2017, No. 276p-P13 dated 17 January 2019, No. 6739p-P13 dated 30 July 2020, 
and No. 3502p-P13 dated 15 April 2021.

8

9

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

KPI progress

To calculate annual bonuses 
for managers and employees, 
the Company analyses progress 
against KPIs following the review 
of the annual performance based 
on the management accounts 
and audited public financial 
statements.

The Company’s Internal Audit Service 
annually assesses the performance 
against corporate and individual KPIs 
set for calculating annual bonuses 
for the management of the Company 

and Group Subsidiaries. The audit 
results for top managers are subject 
to review by the Board of Directors’ 
HR and Remuneration Committee.

Top manager assessment 
results are discussed by the HR 
and Remuneration Committee 
of the Board of Directors. 
The Board of Directors makes 
resolutions regarding annual bonus 
payments and their size depending 
on the management’s progress 
against KPIs.

Target KPIs are normalised 
to reflect the factors beyond 
the management’s control, such as FX 
volatility and global market prices, 
in accordance with the Regulations 
on the KPI Normalisation 
Procedure Related to Management 
Performance Review and Assessment 
in the Reporting Period to Calculate 
Annual Bonuses1.

THE KPI SYSTEM ENSURES:

 ● well-balanced integrated indicators motivating employees  

to achieve the Company’s main goals;

 ● transparency, measurability, minimum sufficiency,  

and consistency of KPIs;

 ● a top-down approach to cascading and breaking down KPIs.

THE KPI SYSTEM IS AIMED AT:

 ● delivering on the Company’s Strategy  

and Long-Term Development Programme;

 ● consistently improving the Company’s financial  

and operating (industry-specific) results;

 ● ensuring compliance with directives and instructions  

of federal executive bodies.

With both financial (economic) 
and operating (industry-specific) KPIs 
in place, the system breaks down 
relevant indicators into the following 
groups:
 ● corporate KPIs based on the key 
financial, economic, operating 
and industry-specific indicators 
from the Company’s consolidated 
business plan and business plans 
of its business units;

 ● individual KPIs based on individual 

strategic goals for each top 
executive.

Aside from that, for the purposes 
of motivating the Company’s 
employees to deliver on Rosneft’s 
Strategy, Long-Term Development 
Programme and business plan, we 
introduced bonus disqualification 
(blocking) indicators. A failure 
to achieve targets under these 
indicators reduces the employee’s 
overall annual bonus amount 
in the reporting period.

KPIs and targets for the senior 
management are set by Rosneft’s 
Board of Directors on an annual basis 
subject to preliminary discussion 
by the relevant committee.

10

11

1.  The Regulations were approved (Minutes No. 27 dated 6 April 2015) and amended (Minutes No. 10 dated 27 September 2021) 

by Rosneft’s Board of Directors.

Investment  
programme

Rosneft’s 2022 investment programme was approved as part 
of the 2022–2023 Business Plan at the Board of Directors meeting 
on 17 December 2021 (Minutes No. 16 dated 20 December 2021).

business segments based 
on portfolio management 
approaches.

Within our portfolio, we evaluate 
projects and investment 
opportunities on the basis 
of project profitability by taking 
into account risk assessments 
and the Company’s financial 
capacity.

The 2022 capex was mainly focused 
on maintaining and developing 
mature and new oil and gas assets 
to meet our strategic production 
and reserve replacement goals, 
as well as implementing cost-effective 
projects to develop refineries 
and a retail network development 
programme.

As part of drafting and implementing 
its investment programme, 
the Company swiftly responds 
to external and internal developments 
by selecting and prioritising projects 
and quickly optimising or reallocating 
investments between different 

>rub  
 1.1 trln 

Capex in 2022

CAPEX, RUB BLN

1,049

1,132

785 

2020

2021

2022

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Investment process

OUR INVESTMENT ACTIVITIES HELP US ENSURE COMMITMENT 
TO THE FOLLOWING STRATEGIC PRIORITIES:

 ● Sustainable business growth driven by investments in competitive and high value-added projects based 

on an ongoing portfolio optimisation

 ● Increasing efficiency across all business streams through an in-depth analysis of investment needs, 
efficient decision-making and project implementation, monitoring and control throughout the project 
life cycle

 ● Strengthening investment discipline by ensuring better project identification, classification, thorough 

project analysis and efficient decision-making process reliant on delegation of authority

 ● Honouring social responsibility principles regarding occupational safety and environmental protection

 ● Focus on the UN Sustainable Development Goals to help achieve progress in addressing global economic, 

social and environmental challenges, including those related to carbon management

DELEGATING: INVESTMENT DECISION-MAKING HIERARCHY

Board of Directors

Management Board

Investment Committee

Dedicated committees

Exploration and 
Production

Refining, Commerce 
and Logistics

Functional

Rosneft’s investment governance process is integrated with all related processes, including strategic 
and business planning, budgeting, reporting and financial control, project management and corporate 
governance.

12

13

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Refining and sales

In the reporting year, Rosneft refined 
94.4 mmt of crude oil. The refining 
depth and light product yield across 
its oil refineries in 2022 improved 
to 76.2% and 57.1%, respectively.

The Company continued to fully 
meet the growing domestic demand 
for high-quality motor fuels. In 2022, 

domestic sales of petroleum products 
reached a record-breaking 42.1 mmt, 
up 6.0% year-on-year.

The Company has been consistently 
working on domestic technologies 
and import substitution, while 
providing its oil refineries in Russia 
with proprietary catalysts 

for the production of motor fuels 
compliant with the latest standards. 
In the reporting year, Rosneft 
launched export sales of its catalysts 
given their high quality.

Financial results

In 2022, the Company achieved 
growth across key financial metrics 
thanks to its operating performance 
in the prevailing macroeconomic 
environment coupled with sound 
decision-making.

The Company’s operating 
performance and transportation costs 
were negatively affected by higher 
electricity prices, as well as increased 
tariffs for transportation of oil 
and petroleum products by rail 
and pipeline.

Thus, our revenue increased by 3.2% 
year-on-year, while EBITDA improved 
by 9.5%.

In 2022, capex reached RUB 1.1 trln, 
up 7.9% year-on-year.

In the reporting year, our net 
income attributable to shareholders 
amounted to RUB 813 bln, mainly 
driven by non-cash items. The net 
income so achieved forms a solid 
basis for dividend payout for 2022.

In order to maintain financial 
stability, Rosneft took a number 
of steps which helped reduce 
its financial debt and advance 
payment arrears by RUB 0.7 trln 
compared to the beginning of 2022. 

The net debt/EBITDA ratio was 1.3x 
as at 31 December 2022, generally 
in line with that as at 1 January 2022.

EBITDA, RUB BLN

2,330 

2,551

2021

2022

Operating  
and financial results

Exploration and production

as at 31 December 2022. The 2Р 
reserve replacement ratio 
exceeds 100%.

Production drilling in 2022 
amounted to 11.2 mln m, up 
3.3% year-on-year. Despite 
a volatile macroeconomic 
and geopolitical environment 
in recent years, Rosneft has 
been maintaining consistently 
high volumes of production 
drilling. The reporting year saw 
more than 3 thousand wells put 
into operation, with the share 
of the most efficient horizontal 
wells reaching 68%. The number 
of new horizontal wells drilled 
using multi-stage hydraulic 
fracturing techniques stood 
at over 1,300, or 43% of all wells 
commissioned during the year. 
Production per horizontal 
well was more than twice 
as high as per directional well. 
The Company relies on such 
wells to sustain production 
at mature fields by developing 
more complex deposits, 
as well as to reduce costs when 
developing conventional ones.

Суточная добыча углеводородов, млн б.н.э. в сутки

DAILY HYDROCARBON 
PRODUCTION,  
KBOE PER DAY

4,985 

5,102

+2.3 %

2021

2022

NATURAL GAS 
PRODUCTION, BCM

64.7

74.4

+15.0 %

2021

2022

In 2022, the Company’s hydrocarbon 
production reached 5.10 mmboe per 
day, up 2.3% year-on-year. After 
Sakhalin-1 resumed production 
in the fourth quarter of 2022, 
average daily output of hydrocarbons 
increased to 5.50 mmboe.

The reporting year saw natural 
gas production at an all-time high 
of 74.4 bcm, up 15% year-on-year.

In 2022, Rosneft conducted 
over 4.4 thousand linear km 
of 2D seismic and more than 
6.8 thousand sq. km of 3D seismic 
onshore. 64 exploration wells 
were completed and tested 
with a success rate of 80%.

Our robust exploration 
activities helped discover 
seven fields and 153 deposits 
with a total of around 0.3 btoe 
in AB1C1+B2C2 reserves. 
Some of the most important 
discoveries included 
the Madachagskoye field 
on the Pechora Sea shelf 
with 82.3 mmt in recoverable 
AB1C1+B2C21 oil reserves, being 
the largest discovery in Russia 
in 2022. Under the Russian resource 
classification system (АВ1С1+В2С2), 
Rosneft’s hydrocarbon reserves 
totalled 159.3 bboe (21.5 btoe) 
as at 31 December 2022.

Following an audit under the PRMS 
(Petroleum Resources Management 
System) standards, the Company’s 
1P, 2P and 3P hydrocarbon reserves 
stood at 42.3 bboe, 84.2 bboe 
and 132.4 bboe, respectively, 

Проходка в эксплуатационном бурении, млн м

PRODUCTION 
DRILLING, MLN M

10.9 

11.2

+3.3 %

2021

2022

Vostok Oil project

In 2022, the Company conducted 
over 2 thousand linear km of 2D 
seismic and 2 thousand sq km of 3D 
seismic, drilled six exploration wells 
and completed construction of four 
wells with five wells being tested 
as part of the flagship Vostok Oil 
project. As a result, its resource 
base increased by 300 mln tonnes 
to 6.5 bln tonnes, with the project’s 
high resource potential confirmed 
by an independent international audit.

In the second half of 2022, 
Rosneft started pilot production 
at the Payakhskoye field. So far,  
it has drilled more than 
25 thousand m and completed 
seven production wells, while drilling 
is in progress at five more wells.

expanded. As part of the project, 
Rosneft built a record-breaking 
2 thousand km of winter roads 
passing through the north 
of the Krasnoyarsk Territory 
and the Yamal-Nenets Autonomous 
Area.

The construction of the Vankor–
Payakha–Sever Bay trunk oil 
pipeline is underway, with coastal 
and berthing facilities being also 

1.  The reserves were booked in the Russian State Register of Mineral Reserves in 2022.

14

15

Health, safety 
and environment

Strategic HSE guidelines and targets

As a national oil and gas champion 
and a major global energy company, 
Rosneft operates in strict compliance 
with Russian health, safety 
and environment (HSE) regulations.

Our top priority is to protect life 
and health of the Company’s 
and contractors’ employees.

The Company ensures safe working 
conditions seeking to support 
accident-free operations, keep 

the equipment in good repair 
and proper working order 
and minimise environmental footprint 
in compliance with HSE requirements.

Our strategic goals, targets 
and initiatives as well as systemic 
approaches to HSE management 
are enshrined in the Rosneft-2030 
Strategy.

Strategic HSE targets

 ● Drive towards:

 – zero fatalities by 2030  

or sooner;

 – zero equipment breakdowns 

by 2030 or sooner;

 ● minimisation of environmental 

footprint;

 ● net positive impact on ecosystems.

HSE management system and principles

Resolutions adopted by the Board 
of Directors in 2018 ensure that 
Rosneft’s operating and strategic 
priorities conform to the 17 UN 
Sustainable Development Goals, 
with five of them defined as key 
focus areas: Good Health and Well-
Being, Affordable and Clean Energy, 
Decent Work and Economic Growth, 
Climate Action and Partnership 
for Sustainable Development.

The Company pursues its HSE 
objectives within the framework 
of the Integrated Health, Safety 
and Environment Management System 
(IMS).

The system is certified annually 
by external auditors to verify that it 
meets the national and global HSE 
standards.

In 2022, Rosneft and Group 
Subsidiaries successfully passed 
an external audit of the HSE IMS, 
which increased the number 
of certified Group Subsidiaries 
to 74 as part of the Company’s overall 
certification. 32 Group Subsidiaries 
completed independent occupational 
health and safety certification, 
and 33 were certified in the area 
of environmental management.

The certification process includes 
more than 100 business units which 
account for 72.5 % of the total 
headcount of all Group Subsidiaries 
covered by the Company’s 
management accounting procedures.

In addition to the mandatory controls 
required by law, the Company 
employs the following main types 
of regular controls:
 ● full-scope and ad hoc 

inspections to verify compliance 
with HSE requirements, 
corporate plans and internal 
documents of the Company, 
as well as the adequacy of ongoing 
operational and environmental risk 
management efforts;

 ● internal HSE IMS audits to assess 

compliance with the Environmental 
Management System (ISO 14001) 
and Occupational Health 
and Safety Management System 
(ISO 45001) standards.

Currently, Rosneft has an HSE control 
system in place, which is governed 
by the Regulations on HSE Control.

In 2022, Rosneft and Group 
Subsidiaries conducted 61 full-scope 
and ad hoc inspections and internal 

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Priority UN SDGs

HSE IMS audits. Following the audits, 
Group Subsidiaries prepared 
corrective action plans to bridge 
the gaps identified with a focus 
on the HSE management system 
improvements.

The HSE Control Commission 
regularly meets with the senior 
managers of Rosneft and Group 
Subsidiaries to address matters 
of operational safety and HSE risk 
management which require specific 
decisions to be made by the top 
management. In 2022, the HSE 
Control Commission held 11 meetings.

Rosneft seeks to improve its risk-
oriented approach for the purposes 
of planning and implementing 
controls in a targeted way. In 2022, it 
developed and introduced practices 
to assess Group Subsidiaries based 
on their specifics and HSE metrics.

This approach underpins the control 
plan for 2023 which ensures objective 
assessment and covers potentially 
high-risk aspects of HSE activities, 
including with a special focus on key 
Group Subsidiaries and the most 
important projects for the Company.

Corporate HSE governance

The Board of Directors 
provides strategic management 
of the Company’s HSE activities 
and regularly reviews related 
reports.

The HSE Committee is the Company’s 
key standing coordinating body 
in charge of HSE. In 2022, the HSE 
Committee held six meetings 
to review matters and adopt 

decisions seeking to manage HSE 
risks and prevent occupational 
injuries and accidents, including 
with an adverse environmental 
impact.

16

17

Safe working environment

The Company’s top priorities 
are to ensure the safety of all 
employees and contractors who work 
for us, implement environmentally 
responsible work practices in all 
operational activities and minimise 
environmental footprint.

In order to achieve the goals 
of the Rosneft-2030 Strategy, 
systemic approaches to occupational 
health and safety (OHS) management 
have been defined:
 ● in terms of reducing fatal injuries:
 – application of a risk-oriented 

approach to OHS,

 – absolute compliance 

with the Golden Rules of Safety,

 – implementation of the Control 

of Work procedure,

 – development of employee skills 

and competencies;

 ● in terms of reducing equipment 

breakdowns:
 – implementation of equipment 
reliability/integrity measures.

The Company provided ca. RUB 43.7 
bln in OHS spending in 2022, including 
on activities required by national 
laws and corporate regulations, 
and strategic initiatives.

≈ rub  
43,7  
bln 
OHS spending 
in 2022

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Contractor relations

Coordination of contractors’ efforts 
in terms of operational safety 
is an important element of our 
safety culture and a prerequisite 
for the Company’s sustainable 
development.

The HSE Policy makes no 
difference between the Company’s 
and contractors’ employees 
when protecting life and health 
and ensuring operational safety.

When preparing contract terms 
and procurement documentation, 
the Company assesses the risks 
associated with works and services 
to be provided by prospective 
contractors. Contractors are subject 
to mandatory HSE qualification 
procedures to verify they meet 
the Company’s requirements 
for the availability of an HSE 
management system, qualified 
employees and personal protective 
equipment.

a comprehensive work authorisation 
procedure to verify they are ready 
to operate safely and meet 
the Company’s requirements.

Rosneft monitors contractors’ 
operations, holds safety 
awareness sessions and conducts 
communication activities. Customers 
and their contractors also participate 
in joint accident and emergency drills.

Contractor cooperation on HSE 
is a must throughout the entire cycle 
of customer-contractor interaction. 

Upon signing the contract, 
contractors go through 

Leadership and safety culture

Risk-oriented approach

To raise awareness of the Company’s 
climate action among its employees, 
Rosneft continued to run its updated 
Carbon Management corporate 
courses in 2022. In the reporting year, 
Rosneft provided training to more 
than 150 employees of the Company’s 
Head Office and Group Subsidiaries. 
A corporate distance learning 
course was prepared and launched 
in January 2023.

The managers of Rosneft and Group 
Subsidiaries annually commit 
to demonstrate their HSE leadership. 
Since 2022, the HSE Committee 
has been approving the HSE 
leadership criteria for managers at all 
levels. In line with these criteria, 
the managers of Rosneft and Group 
Subsidiaries develop their personal 
HSE leadership commitments 
with a focus on supporting employee 
safety and HSE compliance, including 
the Golden Rules of Safety covering 
key operational safety requirements 
of the Company.

Representatives of Group Subsidiaries 
regularly meet with contractors 
to discuss current health and safety 
issues, review incidents and lessons 
learned, and develop joint solutions 
to ensure high safety standards 
at the Company’s facilities.

In 2022, the Company held two major 
environmental corporate events: 
the Strategy Session and the 9th 
Corporate Congress of Rosneft 
Ecologists. The participants 

included top management, leaders 
and environmental experts from 
more than 150 Group Subsidiaries, 
and professionals from allied 
business units of the Company’s 
Head Office.

The events focused 
on the environmental goals, strategic 
initiatives and key objectives 
set forth in the Rosneft-2030 
Strategy, as well as the Company’s 
progress towards them. Biodiversity 
conservation, global energy 
transition, circular economy 
and law enforcement trends 
were key issues in the reports 
presented by the Company’s 
experts. The participants also 
discussed using forests as potential 
natural CO2 absorbers to achieve 
net zero emissions, being 
the Company’s strategic target 
for 2050, as well as measures 
to implement Rosneft’s pilot forest 
and carbon management project 
in the Krasnoyarsk Territory aimed 
at increasing absorption to 10 mmt 
of CO2-equiv.

The aim of HSE risk management 
is to introduce and maintain adequate 
and sufficient management actions 
regarding all identified risks that 
are consistent with the level 
of the risk assessed, provided 
with the necessary resources 
allocated by priority and approved 
on the required management level 
of the Company.

Application of the risk-oriented 
approach in HSE risk management 
includes assessment, analysis 
and management taking into account 
global and industry best practices, 
and helps predict possible events 
and take proactive steps to prevent 
them.

