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COMMUNITIES RELATIONS MANUAL SUMMARY

1. PURPOSE

Establish guidelines for the interaction and strengthening of relations with the communities and with the different social actors involved in the development of the territories in the area of influence of Promigas and its related companies, in order to contribute to the improvement of the quality of life in the regions where the operations take place.

2. SCOPE

The content of this Manual applies to all activities carried out by Promigas personnel, contractors and suppliers and related companies involving interaction with the stakeholder communities and their social actors.

3. GENERAL TERMS

This Manual is governed by the Corporate Social Policy of Promigas and its related companies, and the principles set forth therein with respect to stakeholders relations, and constitutes a framework for action by the company's officers and contractors that have interactions with the communities of the area of influence, with the aim of strengthening the company-community relations.

4. INTERACTION WITH COMMUNITIES

4.1 IDENTIFICATION OF STAKEHOLDERS, SOCIAL ACTORS AND THEIR ROLE IN INTERACTIONS WITH THE COMPANIES

Actors	Role played in their relationship with Promigas
Neighboring residents of the infrastructure of companies (organized communities, urban dwellers, peasants and rural dwellers).	Allies in maintaining the integrity of the infrastructure of companies and in achieving a secure environment. They experience the impacts of integrity, maintenance, operations and construction activities, which must be informed.
Ethnic minorities.	They should be consulted about the impact of the projects developed in their territories.
Property owners (people, organized communities, indigenous communities and authorities representing public lands).	Spokepersons to carry out negotiations that facilitate the works of expansion, maintenance, transit, among others (negotiation that can be individual or collective).
Departmental or local authorities and relief agencies.	Key actors for the development of integrity, maintenance and operations activities for the adequate relationship with the communities. Determinant actors in the prevention and contingency plans (in case of emergencies).
Communities that receive the social programs of the companies and foundations	Principals, teachers, students of public educational institutions, beneficiaries of educational community development programs. Youth and families of limited resources who are offered opportunities for entrepreneurship and business initiatives. Local governments that are offered assistance in planning processes for the design and implementation of public policies that facilitate the proper functioning of the education sector.
Community Associations and Representatives.	Multipliers of the work of prevention of emergencies and mediators for the relationship between companies and the community.
Customers.	Beneficiaries of the public service of natural gas and electricity

STAKEHOLDERS MAP

Below are some general guidelines for an assertive relationship with the communities.

4.2 GUIDELINES FOR COMMUNITY RELATIONS

4.2.1 DIALOGUE WITH COMMUNITIES AND SHARING OF ACTIVITIES/PROJECTS

In order to achieve effectiveness in the relationship with communities, the following should be considered:

Identify community leaders with whom to establish contact.
Introduce the company.
Present the projects or maintenance activities to be developed, the possible social and environmental impacts of the work, the mitigation measures to be implemented.
Open dialogue on the perceptions and expectations of the parties.
Information about the channels established for the reception of Petitions, Claims, Complaints and Suggestions and to keep a fluid communication with the company, with contractors.
Training for all employees and contractors who develop interaction activities with the communities on environmental and community management standards, the Promigas Declaration of Human Rights, before initiating the activities and then periodically.

4.2.2 Hiring of Labor and Local Goods and Services

Define, according to the activities to be developed, the amount of labor that will be required from the community and the duration of the work to be hired.
Specify and inform what will be the goods and services that can be contracted with the communities.
Hiring must be performed using a Public Employment System, if any.
Establish agreements between the contractor and the communities clarifying the scope and terms of the contracts.

4.2.3 Damage prevention and effects from the activities or projects

Identify expected environmental aspects and impacts for the activities that will be developed.
Implement prevention and operational control standards for environmental aspects and impacts, the Environmental Management Plan measures defined for the project or activity, and the environmental management and community management standards of the company.
Verify and follow up on the implementation of these standards.
Make neighborhood records before and after the construction and maintenance activities.

4.2.4 Communication and reporting mechanisms for the communities

Means used for the disclosure of information:

Workshops and or meetings.
Megaphone broadcast.
Telephone contact.
Written communication delivered to the recipient or representative in the entity.
Brochures or flyers with project information.
Bulletin boards in the communities.
Press releases issued by the Corporate Communications Department.
Statements delivered by an official spokesperson assigned by the organization.

Petitions, Claims, Complaints and Suggestions

The company has a Petitions, Claims, Complaints and Suggestions response procedure and each project must have a formal Petitions, Claims, Complaints and Suggestions reception and service mechanism. The receipt of and prompt response to community requests must be maintained. The community must be made aware that, in case of any violation of human rights, the company has a reporting system consisting of a toll-free telephone number 018000912577 and a website, www.reportesconfidencialespromigas.com, which are managed by an external firm that ensures confidentiality. Also by e-mail: pqrs@promigas.com.

4.3 CONFLICT PREVENTION AND RESPONSE STRATEGIES

4.3.1 Good Neighbor Strategy

This is the strategy for the relationship with communities, focusing on direct and indirect employees of the companies and in general on all contractor personnel developing activities on site, be it construction, maintenance, studies or social programs, and on the contractors of the social projects and the personnel of the framework and land negotiation contractors, who in the development of their activities have a permanent interaction with the communities and land owners in the areas of influence of the companies.

