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Management Approach

Integrating sustainability principles into all levels of NOVATEK’s corporate governance is strategically important to the Company.

The Company ensures effective oversight of its approach to and performance on sustainability through dedicated Board of Directors committees, with top management’s motivation system containing relevant sustainability-linked key performance indicators.

The Company implements advanced international and national management system standards and takes an integrated approach to sustainability management. Sustainability management is seamlessly integrated into the corporate governance system, ensuring comprehensive attention is paid to these matters across different levels, from the Board of Directors — the highest strategic management body — to the executive bodies and heads of specific business units.

Within the executive bodies, responsibility for each sustainability dimension is assigned to the respective Deputy Chairman of the Management Board.

To drive the implementation of management decisions, corporate documents have been developed to regulate internal sustainability and related risk management practices.

Sustainability Corporate Governance System

* At the time of the Board of Directors election on 12 May 2025.
The 2025 corporate year is counted from the date of the Annual General Meeting of Shareholders on 17 April 2025 to the Annual General Meeting of Shareholders on 1 April 2026.

The General Meeting of Shareholders	NOVATEK’s highest governance body — pays particular attention to the effectiveness of interaction with its shareholders and strives to maximize the transparency and completeness of the information provided to them.
Board of Directors	Functions: setting strategic priorities across all areas, from climate, biodiversity, and water resources to human rights protection and engagement with indigenous peoples of the Far North; approving sustainability reports and their material topics
Remuneration and Nomination Committee	Functions: establishing effective and transparent remuneration of members of the Company’s governance bodies and building up their expertise; planning HR management activities; and reviewing reports on industrial safety, environmental protection, climate impact, corporate governance, and social activities, as well as the Company’s sustainability reports on an annual basis.
Strategy Committee	Functions: defining strategic goals and overseeing the implementation of the sustainability strategy; making recommendations on the dividend policy; and evaluating the long-term effectiveness of the Company’s operations.
Audit Committee	Functions: overseeing the internal and external audit functions; and supervising the performance of the risk management (including climate risks), internal control, and corporate governance systems.
Subcommittee on Climate and Alternative Energy under the Strategy Committee	Function: providing recommendations to the Board of Directors on matters related to NOVATEK’s climate and decarbonization strategy, renewable development, and low-carbon fuel production.

Risk Management and Internal Control System

NOVATEK’s business model is based on a robust risk and opportunity management system, helping the Company achieve its operational and strategic goals while minimizing potential threats. NOVATEK is constantly improving its risk management practices and optimizing its portfolio of insurance programs.

NOVATEK operates a multitier risk management and internal control system (RMICS). The system is structured in accordance with Russian and international best practices, incorporating concepts from the Committee of Sponsoring Organizations of the Treadway Commission (COSO) and Institute of Internal Auditors (IIA), recommendations from the Bank of Russia, etc.

NOVATEK regularly monitors changes in the market environment, geopolitical situation, and regulatory and legal framework to assess their potential impact on the achievement of the Company’s operational and strategic goals.

The main principles, approaches, goals, objectives, participants and their obligations and interaction procedures of the RMICS are governed by PAO NOVATEK’s Regulations on Risk Management and Internal Control System, approved by the Board of Directors.

PAO NOVATEK’s Board of Directors approves the key principles and approaches for establishing the RMICS and sets the level of risk appetite. The Audit Committee of the Board of Directors regularly reviews reports of the Company’s management on the status of risk and opportunity management, assesses the appropriateness of the established level of risk appetite, and, if necessary, instructs management to run an in-depth analysis of individual risk areas within the Company’s activities.

A dedicated unit is responsible for coordinating the Company’s risk management activities and securing insurance coverage for the Company. NOVATEK regularly identifies and assesses risks and opportunities and defines actions to manage them at all levels of corporate governance.

To describe and monitor risks and opportunities, including those related to sustainability, the Company uses risk and opportunity maps, which are submitted to the Management Board and the Audit Committee of the Board of Directors on the annual basis.

The Risk Map categorizes all of the Company’s existing risks, including their current status, risk assessments, and mitigation measures being implemented to reduce their negative impacts. The Opportunity Map includes a list of areas with high development prospects and generation of additional economic benefits, along with the current implementation status of opportunities and planned initiatives for

realization. A significant portion of the Company’s opportunities is related to climate change and covers both its physical impacts and urgent issues concerning the global climate agenda.

Risk and opportunity management is embedded across the Company’s strategic, operational, and governance practices.

To improve the quality of strategic and operational decision making, PAO NOVATEK provides training on risk management principles and practices. In the reporting year, such training was delivered to PAO NOVATEK personnel, and in the previous year, to managers. Over 2024–2025, all managers and regular staff at NOVATEK (100% of employees) completed the training.