HSE risk management is a set 
of tools helping managers at various 
levels, from senior executives 
to line managers, to make the best 
and most efficient comprehensive 
decisions on operational safety 
when having limited resources. 
It is based on HSE risk analysis 
and assessment using a bow-
tie diagram and single matrix 
of HSE risk assessment. These 
findings are a starting point 
in prioritising mitigation efforts 
and defining the management 

level authorised to make 
a decision on the implemented risk 
management strategy.

The Company has developed 
standard diagrams for fire, road, 
blowout and pipeline leakage 
risks defining a set of proactive 
and reactive barriers (measures) 
for a particular type of incident. 
Based on the standard solutions, 
Group Subsidiaries develop 
programmes to create/enhance 
barriers. In particular, they already run 
programmes to prevent falls and road 
accidents.

In 2022, Rosneft streamlined HSE 
reporting timelines and formats 
to further align the same 
with the business planning process. 
These efforts will be embodied 
in new internal documents and put 
into practice in 2023.

The Company also applies 
the risk-oriented barrier approach 
to the investigation of HSE incidents 
and development of remedial 
actions.

The barrier approach to incident 
investigation is one of the key tools 
for reducing occupational injuries 

and accidents. It helps significantly 
expand the scope and effectiveness 
of risk management, identify gaps 
in design solutions and/or applicable 
regulations and technical standards 
regarding the proactive and reactive 
barriers in each case under investigation, 
and develop specific remedial action 
plans.

With the new Rosneft-2030 Strategy 
in place, the risk-oriented approach 
remains the central element in HSE 
and covers the full cycle of operations, 
from planning to performance audits. 
Process safety in line with the proactive 
and risk-oriented approach 
results in a set of measures aimed 
at achieving the Company’s safety 
targets. These measures are aimed 
not only at preventing accidents, but 
also at mitigating potential adverse 
consequences, primarily for people, 
society and the environment.

18

19

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

The programmes run by Group 
Subsidiaries in pursuance 
of the Company’s Road Safety Plan 
have a positive effect. In 2022, 
Rosneft had zero road fatalities 
through the fault of its employees. 
With this in mind, we decided 
to continue our efforts in 2023 
and beyond.

Road traffic safety

In 2022, under its 2020–2022 
Road Safety Plan, the Company 
implemented the following proactive 
measures to reduce road safety risks 
and prevent accidents:

 ● identifying dangerous locations 
on oilfield, on-site, industrial, 
or temporary winter roads 
and installing warning systems, 
traffic signs, and cameras that 
could help detect violations;

 ● monitoring the placement of road 
safety notices, traffic signs giving 
directions and alerting drivers 
to danger, as well as priority traffic 
signs, snow poles and hazard 
delineators;

 ● assessing the equipment 

of the Company’s and contractors’ 
vehicles using in-vehicle 
monitoring systems and video 
recorders;

 ● monitoring compliance 

with safety requirements related 
to transportation and trip planning 
arrangements, compliance 
with established travel routes 
and work and rest schedules 
by drivers of Group Subsidiaries 
and contractors using in-vehicle 
monitoring systems;

 ● running accident prevention 

campaigns “Safe road – 2022” 
and “We are for road safety – 
2022” in the regions of operation;

 ● monitoring road infrastructure 

 ● running the ten-day “Beware, 

and maintenance (timely cleaning 
and treatment of road surfaces, 
placement of traffic signs, 
condition of ice and winter roads, 
readiness of utility vehicles);

 ● preventing road accidents, 
including vehicle roll-overs, 
and enhancing road safety across 
Group Subsidiaries;

Children!” campaign in anticipation 
of the school year held by Group 
Subsidiaries in cooperation 
with the traffic police, including 
discussions and drawing 
competitions devoted to road 
safety.

of existing facilities and those 
under construction, regular training 
for the staff involved and safe 
maintenance of facilities located 
on the permafrost soil, while 
also developing and updating 
the Company’s internal documents 
governing the geotechnical 
monitoring design, construction 
and operation of facilities located 
on the permafrost soil.

As part of its target innovative project 
to develop geotechnical monitoring 
technologies, Rosneft intends 
to promote geotechnical monitoring 
at its facilities, including fundamental 
research into current permafrost 
processes, forecast of environment 
alterations driven by global climate 
change, search for and application 
of new methodologies and techniques 
enhancing the monitoring efficiency 
(e.g. cost reductions that do not 
translate into increased risks 
of on-site accidents).

Process safety

The Company complies with federal 
and corporate regulations on process 
safety. Operational functions and HSE 
units of Group Subsidiaries oversee 
both the planning and implementation 
of necessary actions when developing 
operational programmes and business 
plans, while Rosneft exercises 
centralised control.

The Company plays an active role 
in improving legislation on process 
and fire safety, including the large-
scale revision on the federal level. 
In 2022, Rosneft participated 
in discussing 154 draft regulations 
on occupational health and safety 
(draft laws of the Russian Federation, 
draft orders of Rostekhnadzor 
and federal ministries, draft 
resolutions of the Russian 
Government) put forward 
by Rostekhnadzor’s R&D Council, 
the Industrial Safety Committee 
of the Russian Union of Industrialists 
and Entrepreneurs, federal 
ministries, the Russian Government 
and the State Duma of the Russian 
Federation. The Company reviewed 
and finalised consolidated comments 
on, and additions to, the above 
documents.

Rosneft is a regular participant 
in industry-specific meetings 
and conferences held 
by Rostekhnadzor’s R&D 
Council, the Ministry of Energy 
and the Industrial Safety 
Committee of the Russian Union 
of Industrialists and Entrepreneurs. 
The Company actively contributes 
to Rostekhnadzor’s working groups 
on revision of key federal standards 
and rules dealing with oil and gas 
industrial safety. In 2022, Rosneft 
participated in 44 meetings and joint 
sessions on HSE matters.

Since January 2019, the Company 
has been extensively using a routine 
to keep record of and categorise 
industrial incidents in line 
with its strategic target of zero 
equipment breakdowns. Along 

with the risk-oriented (barrier) 
approach, special-purpose 
programmes are also in place 
to ensure the integrity of operational 
facilities, which is achieved primarily 
by including ad hoc inspections 
and audits in the action plans 
aiming to create/enhance barriers 
where the incidents have revealed 
inconsistencies.

In line with the Rosneft-2030 strategic 
targets in Environmental Leadership 
adopted in 2021 with a view 
to reducing land contamination from 
pipeline oil spills to zero by 2035, 
the Company updated its special-
purpose programme titled “Oilfield 
Pipeline Reliability Improvement 
in 2020‒2025” with a prospect up 
to 2035.

In 2022, the Company performed 
the following actions under its 
pipeline integrity programme 
“Pipeline Reliability Improvement 
in 2020‒2025”:
 ● revamp and repair of 1,580 km 

of oilfield pipelines;

 ● inhibition of more than 16,200 km 

of oilfield pipelines;

 ● in-line cleaning of 11,300 km 

of pipelines;

 ● diagnostics and safety reviews 

of 24,500 km of oilfield pipelines.

The Company continues to run 
equipment reliability improvement 
programmes in Oil Refining 
and Petrochemicals, including long-
term pipeline replacement initiatives:
 ● replacement of CrMo steel 

pipelines with austenitic welds;
 ● replacement of end-of-life carbon 

steel pipelines;

 ● removal of dead-end sections;
 ● removal of various fittings;
 ● removal of open pressure relief 

valves;

 ● replacement of overhead pipelines.

To reduce risks of on-site accidents, 
the Company continues to run its 
geotechnical monitoring project, 
which includes continuous review 

20

21

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Environmental responsibility

Water protection

Green investments

The Company consistently implements 
investment projects and initiatives 
seeking to achieve its strategic 
targets of minimising environmental 
footprint and facilitating biodiversity 
conservation in the regions 

of operation. In 2022, green 
investments to improve pipeline 
reliability, wastewater treatment 
and waste management practices, 
and remediate contaminated land 
amounted to ca. RUB 57 bln.

≈ rub  
57 bln 

in green investments

One of the Company’s strategic 
priorities is to minimise 
the demand for fresh water 
in alignment with the United 
Nations Sustainable Development 
Goals. This is achieved 
through the implementation 
of infrastructure modernisation 

projects and the use of the best 
available technologies. In 2022, 
the Company continued to improve 
the quality of wastewater 
discharges through construction 
and renovation of treatment 
facilities. This was helped 
by the renovated facilities reaching 

their design capacity and existing 
ones being maintained to show 
the same efficiency as before.

The Company nearly halved the share 
of excess pollutant discharges in 2022 
vs 2021.

Non-greenhouse gas emissions

In 2022, the Company reduced gross 
air pollutant emissions by 2% year-
on-year, while also halving its excess 
emissions. 

Our Gas Investment Programme 
has many environmental effects 
contributing to further reduction in air 
pollutant emissions.

22

23

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Carbon management

Carbon management – risk and opportunity management

The Company takes into account 
the importance and impact of carbon 
management risks (including risks 
associated with climate change) 
on its operations. Our commitment 
to sustainability principles was further 
highlighted in the new Rosneft-2030 
Strategy, which provides 
for a reduction of the Company’s 
carbon footprint while boosting its 
operational and financial efficiency.

Rosneft plans to achieve carbon 
neutrality by 2050 through a number 
of strategic initiatives to reduce 
emissions. These initiatives imply:
 ● a more than 25% reduction 

in Scope 1 and 2 emissions by 2035 
as compared to 2020;

 ● achievement of zero routine APG 

flaring in line with the World Bank’s 
Zero Routine Flaring by 2030 
initiative;

 ● a reduction of methane intensity 

to below 0.2%;

 ● a gradual transition 

of the Company’s vehicles to low-
carbon fuels.

These initiatives will contribute 
to the goals set by Russia’s Long-
Term Development Strategy 
with Low Greenhouse Gas Emissions 
to 2050 and will help Russia fulfil its 
obligations under the Paris Climate 
Agreement.

Biodiversity conservation

As part of its corporate 
strategic initiatives designed 
to achieve a net positive impact 
on ecosystems, the Company 
places a special focus 
on biodiversity conservation. 
In 2022, Rosneft developed 
conceptual approaches 
to biodiversity conservation, 
formalising them in its internal 
documents, and also started 
drafting a corporate-wide 
Programme for Biodiversity 
Conservation in the regions 
of operation.

In pursuance of the national 
Environment project 
and the Cooperation Agreement 
between Rosneft and the Russian 
Ministry of Natural Resources 
and Ecology, the Company 
continued to assess the current 
natural state and population 
dynamics of key species 
in the marine and terrestrial 
ecosystems of the Arctic. 
These species are indicated 
in the Agreement and include 
wild reindeer, ivory gull, Atlantic 
walrus, and polar bear – all (except 
for the reindeer) listed in the Red 
Data Book of the Russian 
Federation.

Following up on the field work 
to study polar bear populations 
in 2020–2021, the Company 
was processing field data throughout 
2022. In August 2022, further 
field studies were carried out 
with a focus on walrus populations 
on Alexandra Land, an island in Franz 
Josef Land, as well as the Orange 
Islands and Cape Zhelaniya, part 
of the Novaya Zemlya archipelago. 

Reconnaissance and aerial surveys 
were conducted in wild reindeer 
habitats near the Kheta and Khatanga 
rivers, with their migration routes 
studied in the Taimyrsky Dolgano-
Nenetsky and Evenki districts, 
Krasnoyarsk Territory. An office 
analysis of the findings and ivory 
gull biological specimens offered 
insights about eight ivory gull colonies 
in the Kara Sea.

Drilling waste and oily waste handling, land remediation

as a result of past activities 
of previous owners of assets prior 
to their integration into Rosneft.

In 2022, the Company processed 
more than 4 mmt of drilling 
waste and around 1.2 mmt of oil-
contaminated waste, which enabled it 
to dispose of the waste accumulated 
in the reporting year and reduce 
the amount of legacy waste. 
Rosneft keeps handling waste in line 
with the applicable Russian laws.

The Company continues to restore 
land resources by reducing 
the area of contaminated land, 

with over 470 hectares remediated 
(more than 90% owing to the efforts 
of internal ecological services 
established by key Group Subsidiaries). 
Efforts are ongoing to survey 
contaminated areas and develop land 
remediation projects.

In 2022, the Company approved 
and started implementing a programme 
to eliminate environmental legacy 
effects, which aims to fully eliminate 
land contaminated and waste generated 

24

25

Corporate governance

Key corporate governance principles 
and improvements in 2022

Rosneft’s leading market position, both 
domestically and globally, and its commitment 
to creating a long-term sustainable value 
make it of the utmost importance that our 
corporate governance framework ensures 
efficient communication and cooperation 
between the shareholders, Board 
members, top managers, employees, 
business partners, and local communities 
across the Company’s footprint.

Our corporate governance framework seeks 
to drive the long-term sustainable growth 
of the Company’s shareholder value.

Rosneft’s corporate governance 
framework relies on the Corporate 
Governance Code developed in line 
with internationally recognised standards.

Rosneft maintains 
compliance 
with the Bank 
of Russia’s Corporate 
Governance Code 
at a high level.

For evaluation of compliance 

with the Bank of Russia’s 

Code, see 

 Appendix 1 to this 

Annual Report.  

The internal documents 

regulating corporate 

governance are available 

on the Company’s official 

website.

 The Corporate 

Documents 
section 
of the Company’s 
website

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

GUIDING PRINCIPLES FOR THE COMPANY’S GOVERNING BODIES

Commitment to shareholders

Rosneft has adopted the world’s best corporate governance practices, complies with the Bank of Russia’s 
Corporate Governance Code to ensure the following:  

 ● equal rights and opportunities for, and equitable treatment of all shareholders;
 ● professionalism and independence of the Board of Directors who act in the best  

interests of all shareholders;

 ● efficiency of the Risk Management and Internal Control System (RM&ICS);
 ● timely disclosure information on the Company’s activities that is most relevant to shareholders 

and investors for them to rely on in making informed decisions (references  
to 

 Corporate Governance Code).

 Appendix 2 and the 

A substantial share of the Company’s net income is distributed as dividends.
In 2022, our shareholders received RUB 250.4 bln. We continue enhancing the Shareholder’s Personal 
Account, a powerful tool for shareholders to stay in contact with the Company.

Innovation and global leadership

Continuous improvement and global leadership are the priorities that encourage us to develop  
and invest in cutting-edge technologies.

Favourable environment for sustainable growth

The Company cares for its employees, their families, and members of local communities across its footprint.
We at Rosneft keep a clear focus on employee health, having adopted an integrated framework to respond 
to epidemic threats. We supplied all production sites and offices with personal protective equipment 
and arranged for regular testing of our employees and contractors.
The Company takes care of the environment by introducing carbon management initiatives and implementing 
best waste management practices. Commitment to environmental safety is an integral part of our corporate 
culture. The Company supports scientific research, culture, and sports. Rosneft respects and honours 
human rights and freedoms in accordance with the Universal Declaration of Human Rights, Social Charter 
of the Russian Business, relevant generally accepted standards, and the laws of the Russian Federation 
and other countries where the Company operates.

Partnership with non-governmental organisations and cooperation with state institutions

The Company is a party to the UN Global Compact.
Rosneft is a major contributor to the revenue part of the national budget: over the past decade, the Company’s 
taxes and other mandatory payments have accounted for 17% of all federal budget revenue for the period.

Protection of shareholders and key stakeholders

The Company implements best internal control and risk management practices, develops technologies for industrial 
safety and information security, and ensures product safety, protecting its customers and contractors.

26

27

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Key achievements in 2022

Rosneft was able to improve its ranking in the Net Zero Company Benchmark, 
which measures global companies’ progress towards carbon neutrality, and scored 
ahead of all Russian peers. The Company enhanced its position after it had 
announced its goals under the Rosneft-2030: Reliable Energy and Global Energy 
Transition Strategy approved by the Board of Directors in December 2021.

Rosneft is among the first 
companies in the Russian 
oil and gas industry to set 
a target of achieving net carbon 
neutrality by 2050 with respect 
to Scope 1 and 2 emissions.

The Rosneft-2030 Strategy 
outlines the climate agenda 
for short- and long-term horizons: 
cut absolute GHG emissions by 5% 
by 2025; reduce methane intensity 
to below 0.2%, achieve zero routine 
flaring of APG and cut specific 
GHG emissions in Exploration 
and Production to below 20 kg 
of CO2 per boe by 2030; and cut 
absolute GHG emissions by more 
than 25% by 2035.

Rosneft’s Board of Directors 
resolved to resume the Company’s 
Open Market Share Buyback 
Programme and extend it until 
31 December 2023. The decision 
to buy back its shares in the open 
market testifies to the confidence 
that Rosneft and its management 
team have in the Company’s 
robust development going 
forward.

In line with the Bank of Russia’s 
recommendations, the Company 
engaged JSC Kept (KPMG 
before 1 July 2022), an external 
consultant, to carry out 
external (independent) 
assessment of performance 

(effectiveness) of Rosneft’s Board 
of Directors and its committees 
in the 2021/2022 corporate year.

The assessment was based 
on the independent consultant’s 
methodology aligned 
with the assignment approved 
by the HR and Remuneration 
Committee of the Board 
of Directors and included 
reviewing Rosneft’s internal 
regulations that govern 
the activities of the Board 
of Directors, and surveying 
members of the Board 
of Directors.

Corporate 
governance 
plans for 2023

 ● Develop remote formats 

of engagement with shareholders 

and members of governing 

and supervisory bodies

 ● Meet goals and objectives 

outlined in the Rosneft-2030: 

Reliable Energy and Global 

Energy Transition Strategy

28

29

Governance and control structure

The Company operates a two-tier management model where management 

functions are split between the Board of Directors and executive bodies.

Board of Directors

Executive bodies

The Board of Directors performs 
the two key functions:
 ● strategic management of the joint-
stock company, which includes 
approving strategic documents 
and material transactions;

 ● oversight of the executive bodies.

 ● Under the law, the Chief Executive Officer (sole executive body) is authorised to act 

on behalf of the Company without a power of attorney when dealing with third parties.

 ● Rosneft has established a collective executive body (Management Board) 
chaired by the Chief Executive Officer. Pursuant to the laws of the Russian 
Federation, the Management Board and its members (except for the CEO) 
are not authorised to enter into transactions or execute legal acts on behalf 
of the Company without a power of attorney.

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General Shareholders Meeting

Rosneft’s supreme governing body responsible for decision-making on key matters 
of the Company’s business.

Board of Directors

Provides strategic management of the Company’s activities; it reports 
to the General Shareholders Meeting and acts on behalf and for the benefit of all 
shareholders within its remit.

Set-up

Committees of the Board of Directors

Audit Committee

HR and Remuneration Committee

Reviews and then issues 
recommendations for overseeing 
the Company’s business, 
preparing complete and accurate 
accounting (financial) statements 
and other reports, and ensuring 
reliability and effectiveness of risk 
management and internal control 
systems, compliance, internal audit, 
and corporate governance

Reviews and then issues 
recommendations for assessing 
effectiveness of the Company’s 
HR and succession policies 
and the appointment 
and remuneration system, 
evaluating Board and management 
candidates, reviewing independence 
of independent directors, 
and conducting performance 
assessments of the Board 
of Directors, the executive bodies, 
and top managers of the Company

Strategy and Sustainable 
Development Committee

Assists in defining the Company’s 
strategic goals and growth targets, 
including ESG goals, and issues 
strategic and business planning 
recommendations.

