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Grievance Procedure

In implementing the Human Rights Policy, Sakhalin Energy focuses on grievance mechanisms and open dialogues with personnel, contractors, and the public.

The Company has developed and implemented a Community Grievance Procedure that represents some of the best global practices.

A grievance is any actual or potential problem that leads to expressing dissatisfaction or concern.

The procedure includes six steps with timelines assigned for addressing grievances:

Step 1: Receiving a grievance
• Via the whistleblowing hotline 8 800 200 6624 (toll-free in Sakhalin Oblast).
• Via one of Sakhalin Energy's information centres (for addresses of the centres, please visit the Company's website or call 8 800 200 6624).
• Via email Grievancereport@sakhalin2.ru
• Via the corporate website www.sakhalinenergy.ru (Feedback section).
• By mail: 35 Dzerzhinskogo St., Yuzhno-Sakhalinsk, 693020, Russian Federation (Attn: Corporate Affairs Division).

Step 2: Grievance assessment and registration, appointment of action parties
When reviewing a grievance, the Sakhalin Energy Grievance Committee shall appoint action parties to deal with the grievance and work with the initiating party. Grievances are recorded in an automated incident registration system, which allows for tracking grievance resolution steps via automatic updates to the appointed action parties and their line managers.

Step 3: Written Notification
Sakhalin Energy shall send a letter to the grievance initiator specifying the grievance registration number and the details of the contact person.

Step 4: Investigation, resolution, and communication
Sakhalin Energy shall identify reasons for the grievance and take measures to resolve it. If the grievance is not resolved within the established period (45 working days), the automated incident registration system notifies the action parties and their line managers about the expiry of the grievance resolution period. If the grievance cannot be resolved in time for reasons beyond control, Sakhalin Energy and the grievance initiator shall sign an agreement to extend the period for resolving the grievance.

Step 5: Grievance close-out
If the grievance initiator agrees that the grievance has been resolved, Sakhalin Energy shall have him/her sign a statement of satisfaction with the interaction process and its outcomes. If the grievance remains unresolved, it shall be re-examined and further measures to resolve it shall be discussed with the grievance initiator.

Step 6: Follow-up (Monitoring)
Monitoring of grievance resolution results: If the grievance initiator has no objections, Sakhalin Energy may contact him/her to make sure that the Company’s activities do not cause further concern.

The Grievance Procedure requires that all grievance-related issues be dealt with confidentially. The identity of the grievance initiator and the content of the grievance shall not be disclosed to third parties without the written consent of the grievance initiator.