Our business is led by a dedicated and experienced management team, diverse in age, nationality and gender. This is integral to advancing the Group’s approach to diversity throughout the business.

Whilst we are encouraged by our diversity at Board and department head levels, we do recognise that diversity remains an ongoing issue in the oil and gas industry, particularly with regards to gender diversity. We strive to be an attractive place to work with an inclusive environment that celebrates diversity. Nostrum is committed to improving the gender balance at all levels of the Company, and in 2018 & 2019 we engaged with interest groups to better understand how we might do this. Additionally, Nostrum adopted a corporate Equality and Diversity Policy in November 2017 to further support these ambitions. At present, 22% of Group employees are female. In the UK, 47% of employees are female.

The Board recognises the importance of continued improvement in this area, and is committed to giving due regard to the benefits of diversity in our future appointments, including ensuring Kazakh nationals are properly represented at senior levels of the Company. The Board also focused on succession planning during 2019, and gender considerations will factor into this. Currently 22% of employees at department head level are female.

In addition, Human Resources is working toward a policy of promotion from within and building a pipeline of diverse employees at all levels of the business. We are pleased to report that 30% of Group recruitment in 2019 was female. There were no recorded discrimination incidents with any of the Group’s employees in 2019.

For more information on how the Equality and Diversity Policy was implemented at Board level in 2019, please see page 69. In 2019, 16 employees (1 male and 15 females took maternity/paternity leave and 19 employees (1 male and 18 females) returned from maternity/paternity leave.

Nostrum prides itself on being an integral community partner, and the Company is one of the largest employers in Western Kazakhstan, with 96% of Group employees engaged locally. We employed a total of 668 staff from more than 17 countries, broken down as follows:

• Uralsk: 483 males, 159 females;
• St. Petersburg: 4 males, 3 females;
• London: 10 males, 5 females;
• Brussels: 1 male, 1 female;
• Almaty: 0 males, 2 females.

We offer all staff members competitive benefits and remuneration packages in compliance with all regulatory bodies, guidelines and requirements, which (to the extent applicable) are also applied to those hired as temporary or part-time employees. In 2019 the average monthly salary of locally engaged employees increased by 12% in KZT.

In an effort to promote gender equality, we will now also monitor gender pay discrepancies. In 2019, the average Group employee salary was 22% higher for males, however the median employee salary was 3% higher for females. This data was not recorded by category and workplace.

We believe investing in our people is key to economic self-empowerment in the communities in which we operate. Under the terms of our PSA, we are required to adhere to an accrual of 1% per annum of the field development cost relative to the Chinarevskoye field. We also adhere to training obligations under subsoil use agreements for the Rostoshinskoye, Darjinskoye and Yuzhno-Gremyachinskoye fields.

There was no advanced training in addition to that required under the PSA and the other subsoil use agreements. There was no assistance for employees who stopped working as a result of retirement or termination of employment.

Our employees and their children are eligible for educational grants and financial support to assist with university and college expenses. Educational fellowships and assistance may also be awarded on a discretionary basis.

In 2019, Nostrum supported 722 employees to benefit from education and training programmes. Our total Group training costs in 2019 were US$2,068,225, and the total number of training days in 2019 was 7,264 days.

Training was undertaken by operational teams, department heads, specialist engineers and other technicians at different levels across the organisation. The average number of training hours per employee by gender and category was not recorded.

More than 200 employees were released in 2019. This was the main cause of staff turnover. The number of employees hired in 2019 was 77 (11.5%) of which 30% were female and 70% male.

In 2018, the Company put collective agreements in place to provide for workforce representation and, in 2019, the Company designated a non-executive director, Sir Christopher Codrington, to serve as its liaison for engagement with the workforce.

The Board of Directors strives to adopt best practices in corporate governance, including engagement with the Group’s workforce.In particular, the Board wishes to understand the views of the Group’s workforce and to take such views into consideration in Board discussions and decision making.Communication between the workforce and the Board is often referred to as the ‘employee voice’, and it is hoped that a wide selection of views from the workforce can be gathered through a range of formal and informal channels.Such channels are intended to help the workforce share ideas and concerns with senior management and the Board.It provides useful feedback about business practices from those delivering them, and can help empower colleagues.The Board encourages individuals to raise any concerns they may have.Doing so acts as an early warning system for actual or potential problems and helps to manage risk.The Board actively listens to workforce concerns and subsequently provides feedback on how the matter raised has been considered, including any action taken. The Board emphasised that the workforce felt safe to raise concerns.

There is no requirement under applicable laws for the Company to notify its employees of significant changes relating to its activities.

Nostrum is committed to maintaining a Group-wide culture that recognises international standards of human rights.

In 2019, the Company developed and implemented a Human Rights Policy which reflects the Company’s desire to comply with industry best practice. There was no training on this policy in 2019.

This is in addition to the Nostrum Code of Conduct (“the Code”) which defines the principles that guide business conduct and provide a non-exhaustive outline of what Nostrum considers permissible conduct by its employees. These principles include provisions relating to human rights and diversity in the workplace, inside dealing and inside information.

A copy of the Code is available on the Group’s intranet in both Russian and English, and can be downloaded from our website: www.nog.co.uk.

There are no divisions of the Group (or its vendors) believed to have significant risk of child/forced labour/hazardous work performance by young employees.

Under the Group’s standard supply contracts, the Group is entitled to require suppliers to demonstrate compliance with the Code and to hold its suppliers responsible for compliance by their supply chain with equivalent terms.

A copy of our Modern Slavery and Transparency Statement is available on our website: www.nog.co.uk.

We have a Whistleblowing Policy which takes into account the Whistleblowing Arrangements Code of Practice issued by the British Standards Institute and Public Concern at Work, and which applies to all individuals working for the Group at all levels and grades.

The Whistleblowing Policy sets out details of three compliance liaison officers who speak a variety of languages for the purposes of reporting any concerns. The Whistleblowing Policy is also mentioned in the Code, and a person who reports any matter in good faith will be protected against any sanctions.

A copy of the Whistleblowing Policy is available in both Russian and English and on the Company’s website. At the time of writing, we have received no reports under our Whistleblowing Policy of forced/involuntary labour or human trafficking in relation to our business or supply chains. For further details, please see our website: www.nog.co.uk