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Reporting

Executive bodies (Chief Executive Officer and Management Board)

Executive bodies manage the day-to-day 
operations for the benefit of the Company 
and report to the Board of Directors and the General 
Shareholders Meeting.
Chief Executive Officer

Sole executive body

Management Board

Collective executive body

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Coordinating and consultative bodies

Coordinating and consultative 
bodies of the Chief Executive Officer 
carry out in-depth reviews of matters 
that are reserved to them.
These bodies include:
 ● Technological Council;
 ● Investment Committee;
 ● Budget Committee;

 ● Compliance Committee;
 ● Metrology Board;
 ● Carbon Management Committee;
 ● HSE Committee;
 ● Central Procurement Committee;
 ● Conflict Resolution Committee;
 ● Commission on Energy Efficiency;

 ● Information Technology Expert 

Council;

 ● other coordinating 

and consultative bodies 
of the Company.

Head of Internal Audit and Corporate Secretary are appointed  
by the Board of Directors

Internal Audit Service

Corporate Secretary

Assesses the robustness and effectiveness 
of the Company’s business processes, identifies 
internal potential for improving its financial 
and business performance, including that of the Group 
Subsidiaries.

Ensures the governing bodies’ compliance 
with the applicable laws, the Company Charter 
and internal regulations, which guarantee protection 
of shareholders’ rights and legitimate interests. 
Organises the work of the Board of Directors 
and is responsible for efficient communication 
between the Company’s shareholders, governing 
and supervisory bodies, and management.

Functional subordination

External auditor

Audit Commission

A commercial organisation selected through 
a procurement process and approved by the General 
Shareholders Meeting upon recommendation 
of the Board of Directors based on the Audit 
Committee’s assessment.

Oversees the Company’s financial and business 
operations and performance of its governing bodies, 
executives, business units and functions, branches 
and representative offices.

30

31

 
 
 
 
 
 
 
 
 
 
 
 
 
General Shareholders 
Meeting

In 2022, the Company’s supreme governing body met twice – for one Annual 
(FY2021) and one Extraordinary General Shareholders Meeting.

The procedure for convening, preparing for, holding and following 
up on the General Shareholders Meeting is set forth by 
Regulations on the General Shareholders Meeting.

 Rosneft’s 

Annual General Shareholders Meeting

Pursuant to Article 3 of Federal Law 
No. 25-FZ dated 25 February 2022, 
the Board of Directors had resolved 
to use absentee voting as the format 
for the Company’s Annual General 
Shareholders Meeting, which was held 
on 30 June 2022 (vote by means 
of ballots).

The meeting approved the Annual 
Report, annual accounting (financial) 
statements and net income 
distribution for 2021 (including 
for dividend payment), elected 
the Board of Directors and the Audit 
Commission, determined 
the remuneration of the Board 

and Audit Commission members 
for the period, and approved 
the Company’s Auditor.

Extraordinary General Shareholders Meeting

As part of implementing its dividend policy, on 23 December 2022 

the Company held an Extraordinary General Shareholders Meeting 

by absentee voting, which resolved to pay interim dividends.

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Exercise of rights by shareholders

THE COMPANY’S SHAREHOLDERS HAVE A NUMBER OF WAYS AVAILABLE TO THEM TO EXERCISE 
THEIR RIGHT TO TAKE PART IN THE GENERAL SHAREHOLDERS MEETING, INCLUDING:

 ● participation (registration and voting) at in-person meetings (directly or through their representatives 

acting by virtue of a power of attorney)

 ● e-voting through the Shareholder’s Personal Account

 ● absentee voting (voting by paper ballots or giving voting instructions to their respective nominees)

At the same time, given the COVID-19 
pandemic and related restrictions 
on public events, the Board of Directors 
decided to hold the 2022 Shareholders 
Meeting in absentia.

The Company’s own corporate 
services and the existing tools 
for remote communication enabled our 
shareholders to participate in corporate 
proceedings in full and provided 
unconditional ability to exercise 
shareholder rights without physical 
presence.

The shareholders were able to carry out 
the following activities remotely:
 ● review the information 

on the meeting on the corporate 
website and in the Shareholder’s 
Personal Account;

 ● vote on the items on the agenda 
via the Shareholder’s Personal 
Account by sending completed 
ballots to the Company or giving 
voting instructions to their 
respective nominees;

 ● ask questions on the agenda 
via their personal accounts, 
the shareholder hotline, or by mail.

Given that the Company’s initiative 
to enable the shareholders to exercise 
their rights remotely proved a success 
and taking into account the current 
changes in shareholder legislation 
and a tendency towards an increasing 
number of shareholders, Rosneft works 
to expand electronic services available 
to shareholders and develop other 
remote communication channels.

INCREASE IN THE NUMBER OF SHAREHOLDERS OVER THE PAST THREE YEARS, ‘000 PEOPLE

796.6

659.7

All resolutions of the 2022 shareholders meetings 
were implemented in full.

190.8

200.1

233.6

+4.9 %
+9.3 

+16.8 %
+33.5 

+182.4%
+426.1 

+20.7 %
+136.8 

2020
(May)

2021
(May)

2021
(September)

2022
(June)

2022
(November)

Number of shareholders

Increase in the number of shareholders vs previous period

32

33

Board of Directors

THE BOARD OF DIRECTORS PERFORMS THE TWO KEY FUNCTIONS:

1

2

Strategic management of the joint-stock company, which includes 
approving strategic documents and material transactions

Oversight of the executive bodies  

The Board of Directors has three standing committees 
created in accordance with Rosneft’s internal regulations. 
The committees are composed of non-executive directors 
from the Company’s Board of Directors. The Audit 
Committee and the HR and Remuneration Committee 
are chaired by independent directors. Members of each 
committee also include independent directors.

The committees of the Board of Directors are responsible 
for the preliminary consideration of most important 
matters and the provision of recommendations 
to the Board of Directors to inform their decisions.

The committees operate in accordance with approved 
plans to address the objectives set by the Board 
of Directors during their tenures.

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Responsibilities of the Audit Committee

The Committee assists the Board 
of Directors in protecting the interests 
of the Company’s shareholders 
by checking the accounting 
(financial) statements and other 
reports for completeness 
and accuracy and ensuring 
reliability and effectiveness of risk 
management and internal control 
systems, compliance, internal audit, 
and corporate governance.

In 2022, the Audit Committee positively 
assessed the effectiveness of external 
and internal audit processes and among 
other things reviewed the Report 
on Internal Audit Activities containing 
conclusions on the organisational 
independence of the Internal Audit 
Service and individual independence 
and impartiality of its employees.

 Reference  

to the Regulations 
on Rosneft Board  
Committees

Responsibilities of the HR and Remuneration Committee

The Committee assists the Board 
of Directors in protecting 
shareholder interests. To that 
end, it is primarily tasked 
with assessing the effectiveness 
of the Company’s HR and succession 
policies, and the appointment 
and remuneration system; conducting 
performance assessments 

of the Board of Directors, 
the executive bodies, and other top 
managers of the Company.

In 2022, the Committee preliminarily 
considered the report on external 
(independent) assessment 
of performance (effectiveness) 
of Rosneft’s Board of Directors 

and its committees in the 2021/2022 
corporate year carried out by external 
consultant JSC Kept (KPMG before 
1 July 2022), which gave a positive 
assessment of the performance 
of the Board of Directors, its 
committees, procedures, and team 
competencies of the Board 
of Directors.

Responsibilities of the Strategy and Sustainable 
Development Committee

The Committee assists the Board 
of Directors in providing strategic 
management of the Company’s 
activities and protecting shareholders’ 
interests by overseeing Rosneft’s 
strategy and sustainable 
development.

The Board of Directors positively 
assessed the performance of the com-
mittees in the 2021/2022 corporate 
year. In accordance with the Company’s 
Regulations on Rosneft Board 
Committees, each of the existing com-
mittees submits to the Board of Directors 
an annual progress report.

In 2022, the Committee preliminarily 
considered the 2021 Sustainability 
Report and report on the progress 
against the Rosneft-2030 Strategy. 
The Committee noted positive trends 
in the Strategy implementation 
despite unprecedented changes 
in the external environment.

Executive bodies

 ● Under the law, the Chief Executive 
Officer (sole executive body) 
is authorised to act on behalf 
of the Company without a power 
of attorney.

 ● Rosneft has established 

a collective executive body 
(Management Board) chaired 
by the Chief Executive Officer. 
Pursuant to the laws of the Russian 
Federation, the Management 

Board and its members (except 
for the CEO) are not authorised 
to enter into transactions or execute 
legal acts on behalf of the Company 
without a power of attorney.

34

35

  
  
  
  
  
  
  
ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Anti-corruption  
efforts

Rosneft works to maintain compliance with the requirements of the anti-
corruption laws of the Russian Federation, including through a set of measures 
aimed at building an organisational structure and elements of corporate culture, 
and establishing rules and procedures to prevent corporate fraud and corruption.

 ● conducted ongoing anti-corruption 
audits of draft internal regulations;

 ● The All about Compliance 

information bulletin dedicated 
to the International Anti-Corruption 
Day was sent to all Rosneft 
employees on 9 December 2022.

The Company manages conflicts 
of interest at all levels.

The rules for the avoidance 
and prevention of conflicts of interest 
are set forth in the Corporate 
Governance Code, the Code 
of Business and Corporate Ethics, 
the Company’s Policy on Combating 
Corporate Fraud and Involvement 
in Corruption Activities, 
and the Regulations on Managing 
Conflicts of Interest.

The effort was also aligned 
with the National Anti-Corruption Plan 
for 2021–2024 approved by Presidential 
Executive Order No. 478 dated 
16 August 2021.

The new anti-corruption procedures 
were developed in accordance 
with the applicable international 
anti-corruption laws, Federal 
Law No. 273-FZ On Combating 
Corruption dated 25 December 2008, 
the guidelines of the Russian Ministry 
of Labour and the Federal Agency 
for State Property Management, 
as well as International Anti-Corruption 
Standard ISO 37001:2016 “Anti-bribery 
management systems – Requirements 
with guidance for use”, and the ICC 
Guidelines on Conflicts of Interest 
in Enterprises.

All of the Company’s governing bodies 
contributed to these efforts within their 
remit.
1.  Rosneft’s Board of Directors 

(the Audit Committee of the Board 
of Directors) approved strategic 
documents and guiding 
principles, and regularly assesses 
the efficiency of such efforts; 
considered and approved the results 
of a review of the anti-corruption 
risk management and internal 
control process.

2.  Rosneft’s Chief Executive Officer 
ensures the implementation 
of the Company’s Policy 
on Combating Corporate Fraud 
and Involvement in Corruption 
Activities, and approves the relevant 
internal regulations.

3.  In accordance with the National 

Anti-Corruption Plan for 2021–2024 
approved by Presidential Executive 
Order No. 478 dated 16 August 
2021 (Instruction of the Russian 
Government No. MM-P17-12165 
dated 6 September 2021) we 
drafted a Comprehensive Anti-Fraud 
and Anti-Corruption Programme 
for 2021–2024 (approved 
by Rosneft’s Compliance Committee 
on 20 June 2022, Minutes No. KK-1).

In the reporting period, Rosneft:
 ● updated its employees on typical 
violations of anti-fraud and anti-
corruption rules (including 
management of conflicts of interest) 
on a quarterly basis;

 ● on an ongoing basis informed 
the relevant units about new 
regulations and government 
initiatives aimed at combating 
corruption;

 ● assessed/reassessed the risk 

of corporate fraud and corruption 
on a quarterly basis in line 
with the approved methodology;

The Regulations set out a framework 
to classify conflicts of interest, 
including conflicts of interest 
between shareholders and members 
of the Company’s governing bodies 
(e.g. decisions made by corporate 
governing bodies that might 
adversely affect the Company’s 
financial and operating performance; 
the Company failing to make a statutory 
disclosure or members of corporate 
governing bodies underreporting 
on their positions in governing 
bodies of other entities, on interests 
(stakes) held in other entities, or other 
information required to be disclosed 
by the applicable laws, the Company’s 
Charter or internal regulations).

 ● carries out an annual campaign 
to collect ethical declarations 
of the Company’s officers 
and employees in order to monitor 
their compliance with restrictions, 
prohibitions and requirements 
of anti-corruption laws;
 ● requires new employees 
and employees appointed 
to new position to sign an anti-
corruption clause, which forms 
part of their employment contracts 
and includes the restrictions, 
prohibitions and requirements aimed 
at preventing the conflict of interest.

All Group Subsidiaries have set up 
conflict of interest commissions.

The Board members’ obligations 
to disclose a conflict of interest are set 
out in the Regulation on the Holding 
by Members of Rosneft Board 
of Directors of Rosneft Shares, 
Shares of and Equity Stakes in Group 
Subsidiaries.

The Company runs ongoing corporate 
training programmes in the field 
of countering corporate fraud 
and corruption for its employees, 
including those whose job 
responsibilities include participation 
in combating corruption, and new hires.

The Company operates a 24/7 Security 
Hotline to report on suspected, proven 
and potential cases of corporate fraud, 
corruption and conflict of interest.

In addition, the Company undertakes 
the following:
 ● collects annual declarations 
on property and property-
related obligations of its 
officers and employees, 
as well as on income, property 
and property-related obligations 
of their spouses and minor children 
who are included in the list 
of persons required to submit such 
declarations;

15,273  
reports  
received by the Security 
Hotline in 2022

In 2022, the Security Hotline received 
15,273 reports.

Identified/prevented damage amounted 
to RUB 172.0 mln.

Members of the Company’s Board 
of Directors are updated on the Security 
Hotline operation on a quarterly basis.

The Corruption Control section 
on the official corporate website has:
 ● the Company’s statement on its zero 

tolerance for corruption;
 ● key provisions of Russian 

and applicable international anti-
corruption laws;
 ● internal documents 
on anti-corruption;

 ● Security Hotline contact details, etc.

36

37

Audit  
Commission

The Audit Commission monitors the Company’s financial and business 
activities and comprises five members elected on an annual 
basis by the Annual General Shareholders Meeting.

The Audit Commission audits 
the Company’s financial and business 
operations, verifies the accuracy 
and reliability of data included 
in Rosneft’s annual reports 
and annual accounting (financial) 
statements, and prepares proposals 
and recommendations for improving 
the asset management efficiency 
and RM&ICS.

In 2022, the Audit Commission held two 
meetings, which, among other things, 
adopted its action plan and approved 
an audit programme.

on the accuracy and reliability of data 
included in Rosneft’s Annual Report 
and annual accounting (financial) 
statements as at 31 December 2021.

The findings of the Audit Commission 
following the audit were communicated 
as part of the materials for the General 
Shareholders Meeting in the form 
of an opinion of the Audit Commission 

On 30 June 2022, the Annual General 
Shareholders Meeting resolved to elect 
the Audit Commission as follows:

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

MEMBERS OF THE AUDIT COMMISSION

Olga Andrianova

Born in 1958.
Graduated from the All-Russian State Distance-Learning Institute of Finance and Economics.
Holder of a ministerial award – Certificate of Merit of the Russian Ministry of Energy.
Chief Accountant – Head of Finance and Economics at JSC ROSNEFTEGAZ.

Sergey Poma

Born in 1959.
Graduated from Nakhimov Black Sea Higher Naval School and St Petersburg State University.
Vice President and Corporate Secretary of the National Association of Securities Market Participants (NAUFOR).

CHAIRMAN OF THE AUDIT COMMISSION

Mikhail Sorokin

Zakhar Sabantsev1

Born in 1974.

Born in 1990.
Graduated from the State University of Management.
Deputy Director of the Strategic Development Department of the Russian Ministry of Transport1.

Graduated from the Moscow State University of Economics, Statistics, and Informatics.

Holder of ministerial awards – Letter of recognition from the Minister of Finance of the Russian Federation (2007), 
For Excellent Work in Finance badge of the Ministry of Finance of the Russian Federation (2012).

Section Head, Bank Sector Monitoring, Consolidated and Analytical Work Section, Financial Policy Department, Ministry 
of Finance of the Russian Federation.

Aleksey Kulagin

Born in 1986.
Graduated from Lomonosov Moscow State University and Tula State University.
Holder of a ministerial award – Acknowledgement of the Russian Ministry of Energy.
Deputy Director of the Department of State Energy Policy of the Russian Ministry of Energy.

1.  On 17 January 2023, Zakhar Sabantsev voluntarily resigned from his position as a member of the Audit 

1.  At the time of election – Deputy Head of the Department of Property Relations and Privatisation of Major Organisations 

of the Federal Agency for State Property Management.

Commission.

38

39

Risk Management 
and Internal 
Control System

Rosneft has established and is continuously improving its Risk Management 
and Internal Control System (RM&ICS) aimed at proactive identification 
and analysis of risks that may impact the Company’s long-term targets 
as well as its ongoing financial and business operations.

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

The Company has in place processes 
to identify, assess and manage 
strategic risks that may hinder 
the delivery against long-term 

targets, financial and operational 
risks that affect the implementation 
of the Company’s current business 

plan, and business process risks 
that may hamper the Company’s ability 
to achieve business targets.

MAIN RISK GROUPS

Short-term targets

First-year targets outlined in  
the Company’s business plan

Medium-term and long-term targets
Targets outlined in  
the Company’s development strategy

1 year

3 years

5 years and longer

To develop a well-structured and integrated risk management and internal control system, 
the Company has put in place a multi-level regulatory framework in this area, which outlines key 
RM&ICS principles at various stages.

Corporate financial and  
operational risks

Strategic risks and  
strategic threats

Company policy

 ● Policy on the Risk Management 
and Internal Control System

Company 
standards

 ● Standard on Risk Management and Internal Control System
 ● Standard on the Corporate-Wide Risk Management 

System (CWRMS)

Company 
regulations

 ● Regulations on Design, Implementation 

and Maintenance of the Internal Control System

 ● Regulations on Market Risk Management
 ● Regulations on Development and Use 

of the Company-Wide Register of Standard Risks 
and Controls

Methodological 
guidelines

 ● Guidelines for Determining and Applying Risk 

Appetite

 ● Risk Assessment Guidelines

KEY PRINCIPLES

Principle of integration

Principle of continuity

Principle of optimality

Principle of separation 
of duties and powers

Principle of full 
responsibility

Principle of adaptability 
and RM&ICS 
enhancement

RM&ICS  
operating 
principles

Principle of reasonable 
assurance

Principle 
of methodological 
integrity

Principle of risk-oriented 
approach

Principle 
of reasonableness 
in formalising 
control procedures 
and documenting RM&ICS

The principles and objectives 
of the RM&ICS are set out 
in the Company’s Policy on the Risk 
Management and Internal Control 
System1 developed in accordance 

with the Russian regulatory 
requirements and drawing 
on recommendations of international 
firms engaged in risk management, 
internal control and audit services. 

