Modern Slavery Statement 2017

This statement is made in accordance with the Modern Slavery Act 2015 and sets out the approach taken by Ophir Energy plc (“Ophir”) and its subsidiaries (together the “Ophir Group1”) to modern slavery risks related to its business and explains the steps Ophir has taken to prevent modern slavery across its operations and supply chain. This statement relates to the financial year ending 31 December 2017.

1 Ophir Group includes all directly or indirectly wholly owned subsidiaries of Ophir Energy plc

Our business

Ophir is an independent oil and gas exploration and production company with operations in Africa, Asia and the Americas. Ophir takes a zero tolerance approach to slavery and human trafficking and such exploitation is entirely at odds with our values. We recognise the potential for human rights violations, particularly human trafficking and slavery, in our industry and the increased risk in certain locations we operate in. Ophir is committed to ensuring this is not present in any part of our business and supply chain.

Our policies and procedures

Ophir’s Code of Conduct is based on our values and sets out clear guidelines as to how we expect our people and stakeholders to act across the Ophir Group. Our Code of Conduct recognises the importance of respecting and promoting human rights, both internally and externally, and confirms Ophir’s commitment to maintaining the fair and equal treatment of all our employees and contractors. These values are reinforced in our recruitment and procurement policies and processes. Ophir supports, and is committed to conducting our business in line with, the UN Guiding Principles of Business and Human Rights.

Our employees are required to report any human rights abuse either in Ophir’s own operations or in that of our business partners and suppliers. An anonymous whistleblowing hotline is in place which enables our employees and third parties to report any wrongdoing or concerns on a range of matters, including human rights violations such as slavery and trafficking. Every incident of whistleblowing is reported to our Board of Directors and investigated fully with appropriate remedial action taken.

Training on the standards and guidelines in our Code of Conduct and other ethical compliance policies is provided to all employees. Our compliance programme also requires employees to sign off annually to confirm adherence with these policies and for senior management to provide written assurance confirming compliance across all areas of the business. Moving forward we are aiming to provide more tailored training on slavery and human trafficking risks, particularly in those areas of the business where the risk is greatest, in order to increase knowledge and awareness.

Any failure by our employees to adhere to our Code of Conduct and our policies is addressed and may result in disciplinary action, up to and including dismissal. If a contractor or supplier fails to act in accordance with their contractual obligations and our expectations this may result in the termination of their contract with Ophir.

Assessing the risk of modern slavery

Our Group-wide risk management approach provides a clear mechanism for identifying risks, assessing mitigating actions and establishing responsibility. The primary potential risk of slavery and human trafficking identified is our supply chain. Many of our contractors and suppliers have highly skilled workers and demonstrate robust ethical compliance systems. However, in certain cases, contractors may rely on less skilled or casual labour and may operate in countries where ethical compliance is less entrenched, which increases potential risks.

Managing risks in our supply chain

Ophir’s procurement controls include a robust screening process. Our Ethical Compliance Due Diligence process takes a risk-based approach to assessing potential contractors and suppliers. This process includes obtaining information from potential suppliers regarding their own ethical compliance policies and processes and whether steps are taken, within their own business or that of their subcontractors, to identify instances of slavery or trafficking.

Ophir expects all contractors and suppliers to act in accordance with our Code of Conduct and key ethical compliance policies and to uphold our values. In support of this our Code of Conduct and key policies form part of our standard contract terms with contractors and suppliers. Our whistleblowing system is also available to contractors and suppliers to report any human rights violations.

As we continue to refresh due diligence on existing suppliers and on-board new suppliers this enables us to identify potential issues to then improve our controls and communicate the risks more effectively to our own people and business partners. We recognise that as the supply chain moves beyond our immediate suppliers and contractors our ability to control potential risks decreases. However, we will continue to monitor risks across our operations and seek to mitigate these risks, as well as work with our contractors and suppliers to increase awareness and understanding of the issues to influence the supply chain.

Assessment of effectiveness

We seek to conduct our business to a high standard of integrity and this includes working to ensure that slavery and human trafficking are not present in our operations and supply chain. Our annual Corporate Responsibility Report includes information on our performance in achieving positive economic, social and environmental impacts across our operations and the communities we operate in. We will continue to strengthen our controls and mitigate the risks of slavery and human trafficking, and work with our business partners, contractors and suppliers to prevent violations. At the time of writing we are not aware of any incidents or accusations of slavery or human trafficking in relation to our operations.

This statement has been approved by the Ophir Energy plc Board on 15 May 2018.

Alan Booth

Interim Chief Executive Officer and Executive Director