These are intended to provide 
reasonable assurance that 
the Company will achieve its goals.

1.  Rosneft’s Policy on the Risk Management and Internal Control System No. P4-05 P-01 approved by the Company’s Board of Directors, 

Minutes No. 15 dated 13 December 2021.

40

41

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

RM&ICS stakeholders

Rosneft’s RM&ICS has various stakeholders whose roles are distributed depending 

on their involvement in developing, introducing and monitoring the performance 

of the system. The RM&ICS has three management levels.

Strategic level

Operational level

Board of Directors 
and Audit Committee 
of the Board of Directors

 ● Define RM&ICS principles 

and approaches

 ● Approve RM&ICS focus 
areas and follow up 
on their progress

 ● Approve corporate 
reports on financial 
and operational risks

 ● Approve risk appetite

 ● Make sure the RM&ICS 

performance is analysed 
and evaluated

 ● Monitor the RM&ICS 

reliability and performance

Chief Executive 
Officer

 ● Validates RM&ICS 

focus areas

 ● Validates RM&ICS 

reports

 ● Validates risk 

appetite

Risk Management 
Committee

 ● Validates 

the materi-
als for RM&ICS 
issues reported 
to the Chief 
Executive Officer

 ● Resolves RM&ICS 

operational 
disputes

Management

Security Service

 ● Distributes roles 

and responsibilities among 
employees

 ● Manages risks

 ● Develops and implements 

control procedures

 ● Conducts self-assessment 

of internal controls

 Risk and Internal Control 
Methodology Department

 ● Plans RM&ICS focus areas

 ● Develops, implements and updates 
Company-wide RM&ICS guidelines

 ● Prepares reports on risks 

and internal controls

 ● Manages the RM&ICS roll-out 

and operation across Rosneft’s 
business units and Group 
Subsidiaries

 ● Provides guidelines to key RM&ICS 
stakeholders, trains them in risk 
management and internal controls

 ● Develops, updates, 

and introduces internal 
anti-fraud and anti-cor-
ruption regulations 
and implementing 
documents

 ● Participates in ensuring 
compliance with internal 
regulations and imple-
menting anti-fraud 
and anti-corrup-
tion initiatives taken 
by Rosneft’s executive 
bodies

Business Units Providing 
Certain RM&ICS Functions

 ● Prepare and consolidate 

RM&ICS reports

 ● Manage the roll-out 
of RM&ICS elements 
and develop proposals 
for the risk management 
methodology

 ● Assist the Company’s 
management in con-
ducting self-assessment 
of internal controls

 ● Manages the Security 

Employees

Hotline

 ● Conducts inspections/
investigations into abu-
sive/unlawful prac-
tices by the Company’s 
employees and third 
parties

 ● Implement risk management 

controls and initiatives

 ● Assist the Company’s 

management in managing 
risks

 ● Help identify, assess 
and report on risks 
and internal controls, 
and conduct assessment 
of internal controls

RM&ICS 
independ-
ent monitoring 
and performance 
assessment

Internal Audit Service

 ● Monitors the RM&ICS 

reliability and performance

 ● Conducts audits

 ● Monitors the implementation 
of RM&ICS improvement 
proposals made by internal 
auditors

 ● Assists the Company’s 

executive bodies 
in investigating abusive/
unlawful practices 
by the Company’s 
employees and third parties

Audit Commission

 ● Audits the Company’s 
financial and business 
operations, verifies 
the accuracy and reliability 
of data included in Rosneft’s 
annual reports and annual 
accounting (financial) 
statements

42

43

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

RM&ICS enhancement

Owing to ongoing improvements in its RM&ICS, the Company can promptly 

respond to changes in the external environment and internal business processes, 

achieve better performance, and increase its shareholder value.

RM&ICS enhancement highlights for 2022

RM&ICS enhancement initiatives

Results

Development and improvement 
of guidelines on the Risk 
Management and Internal Control 
System

 ● Standard on Risk Management and Internal Controls 

was successfully developed

Development and implementation 
of an RM&ICS training programme 
for the employees of Rosneft 
and Group Subsidiaries

 ● Risk and internal control experts at RM&ICS business units 
of Rosneft and Group Subsidiaries underwent training

 ● The existing risk management and internal control distance 
course was updated and made available on the corporate 
intranet portal

Enhancement of the risk assessment 
framework leveraging economic 
and mathematical models and expert 
reviews

 ● The Company’s quantitative risk assessment models 

were verified (back-tested)

 ● Methodological guidelines were approved on the assessment 
of the risk of loss of rights to real estate as a result of non-
existent/incomplete documents of title or claims of third parties

Implementing and maintaining 
the Internal Control System

 ● A self-assessment of the Company’s internal control was carried 
out, including the evaluation of control procedures conducted 
as part of a plan for testing their implementation

 ● A plan for developing, implementing and maintaining the Internal 
Control System was approved by the top manager in charge

Improving the RM&ICS processes 
across Group Subsidiaries

 ● The Corporate-Wide Risk Management System 
was implemented by seven Group Subsidiaries

Key targets 
and objectives 
of the RM&ICS 
enhancement, 
as well as critical 
steps to achieve 
them, are set out 
in the RM&ICS 
Enhancement Plan, 
which is subject 
to approval 
by the Company’s 
Chief Executive Officer 
and Board of Directors.

44

45

Internal Control  
System 

Corporate-Wide Risk  
Management System

THE INTERNAL CONTROL SYSTEM (ICS) IS AN INTEGRAL PART OF THE RM&ICS

KEY COMPONENTS OF THE CORPORATE-WIDE RISK MANAGEMENT SYSTEM (CWRMS)

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

To achieve the ICS objectives, the Company needs to:

5

.

R

E

P

O

R

T

I

N

G

 ● The both systems have aligned goals.

 ● The ICS is governed by the Company’s Policy on the Risk Management and Internal Control System, 
Standard on Risk Management and Internal Controls, and Regulations on Design, Implementation 
and Maintenance of the Internal Control System.

 ● The Company relies on the above internal documents to identify risks inherent in its business processes 
and develop and implement controls, thus improving manageability and efficiency across business 
processes, reliability of financial statements, and compliance with the applicable laws and internal 
regulations.

Define and update key ICS focus areas in alignment 
with the Company’s needs and stakeholder requirements

Assess business process risks, develop, adopt and follow 
controls, including the development of uniform guidelines 
to support efficient ICS operations

Identify shortcomings in existing controls, develop 
and implement initiatives to address the same, streamline 
and upgrade controls

Develop and implement tools to facilitate communication 
and information sharing among all RM&ICS stakeholders, 
including via information systems

The Company’s 
management 
and employees ensure 
the ICS efficiency 
by managing 
the relevant functions 
and performing their 
job duties.

1

2

3

4

46

NITO RIN G                 

O
K M
. RIS

6

  A N N UAL PLANNING 

  1 .

               2

. 

R

Ongoing  
enhancement of the 
CWRMS  
infrastructure and 
process

Regulations  
and policies

Interfaces between 
the CWRMS  
and other  
processes

Distribution  
of roles  
within the CWRMS

I

S

K

I

D

E

N

T

I

F

I

C

A

T

I

O

N

T
N
E
M
S
S
E

                     3. RISK ASS

4. RESPONDING TO   R I S K S  

Risk management at Rosneft 
is governed by the Company’s Policy 
on the Risk Management and Internal 
Control System1, Standard on Risk 
Management and Internal Controls2 
and Standard on the Corporate-Wide 
Risk Management System3.

The CWRMS is a combination 
of interrelated elements embedded 
into various business processes 
of the Company (including strategic 
and business planning processes) 
and implemented at all management 
levels by all employees of the Company.

As part of CWRMS, our management 
(at various organisational levels, 
including the Group Subsidiaries 
and the Company) regularly identifies 
and assesses risks and develops 
response measures covering, among 
others, risks that affect the Company’s 
long-term goals (strategic risks) along 
with financial and operational risks. Risk 
reports including all the information 
on risks, their assessment 
and description of mitigants 
are submitted to the Board of Directors, 
its Audit Committee, Company’s top 
management and employees.

Risk management process

A combination of risk 
management elements supported 
by the existing organisational 
structure, internal policies 
and regulations, risk management 
procedures and techniques, 
which are applied across all 
management levels and functions 
of the Company to make its 
risks acceptable in the context 
of achieving Rosneft’s strategic 
goals

Risk management 
infrastructure

A set of elements that provide 
a Company-wide basis, 
tools, and framework for risk 
management

Heads of the Company’s business units 
arrange for, and steer risk management 
processes within their remit. When 
choosing a risk response and specific 
mitigants, risk owners seek to find 
an optimal trade-off while maintaining 
an acceptable risk level (risk appetite).

1.  Rosneft’s Policy on the Risk Management and Internal Control System No. P4-05 P-01 approved by Resolution of the Company’s Board 

of Directors, Minutes No. 15 dated 13 December 2021.

2.  Rosneft’s Standard on Risk Management and Internal Controls No. P4-05 S-0028 approved by Resolution of the Company’s Management 

Board No. Pr-IS-09p dated 31 March 2022.

3.  Rosneft’s Standard on Corporate-Wide Risk Management System No. P4-01 P-01 approved by Resolution of the Company’s Management 

Board No. 660 No. Pr-IS-36p dated 28 September 2018.

47

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
Rosneft’s risks

INDUSTRY-WIDE RISKS

 ● Risk of accidents
 ● Risk of fatal injuries
 ● Risk of failure to achieve oil and gas 
condensate production targets

 ● Risk related to rising purchase prices 

for electric power

 ● Risk of penalties for the quality of gas 

fed into transportation systems

 ● Risk of lower quality of refinery 

 ● Risk of failure to achieve natural 

feedstock

 ● Risk of failure to comply 

with the repair plan in oil refining 
and petrochemicals

 ● Risk of accumulation of unclaimed 
liquid and non-liquid inventories

gas and gas condensate production 
targets

 ● Risk of failure to achieve planned 

volumes of bulk wholesale 
of crude oil, petroleum products, 
gas processing products, 
and petrochemicals

FINANCIAL RISKS

 ● Risk of tax claims and risk of losing tax benefits
 ● Market risks
 ● Risk of an increase in overdue receivables
 ● Risk of default/cross-default

EXTERNAL CONSTRAINTS

LEGAL RISKS

 ● Risk of breach of competition 

laws

 ● Litigation risk

CHANGES IN LEGISLATION 
AND REGULATORY 
ENVIRONMENT

Since 2014, the USA, EU 
and some other countries have 
been imposing various economic 
constraints on the Russian 
Federation, among other things, 
affecting operations of certain 
companies in the Russian 
energy and other industries 
(including Rosneft and some of its 
subsidiaries). In 2022, the Company 
was under considerably increased 

sanctions pressure. However, 
Rosneft factors in and continuously 
monitors existing constraints 
to minimise their adverse effects, 
and consistently implements its 
Import Substitution and Equipment 
Localisation Programme 
in Russia, expands cooperation 
with companies from friendly 
countries, and redistributes its 
commodity flows.

The Company’s operating results 
are very sensitive to changes 
in the applicable laws, including tax, 
currency and customs regulations, 
etc. Rosneft continuously monitors 
and assesses such changes, and makes 
projections as to their likely effect 
on the Company’s operations. Rosneft’s 
experts are regular members of working 
groups drafting bills in various fields 
of law.

Risk appetite of the Company

The following risk appetite 
indicators were approved for 2022: 

Financial and economic 
performance
The Company strictly complies 
with its financial covenants. 
The Company ensures that all its 
short- and long-term commitments 
are fulfilled as they fall due.

Health, safety, environment
Recognising the nature and scale 
of the footprint of its business, 
products and services, the Company 
feels responsible for safe 
and accident-free operation 
and protects health and safety 
of its employees and local residents 
in regions of its operation. As part 
of its commitment to preventing 
any potential adverse impact 

on the environment, the Company 
makes every effort to protect, 
preserve and restore natural 
resources. 

Corporate governance
The Company has zero tolerance 
for any form or manifestation 
of corporate fraud and corruption.

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

analysis and statistical approaches. 
The assessment horizon 
and the metrics used depend 
on the way specific targets are set out 
in the Strategy. The results are then 
consolidated using the probability 
theory and mathematical statistics 
methods to identify the key strategic 
threats, assess strategic risks 
and develop measures to mitigate them.

ESG risks

Rosneft is fully aware of the importance 
and impact of sustainability risks, 
including ESG, on the Company’s 
business. Our commitment 
to sustainable business principles 
was further highlighted in the new 
Rosneft–2030 Strategy. It seeks 
to reduce the Company’s carbon 
footprint and boost its operational 
and financial efficiency. The Strategy 
will help solidify Rosneft’s position 
in the global hydrocarbon market 
as a reliable producer and supplier 
of energy, minimising its environmental 
and climate impact. Rosneft aims 
to achieve carbon neutrality by 2050 
with respect to Scope 1 and 2 
emissions. To accomplish this 
goal, the Company plans to reduce 
emissions, leverage low-carbon 
generation, develop energy-
saving, carbon capture and storage 
technologies, and promote natural 
absorption.

We analyse sustainability risks as part 
of the effort to identify and assess risks 
that can affect the Company’s long-
term goals (strategic risks and threats). 
The annual process to identify 
and assess (prioritise) strategic risks 
and threats takes into account Russian 
and international research on the oil 
and gas industry development, 
and is based on the Company’s 
strategic targets as set out in its 
development strategy. Following this 
analysis, we determine a list of strategic 
threats that can potentially impact 
the Company’s ability to achieve its 
strategic goals. This list also includes 
threats related to various aspects 
of sustainable development.

Rosneft’s management evaluates 
the impact of strategic threats 
(including those related to sustainable 
development) on the Company’s 
strategic targets using expert 

STRATEGIC THREATS RELATED TO SUSTAINABLE DEVELOPMENT

Environmental

Social

Corporate governance

 ● Accidents and environmental 

damage

 ● Advance of alternative energy 
and green technologies and 
improvements in energy 
efficiency

 ● Changes in the structure 
of energy consumption

 ● Natural disasters

 ● Climate change in the regions 
where the Company operates

 ● Epidemics 

and diseases

 ● HR and social risks

 ● Armed conflicts, 
terrorism, civil 
disturbance

 ● Safety of critical 

facilities

 ● Cyber security

 ● Deterioration of the tax 

regime

 ● Tighter regulation 
and requirements 
in the industry

 ● Stricter regulation and 
requirements related to 
climate change. New 
climate initiatives

 ● Reputation and less 

appealing investment case

48

49

 
ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Internal audit

In 2022, Rosneft’s Internal Audit Service was governed by the Company’s Policy on Internal Audit, Code 

of Ethics of the International Institute of Internal Auditors and international practices of internal audit.

The Internal Audit Service assists 
Rosneft’s Board of Directors 
and the executive bodies of Rosneft 
and Group Subsidiaries in enhancing 
the Company’s management 
efficiency and improving its financial 
and business performance, including 
through a systematic and consistent 
approach to the analysis and evaluation 
of the RM&ICS as well as corporate 
governance, therefore providing 

reasonable assurance that 
the Company will achieve its goals.  
It also helps ensure:

 ● accuracy, reliability, and integrity 
of information on the Company’s 
financial and business operations, 
including those of Group Subsidiaries;

 ● efficiency and effectiveness 
of the Company’s operations, 
including those of Group Subsidiaries;

 ● room for improvement available 
across the Company’s financial 
and business operations, including 
those of Group Subsidiaries;

 ● integrity of the Company’s 

assets, including those of Group 
Subsidiaries.

Reporting and accountability 
lines of internal audit

Functionally and administratively, the Internal Audit Service reports to Rosneft’s 

Board of Directors and Chief Executive Officer respectively.

The existing reporting lines 
whereby the Head of Internal Audit 
reports to the Board of Directors 
and the Company’s executive bodies 
provide sufficient independence 
for performing internal audit 
functions.

Heads of the Internal Audit functional 
units do not participate in managing 
functional areas of the Company’s 
business requiring management 
decisions on audited entities.

The Head of Internal Audit provides 
Rosneft’s Chief Executive Officer, 
Board of Directors (its Audit 

Committee) with confirmation 
of the organisational independence 
of the Internal Audit Service 
and individual impartiality of internal 
auditors at least once a year, as part 
of the internal audit performance 
report.

Functional units of Rosneft’s Internal Audit 
Service are mainly responsible for:

developing an internal audit plan based on the risk-oriented 
approach;

assessing the RM&ICS reliability and performance 
as well as its adequacy given the scale and complexity 
of the Company’s business;

assessing corporate governance;

conducting audits and activities in line with the internal 
audit plan approved by Rosneft’s Chief Executive Officer 
and endorsed by the Board’s Audit Committee;

performing other inspections and tasks as instructed 
by Rosneft’s Board of Directors (its Audit Committee) and/
or the Company’s Chief Executive Officer;

monitoring the Company’s progress in addressing breaches 
and shortcomings identified during internal audits;

performing other functions essential to meet the tasks 
assigned.

Rosneft’s internal audit 
function is performed 
by the Vice President – 
Head of the Internal Audit 
Service (Head of Internal 
Audit) and functional 
units of the Internal Audit 
Service. In accordance 
with Rosneft’s 
organisational structure, 
units of the Internal Audit 
Service report directly 
to the Head of Internal 
Audit.

Internal Audit Quality Assurance 
and Improvement Programme

In order to ensure proper quality control and performance evaluation of internal audit, the Internal 

Audit Quality Assurance and Improvement Programme was developed and put in place. 

To deliver against the Programme’s 
targets, a regular in-house self-
assessment of the internal audit quality 
was conducted in 2022. It was concluded 
following the self-assessment that 
the internal audit function was generally 
in line with the requirements 
of the Company’s Policy on Internal 
Audit and other regulations on internal 
audit, the International Standards 
for the Professional Practice of Internal 
Auditing, and the Code of Ethics 
of the International Institute of Internal 
Auditors.

In 2022, the risk-oriented internal audit 
plan was implemented in full.

audit of the reliability and effectiveness 
of the RM&ICS and also other internal 
audit inspections conducted in 2022.

The Head of the Internal Audit 
Service prepared a report 
on the internal audit performance 
for 2022 and submitted it 
to Rosneft’s Board of Directors 
and its executive bodies.

In accordance with Federal 
Law No. 208-FZ On Joint-Stock 
Companies, an internal audit opinion 
was developed following a mandatory 

Following the 2022 reliability 
and effectiveness assessment 
of RM&ICS, the Internal Audit 
Service concluded that the RM&ICS 
ensured overall support of the risk 
management process and efficient 
internal control system, providing 
reasonable assurance that 
the Company would achieve its 
goals.

50

51

Shareholder relations, 
key events in 2022

The Company has established a multi-level system to protect the rights of its shareholders.

Shareholder rights guaranteed by law

Pursuant to the Russian laws, 
the Company’s shareholders have 
the right to:

 ● vote at the General Shareholders 
Meeting on a one-share-one-vote 
basis;

 ● propose items for the agenda 
of the General Shareholders 
Meeting and nominate candidates 

to the Board of Directors  
(if a shareholder owns at least  
2% of voting shares);

 ● exercise pre-emptive right to buy 

shares in any future issue and issue-
grade securities convertible 
into shares;

 ● receive dividends declared 

by the Company, in proportion 
to the number of shares held;

 ● review information and materials 

provided in preparation 
for the General Shareholders 
Meeting;

 ● obtain information on the Company’s 

operations upon request 
and as established by the Russian laws;

 ● freely dispose of Rosneft’s shares;
 ● exercise other rights granted under 

the Russian law.

Additional rights guaranteed by the Company’s 
Charter and internal regulations

The Company offers equal and fair 
opportunities for its shareholders 
to exercise their legal rights by securing 
additional rights and procedures 
in the Charter and internal regulations, 
including the right to:

 ● receive part of the Company’s profit 

 ● participate in managing 

as dividend;

the Company’s operations.

 ● receive necessary information 
on the Company on a timely 
and regular basis;

Independent and professional Board of Directors

The composition of the Board 
of Directors and the number of Board 
members reflect the Company’s 
shareholding structure.

Electing Board members 
by cumulative voting guarantees 
the rights and legitimate interests 
of shareholders.

The Board of Directors consists 
of four independent directors 
of internationally recognised 
business standing.

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Official channels of communication 
with shareholders

The Company has established efficient 
means of communicating with its 
shareholders.

 ● Shareholder account  

 ● email for requests:  

on 

 the Company’s website;

 shareholders@rosneft.ru;

 ● 24 hour shareholder Hotline 

 ● fax: +7 (499) 517-86-53.

The Company has several 
communication channels in place 
to facilitate the exercise of corporate 
rights and promote efficient 
shareholder relations, including:

(a multichannel phone line to receive 
and handle calls):  
8 (800) 500-11-00 (toll free within 
Russia) and +7 (495) 987-30-60;
 ● mailing address for letters: 26/1 

Sofiyskaya Embankment, Moscow, 
117997, Russia;

Shareholder’s Personal Account

Shareholder’s Personal Account enables all Rosneft shareholders, regardless of where their shares are kept, 
to take part in the General Shareholders Meeting online: register, vote on the agenda items, review information 
for the meeting, and ask their questions to the speakers.

All Rosneft shareholders of record also can:
 ● receive updates on their accounts in the register of shareholders online;
 ● use the registrar’s services remotely (request and receive certificates, extracts, and notices) and pay 

for them online;

 ● monitor accrued dividends;
 ● request and receive 2-NDFL earnings certificates in a convenient way;
 ● exercise their rights in relation to several Shareholder’s Personal Accounts within one session (one 

account).

Shareholders can log into their personal accounts at: 

 https://lka.rosneft.ru/auth/?authLg=en

To gain access to their Shareholder’s Personal Account, shareholders need to request login and password from 
the Moscow Head Office or regional branches of the Company’s registrar, Reestr-RN LLC.

The rules governing the procedure of registering 
a Shareholder’s Personal Account can be found 
on the website of Reestr-RN LLC or on the Company’s 
website. Any questions concerning access 
to the Shareholder’s Personal Account can be addressed to:

 ● Reestr-RN LLC call centre by phone: +7 (495) 411-79-11 

(email: 

 support@reestrrn.ru);

 ● Hotline for Rosneft shareholders at: 8 (800) 500-11-00 

(toll free within Russia) and +7 (495) 987-30-60;  
(email: 

 shareholders@rosneft.ru).

In 2022, the Corporate Governance Department handled 5,278 applications, including:

3,994  

phone calls 

630  

letters

178  

emails

476  

requests claiming unpaid dividends 
for prior periods

Answers to frequently asked questions can be found on 

 the Company’s website.

52

53

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Protecting shareholders’ title to shares 

Corporate Secretary

The Company practices reliable and safe methods of recording title to its shares 

and has engaged a professional registrar to maintain its Shareholder Register.

The registrar, Reestr-RN LLC, 
registers holders of securities 
in Rosneft, more than 
100 issuers within the Group, 
and over 1.4 thousand joint-stock 
companies from various industries.

Reestr-RN LLC consistently ranks 
among the top ten Russian registrars, 
records rights to shares of more 
than half a million security holders, 
actively develops digital customer 

services, and maintains a network 
of 13 branches and 45 transfer agent 
offices, which operate in the regions 
where the majority of the Company 
shareholders reside.

The Company, together 
with Reestr-RN LLC, regularly 
notifies its shareholders of the need 
to update their personal data 
recorded in the Shareholders Register 
of Rosneft.

 Resolutions  
of the General 
Shareholders Meeting

 Regulation 
on Provision 
of Information 
to Rosneft 
Shareholders

 Contact details 

of the registrar and its 
service offices

The Corporate Secretary of Rosneft oversees the Company’s compliance with applicable 

laws, as well as Rosneft’s Charter and internal regulations ensuring execution 

of the rights and legal interests of the Company’s shareholders and successful interaction 

with shareholders, supports the Board of Directors’ performance, and refines corporate 

governance practices in line with shareholders’ and other stakeholders’ interests.

The Corporate Secretary 
reports to the Board of Directors 
and is appointed and dismissed 
by the Chief Executive Officer 
on the basis of the Board of Directors’ 
resolution.

The Corporate Secretary acts 
as the Board of Directors secretary 
and the General Shareholders Meeting 
secretary.

As part of their function to ensure 
Rosneft’s shareholder relations 
and prevent corporate conflicts, 
the Corporate Secretary coordinates 
activities to implement procedures 
required under the laws of Russia 
and Rosneft’s internal regulations 
with a view to executing the rights 
and legal interests of shareholders 
and controlling the same, 
as well as overseeing the execution 

of rights and property interests 
of shareholders in decision-making 
by Rosneft’s governing bodies.

The Corporate Secretary engages 
in actions required to prevent abuse 
of rights by all the parties involved 
in corporate relations, identifies 
potential corporate conflicts early on, 
and steps in to prevent and resolve 
them.

54

55

Dividend Policy

The Dividend Policy approved by the Board of Directors formalises the Company’s 
key principles of, and approaches to, dividend payouts to shareholders 
and introduces transparent decision-making processes for paying out 
(declaring) dividends and determining their amount and payment procedure.

In 2022,  
the Company  
made no changes  
to its 
Policy.

 Dividend 

Principles of the Dividend Policy:

 ● ensuring compliance with the requirements 
of the Russian laws, the Company’s Charter 
and internal regulations when paying out 
(declaring) dividends;

 ● maximising the transparency of the dividend 

calculation process;

 ● increasing the Company’s investment appeal;

 ● maintaining the balance of short- and long-term 

interests of shareholders;

 ● supporting shareholder commitment to improving 

the Company’s profitability;

 ● ensuring that the dividend payout pattern 

comfortably reflects an increase in Rosneft’s net 
profit;

 ● making dividend payments in a way most 

convenient for our shareholders;

 ● paying out dividends as soon as practicable.

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

The decision to pay dividends is made by the General Shareholders 
Meeting upon recommendation of the Board of Directors.

In 2022, the Company discharged 
99.98% of its obligation to pay out 
dividends. Dividends were paid 
to all shareholders of record, except 
for persons who failed to timely notify 
the issuer’s registrar of changes 
in the data recorded on their profile.

The Company’s Charter provides 
for a five-year period when 
shareholders may claim dividends 

declared but not paid due to missing 
address or banking details, 
which is longer than required 
by the applicable laws.

A total of RUB 216.1 bln was allocated 
by Rosneft to paying its interim 
dividends for the first half 
of 2022, which represents 50% 
of the Company’s IFRS net income 
attributable to Rosneft shareholders.

In 2022, the Company  
paid dividends for FY2021 
in the amount of  

RUB  
250.4  
bln 

The interim dividends were not due 
as at 31 December 2022.

On 25 May 2023, the Board of Directors 
recommended that the General 
Shareholders Meeting approve 
RUB 17.97 per share as dividend 
for FY2022. The total amount 
of dividends recommended for FY2022, 
including the interim dividends paid 

in 2023, is RUB 406.5 bln or RUB 38.36 
per share1. The dividend payout ratio 
calculated as dividends divided by non-
consolidated net income under RAS 
for 2022 is 90.3%, while the dividend 
payout ratio calculated as dividends 
divided by consolidated net income 
under IFRS is 50% of the Company’s 
IFRS net income attributable to Rosneft 
shareholders.

In 2022, 

the Extraordinary General 
Shareholders Meeting resolved 
to pay interim dividends

 Dividends 

section on 
Rosneft’s website

ROSNEFT’S DIVIDEND HISTORY

RUB bln

500

400

300

200

100

0

%

50

40

30

20

10

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

2021

2022

7.53

8.05

12.85

8.21

11.75

5.98

10.48

25.91

33.41

6.94

41.66

38.36

Dividend payout ratio under IFRS, %

FY dividends, RUB bln
1H dividends, RUB bln

Dividend per share, RUB

FY dividend per share, RUB

7.53 – Dividend per share for the period, RUB

1. 

Including the interim dividends and the dividends recommended by the Board of Directors to be approved at the Annual General 
Shareholders Meeting in 2023.

56

57

 
 
APPENDICES

Report on compliance 

with the principles 

and recommendations 

of the Corporate 

Governance Code

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

This report on compliance 
with the principles 
and recommendations of the Corporate 
Governance Code (the Report) 
was reviewed by Rosneft’s Board 
of Directors at a meeting held  
on 25 May 2023 (Minutes  
No. 20 dated 29 May 2023) as part 
of the 2022 Annual Report.

The Board of Directors certifies 
that this Report contains complete 
and reliable information on Rosneft’s 
compliance with the principles 
and recommendations of the Corporate 
Governance Code in 2022.

Rosneft assesses its compliance 
with the Corporate Governance Code 
as per the guidelines recommended 
by the Bank of Russia in Letter 
No. IN-06–28/102 on Disclosure 

of Compliance with the Principles 
and Recommendations of the Corporate 
Governance Code in the Annual Report 
of a Public Joint-Stock Company 
dated 27 December 2021. Key 
aspects of the Company’s corporate 
governance model and practice 
are outlined in Section Corporate 
governance of Rosneft’s 2022 Annual 
Report.

No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

1
Status 
of compliance 
with a corporate 
governance 
principle

2
Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

1.1. The Company shall ensure equitable and fair treatment of all shareholders 
exercising their right to participate in managing the Company

To maintain effective relations 
with shareholders, Rosneft provides 
the following communication 
channels: a shareholder hotline, mail 
and email, fax.
The Company does not consider 
setting up a dedicated online forum, 
as it has other communication 
channels in place, as well as provides 
for the opportunity to discuss 
agenda items at General 
Shareholders Meetings and, if 
relevant, using Rosneft’s social 
networks, which are mentioned 
on Rosneft’s official website

Complied with
Complied with in part
Not complied with

Complied with
Complied with in part
Not complied with

1.1.1

1.1.2

The Company 
provides the best 
possible conditions 
for shareholders 
to participate 
in General 
Shareholders 
Meetings, make 
informed decisions 
on agenda items, 
coordinate their 
actions and express 
their opinions 
on matters under 
consideration

The procedure 
to notify 
shareholders 
of a General 
Shareholders 
Meeting and provide 
them with relevant 
materials enables 
them to get 
well-prepared

1.  The Company provides an easily 

accessible communication channel, 
such as a hotline, email or online forum, 
for shareholders to express their 
opinions and put questions regarding 
the agenda in preparation for a General 
Shareholders Meeting.  
The Company provided such 
communication channels and made 
them available to shareholders before 
every General Shareholders Meeting 
held in the reporting period

1. 

In the reporting year, the notice 
of a General Shareholders 
Meeting was posted (published) 
on the Company’s website at least 
30 days prior to the date of the Meeting, 
unless the applicable law established 
a longer period.

2.  The notice specified the documents 

required for admission to the Meeting 
venue.

3.  Shareholders were informed about 
the persons who proposed agenda 
items and nominated candidates 
to the Company’s Board of Directors 
and Audit Commission (if the Company’s 
Charter required establishing such 
Commission)

1.  The “complied with” status is assigned only if the Company’s corporate practice meets all the criteria for compliance with a corporate 

governance principle set out in the third column of the form to be used for reporting on compliance with the Code’s principles. If 
the Company’s corporate practice meets only some of the compliance criteria or none of them, the “complied with in part” or “not 
complied with” status is assigned in the fourth column of the form to be used for reporting on compliance with the Code’s principles.
2.  Explanations are given for each criterion for compliance with a corporate governance principle (assessment criterion) if the Company 

meets only some of the criteria or none of them.

58

59

  
  
  
  
  
ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

When preparing 
for and participating 
in a General 
Shareholders Meeting, 
shareholders have 
unrestricted and timely 
access to any relevant 
information 
and materials, 
and are able 
to put questions 
to the Company’s 
executive bodies 
and directors, 
as well as communicate 
with one another

1. 

In the reporting period, shareholders 
had the opportunity to put questions 
to the Company’s executive bodies 
and directors both before and during 
the General Shareholders Meeting.

2.  The Board of Directors’ opinions 

(including dissenting opinions (if any) 
recorded in the minutes) on each 
of the agenda items of the General 
Shareholders Meetings held 
in the reporting period were added 
to the Meeting materials.

3.  The lists of persons entitled to participate 
in each General Shareholders Meeting 
in the reporting period were made 
available to the shareholders 
eligible to review such lists 
as soon as the Company received those

There are no 
unjustified difficulties 
preventing 
shareholders from 
exercising their rights 
to convene a General 
Shareholders Meeting, 
nominate candidates 
to the governing 
bodies and propose 
items for the agenda

1.  The Charter enables shareholders 
to propose items for the agenda 
of the Annual General Shareholders 
Meeting during at least 60 days after 
the end of the respective calendar year.

2.  In the reporting period, the Company 

rejected no item proposed 
for the agenda and no candidate 
to the Company’s bodies due 
to misprints or other minor flaws 
in shareholders’ proposals

Status 
of compliance 
with a corporate 
governance 
principle

Complied with
Complied with in part
Not complied with

Complied with
Complied with in part
Not complied with

Each shareholder is able 
to exercise their voting 
right without hindrance, 
in the simplest and most 
convenient way

1.  The Company’s Charter enables 

shareholders to fill out an electronic 
voting ballot on the website specified 
in the notice of a General Shareholders 
Meeting

Complied with
Complied with in part
Not complied with

Complied with
Complied with in part
Not complied with

Explanation on items 1–3: no 
General Shareholders Meetings 
were held in the form of a meeting 
(joint presence of shareholders) 
during the reporting period in line 
with Federal Law No. 25-FZ 
of 25 February 2022 On Amending 
the Federal Law On Joint-Stock 
Companies and Suspending Certain 
Provisions of Legislative Acts 
of the Russian Federation.
Explanation on item 4: the Company 
has the Corporate Governance 
analytical information system 
in place. It enables shareholders 
to vote online and interact 
with the Company and the registrar 
via Shareholder’s Personal Account

The procedure 
for holding a General 
Shareholders 
Meeting established 
by the Company 
provides all 
persons present 
at the Meeting 
with equal 
opportunities 
to express their 
opinions and ask 
questions

1. 

In the reporting period, sufficient 
time for reporting on and discussing 
agenda items was provided at General 
Shareholders Meetings held 
in the form of a meeting (joint presence 
of shareholders), with shareholders having 
an opportunity to express their opinions 
and ask questions on agenda items.
2.  The Company extended invitations 

to the candidates nominated 
to the Company’s governing 
and supervisory bodies and took all 
the necessary steps to make sure they 
participate in the General Shareholders 
Meeting convened to vote on their 
candidacies. During the Meeting, 
candidates to the Company’s governing 
and supervisory bodies were available 
for questions from the shareholders.
3.  The sole executive body, the officer 

in charge of accounting, the Chairman 
or other members of the Board’s 
Audit Committee were all available 
for questions from the shareholders 
during the General Shareholders 
Meetings held in the reporting period.
4.  In the reporting period, the Company 
used telecommunications equipment 
to provide shareholders with remote 
access to participate in the General 
Shareholders Meetings, or the Board 
of Directors made a well-informed 
decision to abstain from using such 
equipment in the reporting period due 
to its irrelevance (unavailability)

1.1.3

1.1.4

1.1.5

1.1.6

60

1.2. Shareholders are provided with an equitable and fair opportunity to receive 
a share of the Company’s profits in the form of dividends

1.2.1

The Company 
has developed 
and implemented 
a transparent 
and clear procedure 
to determine 
the amount 
of dividends and pay 
them out

Complied with
Complied with in part
Not complied with

1.  Regulations on the Company’s 

Dividend Policy have been approved 
by the Board of Directors and disclosed 
on the Company’s website.

2.  If, in accordance with the dividend 

policy of a company issuing 
consolidated financial statements, 
the amount of dividends is determined 
based on the company’s results 
recorded in its financial statements, 
the dividend policy shall employ 
the consolidated financial statements.
3.  In the reporting period, substantiation 

of the suggested net income 
distribution arrangements, including 
dividend payments and allocations 
for the Company’s own needs, 
and their assessment for compliance 
with the Company’s dividend 
policy (including explanations 
and the economic rationale 
for allocating part of the net income 
to cover the Company’s own needs) 
were included in the materials 
for the General Shareholders Meeting 
set to consider income distribution 
(including dividend payments / dividend 
declaration)

1. 

In addition to statutory restrictions, 
the Regulations on the Company’s 
Dividend Policy define financial/
economic circumstances under 
which the Company shall not pay out 
dividends

Complied with
Complied with in part
Not complied with

1.2.2

The Company does 
not resolve to pay 
out dividends if 
such resolution, 
though not in breach 
of the legislation, 
is not economically 
viable and may 
lead to false 
assumptions about 
the Company’s 
operations

Explanation on item 3: the Company 
has approved a Rosneft Dividend 
Policy. In line with this Policy, 
the Company shall distribute at least 
50% of its net income recorded 
in the IFRS consolidated financial 
statements (subject to Resolution 
of the Government of the Russian 
Federation No. 774-r dated 29 May 
2006). The Board of Directors also 
works to establish if it is possible 
to pay out dividends in the amount 
determined pursuant to the Rosneft 
Dividend Policy and includes 
the relevant analysis in the Meeting 
materials.
In accordance 
with recommendations approved 
by the Bank of Russia with respect 
to the disclosure of a report 
on compliance with the principles 
and recommendations 
of the Corporate Governance Code 
in the annual report of a public joint-
stock company (Bank of Russia’s 
Letter No. IN-06–28/102 dated 
27 December 2021), the Company 
included explanations of the Board 
of Directors on allocating part 
of the Company’s income 
for certain needs in the materials 
for the General Shareholders 
Meeting set to consider income 
distribution (for 2022)

Pursuant to Resolution 
of the Government of the Russian 
Federation No. 774-r dated 29 May 
2006, the Rosneft Dividend 
Policy sets the target dividend 
at no less than 50% of Rosneft’s 
IFRS net income. Said Resolution 
of the Government contains no 
restrictions (in addition to statutory 
restrictions) on a resolution to pay no 
dividends.
In accordance 
with recommendations 
approved by the Bank of Russia 
with respect to disclosure 
of compliance with the principles 
and recommendations 
of the Corporate Governance Code 
in the annual report of a public joint-
stock company (Bank of Russia’s 
Letter No. IN-06–28/102 dated 
27 December 2021) and clause 
2.2.3 of the Rosneft Dividend Policy 
the Company included explanations 
of the Board of Directors 
on the absence of any financial 
limitations on dividend payments 
in the materials for the General 
Shareholders Meeting set 
to consider income distribution 
(for 2022)

61

  
  
  
  
  
  
  
  
  
  
No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

1.2.3

1.2.4

The Company 
does not allow 
any negative 
changes 
in the dividend 
rights of its current 
shareholders

The Company 
makes every 
effort to prevent 
shareholders 
from receiving 
profit (gain) from 
the Company other 
than in the form 
of dividends 
and liquidation value

1. 

In the reporting period, the Company 
did not perform any actions causing 
negative changes in the dividend rights 
of its current shareholders

Complied with
Complied with in part
Not complied with

Complied with
Complied with in part
Not complied with

1. 

In the reporting period, persons 
controlling the Company did not use 
any means to receive profit (gain) from 
the Company other than in the form 
of dividends (for example, by resorting 
to transfer pricing, unjustifiably 
rendering services to the Company 
at inflated prices, or using internal loans 
issued to controlling persons and/or 
their controlled entities as a substitution 
for dividends)

1.3. Corporate governance framework and practices ensure equality of all shareholders owning shares of the same 
class (type), including minority and foreign shareholders, and their equitable treatment by the Company

1.3.1

1.3.2

The Company 
ensures fair 
treatment of each 
shareholder by its 
governing bodies 
and controlling 
persons, specifically 
allowing no 
abuse of minority 
shareholders 
by major 
shareholders

The Company 
does not perform 
any actions 
that will or may 
result in artificial 
redistribution 
of corporate control

1. 

In the reporting period, persons 
controlling the Company did not 
abuse the rights of the Company’s 
shareholders, and there were no 
conflicts between persons controlling 
the Company and the Company’s 
shareholders (or even if there were any, 
the Board of Directors gave such 
conflicts due consideration)

Complied with
Complied with in part
Not complied with

1.  The Company has no quasi-treasury 
shares, or no quasi-treasury shares 
were used in voting during the reporting 
period

Complied with
Complied with in part
Not complied with

Pursuant to the Russian 
Government’s resolution, Rosneft 
signed an agreement with a 100% 
government-owned company 
to sell all of Rosneft’s interests 
and cease participation in all of its 
projects in Venezuela, including 
the joint ventures of Petromonagas, 
Petroperija, Boqueron, Petromiranda 
and Petrovictoria, as well as oilfield 
services companies, commercial 
and trading operations.
Based on the agreement, all Rosneft 
assets and trading operations 
in Venezuela and/or those 
with connection to Venezuela have 
been disposed of, terminated or 
liquidated.
The agreement and the sale 
of assets resulted in Rosneft’s 
wholly-owned subsidiary receiving 
a 9.6% stake in its parent company.
In addition, the Company’s Open 
Market Share Buyback Programme, 
which also covers GDRs, saw its 
100% subsidiary acquire a further 
0.76% stake. None of these 
shares were used in voting during 
the reporting period

1.4. Shareholders are provided with reliable and effective methods of registering their ownership 
of shares and the opportunity to dispose of their shares freely and without hindrance

1.4

Shareholders 
are provided 
with reliable 
and effective 
methods 
of registering their 
ownership of shares 
and the opportunity 
to dispose of their 
shares freely 
and without 
hindrance

1.  The technologies used 

by the Company’s registrar 
and the terms and quality 
of rendered services meet the needs 
of the Company and its shareholders 
and ensure the most effective way 
to keep record of share ownership 
and exercise shareholder rights

Complied with
Complied with in part
Not complied with

2.1. The Board of Directors is responsible for the strategic management of the Company, formulating 
key principles of and approaches to the risk management and internal control system in the Company, 
supervising the work of the Company’s executive bodies and performing other core functions

1.  The Board of Directors has the powers 

stated in the Charter to appoint 
and dismiss members of executive 
bodies and to determine the terms 
and conditions of their contracts.

2.  In the reporting period, the Nomination 

(Appointment, HR) Committee 3 1 
considered the matter regarding 
whether the members of executive 
bodies had the necessary professional 
qualification, skills and expertise 
to meet the current and expected needs 
of society in line with the Company’s 
approved strategy.

3.  In the reporting period, the Board 
of Directors reviewed the report 
(reports) of the sole executive body 
and the collective executive body (if 
applicable) on the implementation 
of the Company’s strategy

1. 

In the reporting period, the Board 
of Directors addressed matters 
related to the strategy implementation 
and revision, approval of the Company’s 
financial and business plan (budget), 
and review of criteria and indicators 
(including interim ones) as regards 
delivering on the Company’s strategy 
and business plans

Complied with
Complied with in part
Not complied with

Complied with
Complied with in part
Not complied with

2.1.1

2.1.2

The Board 
of Directors 
is responsible 
for the appointment 
of executive bodies 
and their dismissal, 
including as a result 
of failure to perform 
properly. The Board 
of Directors also 
ensures that 
the Company’s 
executive bodies 
act in accordance 
with the approved 
development 
strategy 
and the Company’s 
business profile

The Board 
of Directors 
sets major long-
term targets 
for the Company, 
as well as assesses 
and approves its 
key performance 
indicators 
and primary 
business 
goals, along 
with the Company’s 
strategy 
and business plans 
with regard to its 
core operations

62

63

1. 

 3 The “Nomination Committee”.

  
  
  
  
  
  
  
  
  
  
No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Complied with
Complied with in part
Not complied with

Complied with
Complied with in part
Not complied with

1.  The principles of, and approaches 
to, organising the Company’s risk 
management and internal control 
system were established by the Board 
of Directors and are set out 
in the Company’s internal regulations 
defining the risk and internal control 
management policy.

2.  In the reporting period, the Board 
of Directors approved (revised) 
the Company’s acceptable risks (risk 
appetite) or the Audit Committee and/
or the Risk Committee (if applicable) 
considered the feasibility of putting 
forward the revision of the Company’s 
risk appetite for consideration 
by the Board of Directors

1.  The Company has developed 

and implemented the policy (policies) 
approved by the Board of Directors 
on remuneration and reimbursement 
of expenses (compensations) to its 
directors, executive bodies and other 
key managers.

2.  In the reporting period, the Board 

of Directors addressed matters related 
to the above policy (policies)

1.  The Board of Directors plays a key role 
in preventing, identifying and resolving 
internal conflicts.

Complied with
Complied with in part
Not complied with

2.  The Company has developed 

a framework for identifying transactions 
involving a conflict of interest and a set 
of measures for resolving such conflicts

1.  The Company has determined persons 
responsible for the implementation 
of the Information Policy in its internal 
regulations

Complied with
Complied with in part
Not complied with

1. 

In the reporting period, the Board 
of Directors reviewed the results of self-
assessment and/or external assessment 
of the Company’s corporate governance 
practices

Complied with
Complied with in part
Not complied with

2.1.3

The Board 
of Directors 
formulates 
the principles 
of and approaches 
to risk management 
and internal 
control system 
in the Company

The Board 
of Directors 
determines 
the Company’s 
policy 
on remuneration 
and/or 
reimbursement 
of expenses 
(compensations) 
to its directors, 
executive bodies 
and other key 
managers

The Board 
of Directors 
plays a key role 
in preventing, 
identifying 
and resolving 
internal conflicts 
between 
the Company’s 
bodies, shareholders 
and employees

The Board 
of Directors plays 
a key role in ensuring 
the Company’s 
transparency, full 
and timely information 
disclosure, 
and unhindered 
access 
of shareholders 
to the Company’s 
documents

The Board 
of Directors 
oversees 
the Company’s 
corporate 
governance 
practices and plays 
a key role 
in the Company’s 
material corporate 
events

2.1.4

2.1.5

2.1.6

2.1.7

64

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

2.2. The Board of Directors is accountable to the Company’s shareholders

2.2.1

Information 
on the performance 
of the Board 
of Directors 
is disclosed 
and provided 
to shareholders

1.  The Company’s Annual Report 

for the reporting period includes 
information on attendance 
of meetings of the Board of Directors 
and Committees by each of directors.
2.  The Annual Report includes information 
on key results of the Board of Directors’ 
performance assessment (self-
assessment) carried out in the reporting 
period

Complied with
Complied with in part
Not complied with

Explanation on item 1: information 
on attendance of meetings 
of the Board of Directors and its 
Committees is not disclosed 
in the Annual Report in accordance 
with Resolution of the Government 
of the Russian Federation No. 351 
dated 12 March 2022

2.3. The Board of Directors manages the Company in an effective and competent manner, and is able to make 
objective and independent judgements and decisions in the best interests of the Company and its shareholders

1. 

In the reporting period, the Board 
of Directors (or its Nomination 
Committee) assessed candidates 
to the Board of Directors in terms 
of their required experience, 
knowledge, business reputation, lack 
of conflict of interest, etc.

Complied with
Complied with in part
Not complied with

1. 

In all cases where the agenda 
of a General Shareholders Meeting held 
in the reporting period included election 
to the Board of Directors, the Company 
provided shareholders with biographical 
details of all candidates to the Board 
of Directors, results of assessment 
carried out by the Board of Directors 
(or its Nomination Committee) 
to determine whether the members 
had the necessary professional 
qualification, skills and expertise 
to meet the current and expected 
needs of society, information on their 
compliance with the independence 
criteria as per Recommendations 
102–107 of the Code, and their written 
consent to be elected to the Board 
of Directors

1. 

In the reporting period, the Board 
of Directors analysed its needs 
in terms of professional qualifications, 
expertise and skills and identified 
the competencies the Board 
of Directors needs to develop in short 
and long run

Complied with
Complied with in part
Not complied with

Complied with
Complied with in part
Not complied with

2.3.1

2.3.2

2.3.3

Elected to the Board 
of Directors are only 
those individuals who 
have an impeccable 
business and personal 
reputation, 
as well as the knowledge, 
skills and experience 
required for making 
decisions within 
the remit of the Board 
of Directors 
and performing its 
functions effectively

The Company’s 
directors 
are elected through 
a transparent 
procedure providing 
shareholders 
with sufficient 
information 
on candidates 
to form an opinion 
about their personal 
and professional 
qualities

The composition 
of the Board 
of Directors 
is balanced, 
including in terms 
of directors’ 
expertise, 
experience, 
knowledge 
and business 
skills, and worthy 
of shareholders’ 
trust

65

  
  
  
  
  
  
  
  
  
  
Status 
of compliance 
with a corporate 
governance 
principle

Complied with
Complied with in part
Not complied with

No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

1. 

In the reporting period, the Board 
of Directors reviewed whether 
the number of directors was in line 
with the Company’s needs 
and shareholders’ interests

2.3.4

The number 
of directors ensures 
the most effective 
arrangement 
of activities 
of the Company’s 
Board of Directors, 
including by way 
of establishing 
Committees, 
and enables 
a candidate voted 
for by the Company’s 
substantial minority 
shareholders 
to be elected 
to the Board 
of Directors

2.4. The Board of Directors includes a sufficient number of independent directors

1. 

In the reporting period, all independent 
directors met all of the independence 
criteria as per Recommendations 
102–107 of the Code or were recognised 
as independent by the Board 
of Directors

Complied with
Complied with in part
Not complied with

2.4.1

An independent 
director is a person 
with sufficient 
professional 
skills, experience 
and independence 
to form their own 
opinions and make 
objective and fair 
judgements 
not influenced 
by the Company’s 
executive bodies, 
certain groups 
of shareholders or 
other stakeholders.
Under normal 
circumstances 
a candidate (elected 
director) may not 
be considered 
independent if 
they are related 
to the Company, 
its substantial 
shareholder, 
its substantial 
counterparty or 
competitor, or 
the government

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

2.4.2

Candidates 
to the Board 
of Directors 
are assessed 
for compliance 
with the independence 
criteria, 
with independent 
directors being 
regularly checked 
against these 
criteria. Such 
assessments is in line 
with the substance 
over form principle

1. 

In the reporting period, the Board 
of Directors (or its Nomination 
Committee) formed an opinion 
regarding the independence of each 
candidate to the Board of Directors 
and submitted the relevant report 
to shareholders.

2.  The Board of Directors (or 

the Nomination Committee) considered 
the independence of the current 
directors (after they had been elected) 
at least once in the reporting period.

3.  The Company has developed 

procedures determining actions 
to be taken by a director if they 
cease to be independent, including 
their obligation to notify the Board 
of Directors accordingly and in a timely 
manner

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Complied with
Complied with in part
Not complied with

2.4.3

2.4.4

Independent 
directors make up 
at least one third 
of the elected 
directors

Independent 
directors play a key 
role in preventing 
internal conflicts 
in the Company 
and taking material 
corporate actions 
by the Company

1. 

Independent directors make up at least 
one third of the Board of Directors

Complied with
Complied with in part
Not complied with

1. 

In the reporting period, independent 
directors (with no conflict of interest) 
make a preliminary assessment 
of material corporate actions involving 
a potential conflict of interest 
and submit the results thereof 
to the Board of Directors

Complied with
Complied with in part
Not complied with

2.5. The Chairman of the Board of Directors ensures that the Board 
of Directors performs its functions in the most effective way

Complied with
Complied with in part
Not complied with

1.  The Chairman of the Board of Directors 
is an independent director, or a senior 
independent director has been 
appointed from among independent 
directors.

2.  The role, rights and responsibilities 

of the Chairman of the Board 
of Directors (and, if applicable, 
of the senior independent director) 
are duly specified in the Company’s 
internal regulations

1. 

In the reporting period, the performance 
of the Chairman of the Board 
of Directors was assessed as part 
of the Board of Directors’ performance 
assessment (self-assessment)

Complied with
Complied with in part
Not complied with

2.5.1

2.5.2

The Chairman 
of the Board of Directors 
has been elected from 
among independent 
directors, or a senior 
independent director 
has been appointed 
from among the elected 
independent directors 
to coordinate their 
work and liaise 
with the Chairman 
of the Board of Directors

The Chairman 
of the Board 
of Directors ensures 
constructive 
atmosphere during 
meetings, facilitates 
open discussion 
of agenda items 
and oversees 
implementation 
of the Board 
of Directors’ 
resolutions

66

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No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

2.5.3

The Chairman 
of the Board 
of Directors ensures 
that directors 
are provided 
with information 
required to make 
informed decisions 
on agenda items 
in a timely manner

1.  The responsibility of the Chairman 
of the Board of Directors to ensure 
timely provision to directors of complete 
and reliable information on agenda 
items is specified in the Company’s 
regulations

Status 
of compliance 
with a corporate 
governance 
principle

Complied with
Complied with in part
Not complied with

2.6. Directors act reasonably and in good faith in the best interests of the Company and its 
shareholders, based on sufficient awareness and with due diligence and care

Complied with
Complied with in part
Not complied with

2.6.1

Directors make 
decisions taking 
into account 
all available 
information, 
having no conflict 
of interest, ensuring 
equitable treatment 
of the Company’s 
shareholders 
and keeping within 
the limits of common 
business risks

1.  The Company’s internal regulations 
specify that directors shall notify 
the Board of Directors of any conflict 
of interest they might have 
in relation to any agenda item 
prior to the discussion of that item 
at a meeting of the Board of Directors or 
its Committee.

2.  The Company’s internal regulations 

specify that a director shall abstain from 
voting on any item where they have 
a conflict of interest.

3.  The Company has established 

a procedure enabling the Board 
of Directors to get professional 
advice on matters within its remit 
at the Company’s expense

2.6.2

Directors’ rights 
and responsibilities 
are clearly stated 
and set forth 
in the Company’s 
internal regulations

2.6.3

Directors have 
sufficient time 
to perform their 
duties

1.  The Company has adopted 

and published an internal regulation 
clearly specifying directors’ rights 
and responsibilities

Complied with
Complied with in part
Not complied with

Complied with
Complied with in part
Not complied with

1.  The assessment (self-assessment) 

of the Board of Directors 
in the reporting period included 
the analysis of individual attendance 
of meetings of the Board of Directors 
and the Committees and a review 
of whether a director had been 
on the Board long enough.
2.  As per the Company’s internal 

regulations, directors shall notify 
the Board of Directors of their intention 
to join the governing bodies of other 
companies (excluding those controlled 
by the Company) and of the fact of such 
an appointment

2.6.4

All directors have 
equal access 
to the Company’s 
documents 
and information. 
Newly elected 
directors are provided 
with sufficient 
information 
on the Company 
and the Board 
of Directors’ activities 
as soon as practicable

1.  As per the Company’s internal 

regulations, directors have the right 
to access information and documents 
needed for the performance of their 
duties related to the Company and its 
controlled entities, and the Company’s 
executive bodies are obliged 
to procure the relevant information 
and documents.

2.  The Company has a formalised 

induction programme in place for newly 
elected directors

Complied with
Complied with in part
Not complied with

68

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

2.7. Meetings of the Board of Directors, preparation for and attendance of these 
meetings are key to the effectiveness of the Board of Directors

2.7.1

2.7.2

2.7.3

2.7.4

1.  The Board of Directors held at least six 

meetings in the reporting year

Complied with
Complied with in part
Not complied with

Meetings 
of the Board 
of Directors are held 
as necessary, given 
the Company’s 
scope of operations 
and objectives 
at any given time

The Company’s 
internal regulations 
set out a procedure 
to prepare 
and hold meetings 
of the Board 
of Directors enabling 
directors to make 
proper preparations

1.  The Company has approved 

an internal regulation setting out 
the procedure to prepare and hold 
meetings of the Board of Directors 
and specifying, among other things, 
that the notice of a meeting shall 
be generally given at least five days 
prior to the date of the meeting.
2.  In the reporting period, the directors 

Complied with
Complied with in part
Not complied with

who were unable to attend the meeting 
in person had the opportunity 
to participate in discussion 
and voting on agenda items remotely 
– via conference calls and video 
conferencing

1.  The Company’s Charter or another 
internal regulation specifies that 
the most important matters (including 
those listed in Recommendation 
168 of the Code) shall be reviewed 
at in-person meetings of the Board 
of Directors

Complied with
Complied with in part
Not complied with

1.  The Company’s Charter specifies that 
resolutions on the most important 
matters, as per Recommendation 
170 of the Code, shall be adopted 
at meetings of the Board of Directors 
by a qualified majority of at least three 
quarters of the votes or by a majority 
vote of all elected directors

Complied with
Complied with in part
Not complied with

The format 
of a meeting 
of the Board 
of Directors 
is determined 
taking into account 
the importance 
of agenda items. 
Resolutions 
on the most important 
matters are adopted 
at in-person meetings

Resolutions 
on the most 
important 
matters related 
to the Company’s 
operations 
are adopted 
at meetings 
of the Board 
of Directors 
by a qualified 
majority vote 
or by a majority 
vote of all elected 
directors

Paragraph 10.5.5 of Rosneft’s Charter 
specifies the range of matters 
to be resolved by the Board 
of Directors by a qualified majority 
vote. Given the scope of Rosneft’s 
operations, the number of matters 
reviewed by the Board of Directors, 
the composition of the Board 
of Directors and the economic 
sanctions the Company is exposed 
to, expanding this range to include all 
matters set out in Recommendation 
170 of the Code may materially 
impede or prevent the resolution 
of matters material to the Company. 
Therefore, setting a higher quorum 
as recommended by the Code may 
result in the Board of Directors not 
being able to resolve a number of key 
matters. At the same time, the number 
of directors, the structure of the Board 
of Directors, including four independent 
directors, the procedure to prepare 
for meetings, discuss matters at them 
and disclose information on them 
guarantee the protection of rights of all 
shareholder groups of the Company. 
The Company has no intention to change 
its approach in the medium term

69

  
  
  
  
  
  
  
  
  
  
No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

2.8. The Board of Directors establishes Committees for preliminary consideration 
of the most important matters related to the Company’s operations

2.8.1

2.8.2

For preliminary 
consideration 
of matters related 
to the monitoring 
of the Company’s 
financial 
and business 
operations, 
an Audit Committee 
composed 
of independent 
directors has been 
established

For preliminary 
consideration 
of matters related 
to the development 
of an effective 
and transparent 
remuneration 
framework, 
a Remuneration 
Committee 
composed 
of independent 
directors 
and chaired 
by an independent 
director not being 
the Chairman 
of the Board 
of Directors has 
been established

Complied with
Complied with in part
Not complied with

1.  The board of directors has a standing 
audit committee comprised entirely 
of independent directors.

2.  The Company’s internal regulations 
specify the Audit Committee’s 
objectives, including, among others, 
those set out in Recommendation 172 
of the Code.

3.  At least one member of the audit 

committee, who is an independent 
director, has knowledge and expertise 
in the preparation, analysis, evaluation 
and audit of accounting (financial) 
statements.

4.  The audit committee held at least 
one meeting per quarter during 
the reporting period

1.  The board of directors has a standing 
remuneration committee comprised 
entirely of independent directors.

Complied with
Complied with in part
Not complied with

2.  The remuneration committee is chaired 
by an independent director who is not 
the chairman of the board of directors.

3.  The Company’s internal regulations 

specify the Remuneration 
Committee’s objectives, including, 
among others, those set out 
in Recommendation 180 of the Code 
as well as the circumstances 
(events) on the occurrence of which 
the Remuneration Committee shall 
consider a revision of the Company’s 
remuneration policy for members 
of the Board of Directors, executive 
bodies and other key executive officers

The principle is not complied 
with inasmuch as the HR 
and Remuneration Committee 
of the Board of Directors is not exclusively 
composed of independent directors.
The HR and Remuneration 
Committee of the Board of Directors 
is mostly made up of independent 
directors. The elected Chairman 
of the HR and Remuneration 
Committee of the Board of Directors 
is an independent director.
The remit of the HR and Remuneration 
Committee of the Board of Directors 
includes matters reserved 
for a Nomination Committee 
and a Remuneration Committee 
by the Corporate Governance Code.
Taking into account:
 ● the Company’s three standing 

committees (the Audit 
Committee, HR and Remuneration 
Committee, and Strategic 
Planning Committee);
 ● the recommendations 
and restrictions set out 
in the Code (on the minimum 
number of Committee members 
(three), on the maximum number 
of Committees a director may 
sit on, on the minimum number 
of independent directors 
on an Audit Committee and an HR 
and Remuneration Committee, 
and on the composition 
of Committees based on directors’ 
relevant expertise), compliance 
with the recommendation to have all 
Committees chaired by independent 
directors is impracticable.

At the same time, the Company’s internal 
regulations, including the Regulations 
on the Board of Directors, specify 
procedures to prevent any conflict 
of interest and eliminate the risk 
of recommendations by the committee 
of the Board of Directors being affected 
by the controlling shareholder or 
executive bodies.
The Company has no intention to change 
its approach in the medium term

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Complied with
Complied with in part
Not complied with

Complied with
Complied with in part
Not complied with

1.  The board of directors has a standing 

nomination committee (or its objectives 
specified in Recommendation 186 
of the Code are implemented 
by a different committee) 
with the majority of its members being 
independent directors.

2.  The Company’s internal regulations 

specify the objectives of the nomination 
committee (or another relevant 
committee with combined functionality), 
including, among others, those set out 
in Recommendation 186 of the Code.

3.  To align the composition of the Board 

of Directors with the objectives and purposes 
of the Company, in the reporting period, 
the Nomination Committee, acting on its own 
or jointly with other Committees of the Board 
of Directors, or an authorised shareholder 
engagement division arranged for interaction 
with a broad range of shareholders 
to discuss the selection of candidates 
for the Company’s Board of Directors

1. 

In the reporting period, the Company’s 
Board of Directors reviewed 
the relevance of the structure of its 
Board of Directors to the scale, nature, 
objectives, needs of the Company 
and its risk profile. Additional 
committees have been either 
established or found unnecessary

2.8.3

2.8.4

2.8.5

For preliminary 
consideration 
of matters related 
to human resources 
(succession) 
planning, expertise 
and performance 
of the Board 
of Directors, 
a Nomination 
(Appointment, 
HR) Committee 
mostly composed 
of independent 
directors has been 
established

Given the scope 
of operations and risk 
levels, the Company’s 
Board of Directors 
has ensured that 
the composition 
of its Committees 
is fully in line 
with the Company’s 
objectives. Additional 
committees have been 
either established or 
found unnecessary 
(a Strategy Committee, 
a Corporate 
Governance 
Committee, an Ethics 
Committee, a Risk 
Management 
Committee, 
a Budget Committee, 
a Health, Safety 
and Environment 
Committee, etc.)

The composition 
of Committees 
enables 
comprehensive 
discussion 
of matters subject 
to preliminary 
consideration 
with due regard 
to varying opinions

Complied with
Complied with in part
Not complied with

1.  The Audit Committee, the Remuneration 

Committee and the Nomination 
Committee (or another relevant 
committee with combined functionality) 
were chaired by independent directors 
in the reporting period.

2.  The company’s internal regulations 

(policies) contain provisions that prohibit 
the non-members to attend meetings 
of Audit Committee, the Remuneration 
Committee and the Nomination 
Committee (or another relevant 
committee with combined functionality), 
unless they are invited by the chairman 
of a respective committee

2.8.6

Committee 
Chairmen report 
on their Committees’ 
performance 
to the Board of Directors 
and its Chairman 
on a regular basis

1. 

In the reporting period, Committee 
Chairmen regularly reported 
to the Board of Directors on their 
Committees’ performance

Complied with
Complied with in part
Not complied with

70

71

  
  
  
  
  
  
  
  
  
  
No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

2.9. The Board of Directors arranges performance assessment of the Board of Directors, its Committees and directors

3.1.2

Complied with
Complied with in part
Not complied with

Explanation on item 3: due 
to the pandemic in some of the 
countries, the Board of Directors 
reviewed the results of its 
assessment by absentee voting

1.  The Company’s internal regulations 

set out the procedure for carrying out 
the assessment (self-assessment) 
of the Board of Directors.

2.  In the reporting period, assessment 
(self-assessment) of the Board 
of Directors’ performance included 
performance assessment of individual 
directors and the Board of Directors 
as a whole.

3.  Results of the assessment (self-

assessment) of the Board of Directors 
carried out in the reporting period 
were reviewed at an in-person meeting 
of the Board of Directors

1.  To assess the Board of Directors’ 

performance on an independent basis, 
the Company engaged an external 
organisation (consultant) at least once 
over the last three reporting periods

Complied with
Complied with in part
Not complied with

2.9.1

2.9.2

The Board 
of Directors’ 
performance 
assessment is aimed 
at evaluating 
the effectiveness 
of the Board 
of Directors, 
its Committees 
and directors, 
checking their 
performance against 
the Company’s 
development 
needs, enhancing 
their activities 
and identifying areas 
for improvement

Performance 
assessment 
of the Board 
of Directors, its 
Committees 
and directors 
is carried out 
on a regular basis 
at least once a year. 
To assess the Board 
of Directors’ 
performance 
on an independent 
basis, an external 
organisation 
(consultant) 
is engaged at least 
once every three 
years

3.1. The Company’s Corporate Secretary ensures effective day-to-day interaction 
with shareholders, coordinates the Company’s efforts to protect shareholder rights 
and interests, and contributes to the Board of Directors’ efficient work

3.1.1

The Corporate 
Secretary has 
sufficient knowledge, 
experience 
and expertise 
to perform 
their duties, 
as well as impeccable 
reputation, and enjoys 
shareholders’ trust

1.  The Company’s website and Annual 
Report provide biographical details 
of the Corporate Secretary (including 
the age, eduction, qualification 
and expertise) and positions 
the Corporate Secretary held 
in governing bodies of other legal 
entities at least over the last five years

Complied with
Complied with in part
Not complied with

In accordance with Resolution 
of the Government of the Russian 
Federation No. 351 dated 12 March 
2022 On Special Aspects of Disclosing 
and Providing Information Subject 
to Disclosure and Provision 
under the Federal Law On Joint-
Stock Companies and Federal 
Law On the Securities Market 
and on Special Aspects of Disclosing 
Insider Information under the Federal 
Law On Countering the Misuse 
of Insider Information and Market 
Manipulation and Amending Certain 
Laws of the Russian Federation, 
information about the Corporate 
Secretary is not disclosed

The Corporate 
Secretary 
is sufficiently 
independent from 
the Company’s 
executive bodies 
and has the powers 
and resources 
required to perform 
their duties

1.  The Company has adopted 

and disclosed an internal regulation 
on Corporate Secretary.

Complied with
Complied with in part
Not complied with

2.  The Board of Directors approves 
the candidate for the position 
of Corporate Secretary, terminates 
the Corporate Secretary’s powers 
and considers the payment of additional 
remuneration to the Corporate 
Secretary.

3.  The Company’s internal regulations 
define the Corporate Secretary’s 
right to request and receive 
the Company’s documents 
and information from governing bodies, 
structural subdivisions and officers 
of the Company

4.1. Remuneration paid by the Company is sufficient to attract, motivate and retain employees 
with the required competence and expertise. Remuneration is paid to the Company’s directors, executive 
bodies and other key managers in accordance with the remuneration policy adopted by the Company

1.  The remuneration of members 

of the Board of Directors, governing 
bodies and other key executive officers 
of the Company is based on pay 
benchmarking against peers

Complied with
Complied with in part
Not complied with

Complied with
Complied with in part
Not complied with

1. 

In the reporting period, 
the Remuneration Committee reviewed 
the remuneration policy (policies) 
and (or) its (their) implementation 
practices, assessed their effectiveness 
and transparency and, where 
necessary, submitted relevant 
recommendations to the Board 
of Directors to revise this policy 
(policies)

4.1.1

4.1.2

Remuneration paid 
by the Company 
to directors, executive 
bodies and other 
key managers 
is sufficient to ensure 
their efficient 
work and enables 
the Company 
to attract and retain 
competent 
and qualified 
specialists. 
At the same time, 
the Company avoids 
paying higher-
than-required 
remuneration or 
creating unreasonably 
wide remuneration 
gaps between 
any of the above 
persons and Company 
employees

The Company’s 
remuneration policy 
has been developed 
by the Remuneration 
Committee 
and approved 
by the Board 
of Directors. 
The Board 
of Directors, 
supported 
by the Remuneration 
Committee, monitors 
the introduction 
and implementation 
of the remuneration 
policy 
in the Company, 
and revises 
and amends it 
as necessary

72

73

  
  
  
  
  
  
  
  
  
  
No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

1.  The Company’s remuneration 

policy (policies) provides (provide) 
for transparent mechanisms 
to determine the amount 
of remuneration payable to its directors, 
executive bodies and other key 
managers, and covers (cover) all types 
of payments, benefits and privileges 
provided to them

4.1.3

4.1.4

The Company’s 
remuneration 
policy provides 
for transparent 
mechanisms 
to determine 
the amount 
of remuneration 
payable to its 
directors, executive 
bodies and other key 
managers, and covers 
all types of payments, 
benefits and privileges 
provided to them

The Company 
develops a policy 
on reimbursement 
of expenses 
(compensations) 
specifying 
reimbursable expenses 
and service levels that 
its directors, executive 
bodies and other 
key managers 
are entitled to. This 
policy may form part 
of the Company’s 
remuneration policy

1.  The Company’s remuneration policy 

(policies) or other internal regulations 
specify procedures to reimburse its 
directors, executive bodies and other 
key managers for the expenses incurred

Complied with
Complied with in part
Not complied with

4.2. Remuneration system for directors ensures alignment of their financial 
interests with the long-term financial interests of shareholders

Complied with
Complied with in part
Not complied with

1. 

In the reporting period, the Company 
paid remuneration to members 
of the Board of Directors in line 
with the Company’s remuneration 
policy.

2.  In the reporting period, the Company 
did not offer the members of its 
Board of Directors any short-term 
motivation plans and additional financial 
incentives based on the Company’s 
performance (performance indicators). 
The Company did not pay remuneration 
for participation in individual meetings 
of the Board of Directors or its 
Committees

1. 

If the Company’s internal regulation 
(regulations), namely its remuneration 
policy (policies), allows (allow) 
distribution of the Company’s 
shares to directors, clear rules 
on share ownership by directors 
aimed at encouraging their long-
term ownership shall be introduced 
and disclosed

Complied with
Complied with in part
Not complied with

The Company 
pays fixed annual 
remuneration 
to its directors 
The Company does 
not pay remuneration 
for participation 
in individual meetings 
of the Board 
of Directors or its 
Committees.
The Company does 
not offer short-
term motivation 
plans and additional 
financial incentives 
to the members of its 
Board of Directors

Long-term ownership 
of the Company’s 
shares ensures best 
alignment of directors’ 
financial interests 
with the long-
term interests 
of shareholders. 
At the same time, 
the Company does 
not link the right to sell 
shares to achieving 
certain performance 
indicators, 
and directors do not 
participate in options 
plans

4.2.1

4.2.2

74

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Status 
of compliance 
with a corporate 
governance 
principle

Complied with
Complied with in part
Not complied with

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

4.2.3

The Company does not 
provide any additional 
payments or 
compensations 
to directors in the event 
of early termination 
of office due 
to a transfer of control 
over the Company 
or any other 
circumstances

1.  The Company does not provide 
any additional payments or 
compensations to directors 
in the event of early termination 
of office due to a transfer of control 
over the Company or any other 
circumstances

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Complied with
Complied with in part
Not complied with

4.3. Remuneration system for members of executive bodies and other key managers of the Company 
links their remuneration to the Company’s performance and their personal contribution thereto

4.3.1

4.3.2

4.3.3

Complied with
Complied with in part
Not complied with

Remuneration 
paid to members 
of executive 
bodies and other 
key managers 
of the Company 
ensures 
a reasonable 
and justified balance 
between the fixed 
and variable 
components, 
with the latter 
depending 
on the Company’s 
performance 
and an employee’s 
personal (individual) 
contribution thereto

1. 

In the reporting period, the variable 
remuneration for members of executive 
bodies and other key managers 
of the Company was linked to annual 
performance indicators approved 
by the Board of Directors.
2.  During the latest assessment 
of the remuneration system 
for members of executive 
bodies and other key managers 
of the Company, the Board of Directors 
(the Remuneration Committee) 
ensured that the Company maintained 
an effective balance between 
the fixed and variable components 
of remuneration.

3.  The remuneration payable to members 
of the executive bodies and other 
officers of the Company factors 
in the risks to which the Company 
is exposed to prevent excessively risky 
decision-making in management

Complied with
Complied with in part
Not complied with

Complied with
Complied with in part
Not complied with

If the Company introduces a share-
based long-term incentive plan 
for members of its executive bodies 
and other key officers (share-based 
financial instruments), the right 
to sell shares and other financial 
instruments may be exercised no 
earlier than three years after the date 
on which they were granted. Moreover, 
the right to sell them is subject 
to the achievement by the Company 
of certain performance indicators

In the reporting period, the amount 
of severance pay (“golden parachute) 
paid by the Company to members of its 
executive bodies or key managers 
in the event of early termination 
of office, provided that such termination 
was initiated by the Company 
with no misconduct on the part 
of the respective employee, did not 
exceed twice the size of the fixed 
component of their annual remuneration

1. 

1. 

The Company has 
introduced a long-
term incentive 
plan for members 
of its executive 
bodies and other 
key managers 
involving its shares 
(options or other 
derivatives with its 
shares as underlying 
assets)

The amount 
of severance 
pay (“golden 
parachute”) payable 
by the Company 
to members of its 
executive bodies 
or key managers 
in the event of early 
termination of office, 
provided that such 
termination is initiated 
by the Company with no 
misconduct on the part 
of the respective 
employee, does not 
exceed twice the size 
of the fixed component 
of their annual 
remuneration

75

  
  
  
  
  
  
  
  
  
  
ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

5.1. The Company has put in place an effective risk management and internal control 
system to provide reasonable assurance that it will achieve its goals

5.2. The Company conducts internal audits to assess the reliability and effectiveness of its Risk 
Management, Internal Control System and corporate governance on a regular and independent basis

The Board 
of Directors 
has formulated 
the principles 
of and approaches 
to the risk 
management 
and internal 
control system 
in the Company

The Company’s 
executive 
bodies ensure 
the establishment 
and maintenance 
of an effective 
risk management 
and internal 
control system 
in the Company

The Company’s 
risk management 
and internal control 
system provides 
an accurate, fair 
and clear view 
of the Company’s 
current situation 
and prospects, 
and ensures integrity 
and transparency 
of the Company’s 
statements, 
as well as a reasonable 
and acceptable level 
of risk-taking

The Company’s 
Board of Directors 
takes the necessary 
steps to ensure 
that the Company’s 
Risk Management 
and Internal 
Control System 
functions effectively 
and is in line 
with the relevant 
principles 
and approaches 
formulated 
by the Board 
of Directors

1.  Risk management and internal control 
functions of the Company’s governing 
bodies and divisions are clearly set out 
in the Company’s internal regulations / 
relevant policy approved by the Board 
of Directors

Complied with
Complied with in part
Not complied with

1.  The Company’s executive bodies 

have ensured the distribution of risk 
management and internal control 
duties, powers and responsibilities 
among heads of units and divisions 
accountable to them

Complied with
Complied with in part
Not complied with

1.  The Company has approved an anti-

corruption policy.

2.  The Company has established a safe, 
secure and easily accessible channel 
(hotline) to inform the Board of Directors 
or its Audit Committee about violations 
of law, internal procedures or the Code 
of Corporate Ethics

Complied with
Complied with in part
Not complied with

Complied with
Complied with in part
Not complied with

1. 

In the reporting period, the Board 
of Directors (the Audit Committee and/
or the Risk Committee (if applicable) 
arranged for an assessment of reliability 
and effectiveness of the risk 
management and internal control 
system.

2.  In the reporting period, the Board 
of Directors reviewed the findings 
from the assessment of reliability 
and effectiveness of the risk 
management and internal 
control system to include them 
in the Company’s annual report

5.1.1

5.1.2

5.1.3

5.1.4

76

5.2.1

5.2.2

For the inter-
nal audit purposes, 
the Company has 
established a dedi-
cated unit or engaged 
an independent exter-
nal organisation. 
Functional account-
ability and adminis-
trative accountability 
of the internal audit 
unit are separated. 
The internal audit unit 
is functionally account-
able to the Board 
of Directors

The internal audit 
unit is responsible 
for assessment 
of reliability 
and effectiveness 
of the risk 
management 
and internal 
control system 
and the corporate 
governance 
system and relies 
on generally 
accepted internal 
audit standards

1.  For the internal audit purposes, 
the Company has established 
a dedicated internal audit 
unit functionally accountable 
to the Board of Directors, or engaged 
an independent external organisation 
with the same accountability principle

Complied with
Complied with in part
Not complied with

Complied with
Complied with in part
Not complied with

1. 

In the reporting period, as part 
of internal audit, the reliability 
and effectiveness of the internal 
control and risk management system 
was assessed.

2.  In the reporting period, as part 

of the internal audit, the corporate 
governance practice (practices) 
were assessed, including 
the communication procedures 
(including those relating to internal 
control and risk management) at all 
levels of the Company’s governance 
and the stakeholder engagement 
procedures

6.1. The Company and its operations are transparent to shareholders, investors and other stakeholders

6.1.1

6.1.2

The Company 
has developed 
and implemented 
an Information 
Policy ensuring 
effective exchange 
of information 
between 
the Company, 
its shareholders, 
investors and other 
stakeholders

1.  The Company’s Board of Directors 

has approved its Information 
Policy developed in accordance 
with the Code’s recommendations.
2.  In the reporting period, the Board 
of Directors (or its Committee) 
considered the effectiveness 
of communication between 
the Company, shareholders, 
investors and other stakeholders 
and the advisability of (need for) 
a revision of the Company’s Information 
Policy

The Company 
discloses information 
on its corporate 
governance system 
and practices, 
including detailed 
information on its 
compliance 
with the principles 
and recommendations 
of the Code

1.  The Company discloses information 
on its corporate governance system 
and on the general corporate 
governance principles it uses, including 
by disclosing such information 
on the Company’s website.

2.  The Company discloses 

information on the composition 
of its executive bodies and Board 
of Directors, on the independence 
of directors and their membership 
in the Committees of the Board 
of Directors (as defined in the Code).

3.  If there is a person controlling 

the Company, the Company publishes 
a memorandum on behalf of such 
controlling person detailing their plans 
as regards corporate governance 
in the Company

Complied with
Complied with in part
Not complied with

Complied with
Complied with in part
Not complied with

Explanation on item 2: 
information about the members 
of the Management Board 
is not disclosed in accordance 
with Resolution of the Government 
of the Russian Federation 
No. 351 dated 12 March 2022 
and the recommendations 
of the Bank of Russia (Information 
Letter No. IN-02-28/108 dated 
24 August 2022)

77

  
  
  
  
  
  
  
  
  
  
ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Complied with
Complied with in part
Not complied with

6.2. The Company discloses complete, up-to-date and accurate information on the Company in a timely 
manner to ensure that its shareholders and investors are able to make informed decisions

6.2.1

The Company 
discloses 
information 
on a regular basis 
and in a consistent 
and timely 
manner, in line 
with the principles 
of data accessibility, 
accuracy, 
completeness 
and comparability

6.2.2

The Company avoids 
formal approach 
to information 
disclosures 
and discloses 
material information 
on its operations 
even if such 
disclosures are not 
required by law

Complied with
Complied with in part
Not complied with

Complied with
Complied with in part
Not complied with

1.  The Company has in place a procedure 

streamlining the work of all 
the Company’s structural subdivisions 
and employees involved in disclosing 
information or whose activity may lead 
to the need for disclosing information.
2.  If the Company’s securities are traded 

in established foreign markets, 
disclosures of material information 
during a reporting year are made 
in Russia and in such markets 
on a concurrent and equal basis.

3.  If foreign shareholders own 

a substantial number of shares 
in the Company, disclosures during 
the reporting year were made in Russian 
and in one of the most widely used 
foreign languages

1.  The Company’s Information Policy 

defines approaches to non-mandatory 
disclosure of information on other 
events (actions) that have a material 
effect on the price and quotes of its 
securities.
2.  In accordance 

with Recommendation 290 of the Code, 
the Company discloses information 
on its capital structure in the Annual 
Report and on its website.

3.  The Company discloses information 

on its material controlled legal 
entities, including their key business 
areas, mechanisms for ensuring 
their accountability, and the powers 
of the Company’s Board of Directors 
to define their strategy and assess their 
performance.

4.  The Company publishes a non-financial 

report, i.e. a sustainability report, 
environmental report, corporate social 
responsibility report or another report 
providing non-financial information, 
including that on the Company’s 
environmental (environment 
protection and climate change), social, 
and governance (ESG) performance, 
other than the report of the issuer 
of issue-grade securities or the annual 
report of a joint-stock company

Explanation on item 3: the Company 
discloses information on its mate-
rial controlled legal entities, includ-
ing their key business areas 
and mechanisms for ensuring their 
accountability.
Rosneft's Board of Directors over-
sees the development of the strat-
egy and performance assessment 
at controlled legal entities using 
the following mechanisms:
 ● control over executive bodies 

whose remit includes the approval 
of the Group Subsidiaries’ plans 
as per Rosneft's Charter;

 ● corporate procedures governed 
by Rosneft's internal regula-
tions, which ensure alignment 
of all strategic planning docu-
ments of Rosneft and the Group 
Subsidiaries with Rosneft’s 
strategy approved by the Board 
of Directors.

The powers of the Board of Directors 
to approve Rosneft’s Strategy 
and monitor its implementation, 
and the powers of the Chief Executive 
Officer and the Management Board 
to approve the planning documents 
of the Group Subsidiaries are set 
forth in Rosneft’s Charter. The pow-
ers of the Strategy and Sustainable 
Development Committee of Rosneft’s 
Board of Directors to define 
the Company's policy with respect 
to the Group Subsidiaries are set 
forth in the Regulations on Rosneft 
Board Committees and disclosed 
on the corporate website.
Detailed information on internal pro-
cedures for approval of strategic 
documents of the Group Subsidiaries 
and control over their implementation 
by the Board of Directors (its commit-
tees) is not disclosed. The Company 
has no intention to change this 
approach in the medium term

1.  The Company’s Annual Report 

provides information on the results 
of the external and internal audit 
assessment by the Audit Committee.

2.  The Company’s Annual Report 

provides information on the Company’s 
environmental and social policies

6.2.3

As a key 
communication 
tool to liaise 
with shareholders 
and other 
stakeholders, 
the Annual Report 
provides information 
needed to assess 
the Company’s 
performance 
for the year

6.3. The Company provides shareholders with equal and unhindered access 
to information and documents as per their request

1.  The Company’s information policy 
(internal regulations setting forth 
the information policy) define(s) 
the procedure ensuring unhindered 
access to the Company’s information 
and documents at the shareholders’ 
request.

2.  The Company’s information policy 
(internal regulations setting out 
the information policy) contain(s) 
provisions stipulating that the Company 
shall take all necessary steps to obtain 
the information on its controlled 
entities from the relevant controlled 
entities, as may be requested 
by the shareholders

1. 

In the reporting period, the Company 
did not refuse to provide shareholders 
with requested information, or such 
refusals were justified.

2.  If and when required by the Company’s 

Information Policy, shareholders 
are informed of the sensitive 
nature of the information provided 
and undertake to keep it confidential

Complied with
Complied with in part
Not complied with

Complied with
Complied with in part
Not complied with

6.3.1

No unreasonable 
difficulties prevent 
the shareholders 
from exercising 
their right to access 
the Company's 
documents 
and information

6.3.2

When providing 
information 
to shareholders, 
the Company 
maintains 
a reasonable 
balance between 
the interests 
of individual 
shareholders 
and those 
of the Company, as it 
is in the Company’s 
best interests 
to keep confidential 
any sensitive 
commercial 
information that may 
have a material 
effect on its 
competitive position

78

79

  
  
  
  
  
  
  
  
  
  
No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

No.  

Corporate 
governance 
principles  

Criteria for compliance 
with a corporate governance 
principle  

7.1. Actions that have or may have a material effect on the Company’s shareholding structure and financial 
position and, consequently, on the shareholders’ position (material corporate actions) are taken on fair 
terms ensuring that rights and interests of the shareholders and other stakeholders are respected

7.1.3

Explanations on the failure 
to meet criteria for compliance 
with a corporate governance 
principle  

Status 
of compliance 
with a corporate 
governance 
principle

Complied with
Complied with in part
Not complied with

Complied with
Complied with in part
Not complied with

1.  The Company’s Charter sets out a list 

(criteria) of transactions or other actions 
deemed to be material corporate 
actions. As per the Company's 
Charter, decision-making with regard 
to material corporate actions 
is reserved to the Board of Directors. If 
and when the law expressly reserves 
such corporate actions to the General 
Shareholders Meeting, the Board 
of Directors provides shareholders 
with relevant recommendations

1.  The Company has established 

a procedure for independent directors 
to express their opinions on material 
corporate actions before their approval

Complied with
Complied with in part
Not complied with

Material corporate 
actions include 
reorganisation 
of the Company, 
acquisition 
of 30% or more 
of the Company’s 
voting shares 
(takeover), major 
transactions made 
by the Company, 
increase or 
reduction 
in the Company’s 
charter capital, 
listing and delisting 
of the Company’s 
shares, and other 
actions that may 
result in a material 
change in the rights 
of shareholders 
or be against 
their interests. 
The Company’s 
Charter sets out 
a list (criteria) 
of transactions 
or other actions 
deemed 
to be material 
corporate actions 
and reserved 
to the Company’s 
Board of Directors

The Board 
of Directors plays 
a key role in making 
decisions or 
recommendations 
with regard 
to material corporate 
actions and relies 
on the opinion 
of the Company’s 
independent 
directors

7.1.1

7.1.2

80

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

1.  Approval of the Company's material 
transactions is reserved to Board 
of Directors as per the Company's 
Charter, with due regard to the specifics 
of the Company's operations 
and in addition to regulatory 
requirements for transaction approvals.

2.  In the reporting period, all material 

corporate actions were duly approved 
prior to their implementation

When taking material 
corporate actions 
affecting the rights 
and legitimate 
interests 
of shareholders, 
the Company 
ensures equitable 
treatment of all of its 
shareholders, and, 
where statutory 
mechanisms 
protecting 
shareholder rights 
are insufficient, takes 
additional steps 
to protect the rights 
and legitimate 
interests 
of the Company’s 
shareholders.
In doing so, 
the Company 
is guided not only 
by the formal 
regulatory 
requirements, but 
also by the corporate 
governance principles 
specified in the Code

7.2. The Company ensures that material corporate actions are taken in a manner enabling shareholders 
to receive full information on such actions in due time and influence them, and guarantees 
respect and due protection of shareholder rights when such actions are taken

7.2.1

7.2.2

Information 
on material 
corporate actions 
is disclosed, 
with an explanation 
of the relevant 
reasons, conditions 
and consequences

Rules 
and procedures 
for taking material 
corporate actions 
are set forth 
in the Company’s 
internal regulations

1. 

In the reporting period, the Company 
disclosed information on its material 
corporate actions (if any) in a timely 
and detailed manner, including 
the relevant reasons, conditions 
and consequences for the shareholders

Complied with
Complied with in part
Not complied with

In the reporting period, the Company 
disclosed information in line 
with the requirements of the Bank 
of Russia and the Federal Agency 
for State Property Management.

Complied with
Complied with in part
Not complied with

1.  The Company’s internal regulations 
set out the rules and procedure 
for engaging an appraiser to determine 
the value of the property to be sold or 
purchased in a major transaction or 
a related-party transaction.

2.  The Company’s internal regulations 
set out a procedure for engaging 
an appraiser to determine 
the value of the Company’s shares 
to be purchased or bought back.
3.  If a member of the Company's Board 
of Directors, the sole executive body, 
a member of the collegial executive 
body, or a person who is a controlling 
person of the Company or a person 
entitled to give the Company binding 
instructions has no formal interest 
in the Company's transactions, but 
has a conflict of interest or other 
actual interest with regard to such 
transactions, such persons shall 
abstain from voting on the approval 
of such transactions as required 
by the Company's internal documents

81

  
  
  
  
  
  
  
  
  
  
ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

THIS ANNUAL REPORT HAS BEEN PREPARED 
BASED ON THE FOLLOWING LOCAL 
(INTERNAL) REGULATIONS OF ROSNEFT:

Information on core internal 

regulations that serve as a basis 

 ● Charter;

for the preparation of this 

annual report, including key 

internal documents regulating 

the internal audit function 

and the functioning of the RM&ICS

 ● Rosneft’s Corporate Governance Code;

 ● Code of Business and Corporate Ethics of Rosneft;

 ● Regulations on the General Shareholders Meeting;

 ● Regulations on the Board of Directors;

 ● Regulations on Rosneft Board Committees;

 ● Regulations on Remunerations and Compensations Payable to Members of the Board of Directors;

 ● Regulations on the Collective Executive Body (Management Board);

 ● Regulations on the Sole Executive Body (Chief Executive Officer);

 ● Standard on Payments and Compensations to Top Managers;

 ● Regulations on the Audit Commission;

 ● Regulations on Remunerations and Compensations Payable to Rosneft’s Audit Commission Members;

 ● Regulations on the Corporate Secretary;

 ● Regulations on the Information Policy;

 ● Regulations on Provision of Information to Rosneft Shareholders;

 ● Regulations on Internal Control Rules for the Prevention, Detection and Suppression of Illegal Use of Insider 

Information in Rosneft and/or Market Manipulation;

 ● Rosneft’s Dividend Policy;

 ● Company Policy on Combating Corporate Fraud and Involvement in Corruption Activities;

 ● Company Policy on Internal Audit;

 ● Company Policy on Risk Management and Internal Control System;

 ● Company Policy on Health, Safety and Environmental Protection.

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General information 
about Rosneft

Date of state registration 
and registration number of Oil Company 
Rosneft:
 ● date of state registration 

of the Company as a legal entity: 
7 December 1995;

 ● Number of State Registration 
Certificate of the Company: 
024.537;

 ● date of entry in the Uniform State 
Register of Legal Entities about 
a legal entity established prior 
to 1 July 2002: 12 August 2002;
 ● series and number of Certificate 

of Entry in the Uniform 
State Register of Legal 
Entities about a legal entity 
established prior to 1 July 2002: 
series 77 No. 004856711;
 ● Primary State Registration 

Number under which entry about 
the establishment of the Company 
is made in the Uniform State 
Register of Legal Entities: 
1027700043502.

Constituent entity of the Russian 
Federation in whose territory 
the Company is registered: Moscow.

Main types of operations 
of the Company: geological prospecting 
and geological exploration work 
aimed at oil, gas, coal and other 
minerals search; extraction, 
transportation and processing 
of oil, gas, coal and other minerals 
and timber; production of oil products, 
petrochemicals and other products, 
including electric power, woodworking 
products, fast moving consumer goods 
and provision of services to the public; 
storage and sale (including sale 
in the domestic market and export 
sale) of oil, gas, oil products, coal, 
electric power, woodworking products, 
and other hydrocarbon and other 
derivatives.

Pursuant to Decree of the Government 
of the Russian Federation No. 1226-r 
dated 20 August 2009, Rosneft 
has been included into the list 
of strategic enterprises charged 
with implementation of uniform public 
policy in those branches of economy 
where such entities operate.

Pursuant to Decree of the President 
of the Russian Federation No. 688 
dated 21 May 2012, Rosneft has been 
included into the list of strategic 
enterprises and strategic joint-stock 
companies.

ABOUT THE COMPANY

CORPORATE
GOVERNANCE

APPENDICES

ROSNEFT ANNUAL REPORT 2022

Contact details

FULL NAME:

FOR INSTITUTIONAL INVESTORS:

Public Joint-Stock Company Rosneft Oil 
Company

Investor Relations Department,  
Rosneft  
Telephone: +7 (495) 411-05-04  
 ir@rosneft.ru
E-mail: 

ABBREVIATED NAME:

PJSC Rosneft Oil Company

RAS AUDITOR OF THE COMPANY:

TSATR – Audit Services LLC  
77 Sadovnicheskaya Embankment,  
Bldg. 1, Moscow, 115035, Russia  
Telephone: +7 (495) 705-97-00;  
+7 (495) 755-97-00  
Facsimile: +7 (495) 755-97-01

REGISTRAR OF THE COMPANY:

Reestr-RN LLC  
2/6 Podkopaevsky Lane,  
Bldg. 3–4, Moscow, 109028, Russia  
Telephone: +7 (495) 411-79-11  
Facsimile: +7 (495) 411-83-12  
E-mail: 
Website: 

 support@reestrrn.ru  
 www.reestrrn.ru

MOSCOW OFFICE:

10 Butyrskiy Val, Bldg. A, 13th Floor, 
Moscow, 125047, Russia  
Telephone: +7 (495) 967-71-13

LOCATION OF THE COMPANY:

26/1 Sofiyskaya Embankment, Moscow, 
117997, Russia

POST ADDRESS:

26/1 Sofiyskaya Embankment, Moscow, 
117997, Russia

INFORMATION SERVICE:

Telephone: +7 (499) 517-88-99  
Facsimile: +7 (499) 517-72-35  
Telex: 114405 DISVO.RU  
E-mail: 

 postman@rosneft.ru

FOR SHAREHOLDERS:

Shareholder Relations Division, 
Corporate Governance Department, 
Rosneft  
Telephone: +7 (495) 987-30-60;  
8 (800) 500-11-00 (calls from Russia 
toll-free)  
Facsimile: +7 (499) 517-86-53  
E-mail: 

 shareholders@rosneft.ru

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