Take advantage of existing interactions between officials and contractors and communities, to generate first-hand information related to communities and their dynamics in the territory.
Keep the company informed, through contract administrators and managers, about relevant issues for Social Management decision making.
Solve, without generating expectations, the questions or concerns that may arise in the community with respect to the processes that the company carries out in matters of maintenance and/or construction, prior approval of a script by the company.
Achieve a natural relationship in the daily routine and not sporadically associated with special events.
During the interaction in the territory and with the inhabitants of the communities, identify situations that could become a trigger for conflict in the relations between the company and the community and situations that affect the integrity of the pipeline and put at risk both the communities located in the area of influence and the Company employees and contractors. This shows a specific interest of Promigas in strengthening and generating new bonds.

4.3.2 What should be taken into account for Conflict Response?

Consider:

Legitimacy of the leaders who represent the community.
Verify with the representatives of the community the accuracy of what is stated in the verbal or written communications.
Clarify with those responsible for the projects and/or operations the social/environmental aspects/impacts reported by the communities caused by the activities, especially those that spread poor information among the communities.
Agree on actions to remedy possible damages and comply with the established commitments.
Prepare minutes with the commitments established in the different meetings.
Provide timely information to interested publics about progress in the performance of agreements and commitments or about variations in activities that were already informed.

4.3.3 Conflict response according to the level of complexity

Low

Medium

High

Immediate possibility of response on site, for cases such as noise, requests for information, construction authorizations in the area determined by the company, inconvenience due to delays in works, minor effects, petitions, complaints, reports or requests that motivate communities to claim an economic or social benefit.

Situation that alters work schedules, without permanently stopping the company's operation, such as unauthorized excavations, legal claim for information, right of way invasion, negotiations, fires and damages that could harm the integrity of the gas pipeline, among others.

Situations of conflicts with actions such as blockages, threats or manipulation of equipment or gas infrastructure, risks to the physical integrity of people, repeated noncompliance by the company with communities or owners of the area of influence, high expectations of economic and/or materials benefits or breakdowns of collective negotiations, among others.

o Easement and Compensation Professional

o Communities Professional

o Industrial Safety Professional

o Maintenance Professional

o Infrastructure Project Management Professional

o Physical Security Professional

o Sustainability and Environment Management

o Land Management Coordination

o Maintenance Coordination

o Construction Management

o Physical Security Coordination

o Legal Affairs Office

o Construction Management

o Maintenance Management

o Sustainability and Environment Management

o Corporate Affairs Vice President

o Community Relations Team

5. GOVERNMENT BODIES IN RELATIONS WITH COMMUNITIES

5.1 COMMUNITY RELATIONS TEAM

Interdisciplinary group led by the Corporate Affairs Vice President or whoever acts on his behalf in each of the companies and made up of representatives of the companies included in the scope of this manual and according to the foundations of positions that must interact or coordinate interactions with the communities .

The meetings of the community relations team are understood as spaces for planning, reflection and learning, where each of the participants contributes their skills and competencies to achieve strategic interactions with the community, assess the results of the interactions, the construction of agreements and the definition of best practices on community relations actions. Further information about the composition of this team can be found in

5.2 COMMUNICATION OF RESULTS

The established means to communicate the results of the management with communities and to maintain an effective communication between the members of the team are:

Ordinary meetings every three months, in which the area in charge of social management within each company coordinates the presentation of the results of the management with communities in the previous period, including among other topics the trend of Petitions, Claims, Complaints and Suggestions and the requests met or refused.
Scheduled meetings between those in charge of social management of corporate companies in order to identify good practices in the area of community relations and share lessons learned.
Meetings established to respond to special cases.

6. GUIDELINES FOR SOCIAL INVESTMENT

Strategic social investment refers to the investment made within the framework of the company's social management and that seeks to facilitate access to the territories and the social license required by the company to operate within them, according to the social management guidelines defined in the Social Management Policy.

Social investment programs are carried out in prioritized communities according to the criteria, and are defined within two material issues of the strategic approach: Local Development and Quality of Education.

We consider donations, institutional agreements and social management initiatives as strategic social investment, which serve to support the communities of the area of direct influence, considering: i) the socioeconomic and environmental characterization of the communities; ii) the impacts of the company activities; and iii) the development outlook of the communities themselves.

6.1 PRIORITIZATION OF COMMUNITIES

6.1.1 CRITERIA FOR IDENTIFICATION

To define the communities on which the actions of the annual investment plan should be concentrated, the companies will review the populations in light of the following criteria, with which a matrix of priority communities will be annually established:

Real or potential impacts: This criteria includes the communities influenced by the routine and non-routine activities developed by the companies, related to the construction of projects and activities such as operation of stations, expansion of networks and maintenance of the infrastructure of the companies.

Ethnic or cultural factors: Ethnic, Afro or Raizal communities, settled on the area of influence of the companies.

Background: Regarding communities that have been historically affected by situations related to the construction of projects, the operation of the pipeline, easement negotiations or communities that recurrently submit petitions, requests or complaints to the company.

Qualification of variables: To determine the communities that will be a priority in the Promigas programs and the social management carried out by the Promigas Foundation, an assessment of the variables is established according to a scale of 1 to 4 points: Low (1), Medium ( 2), High (3) and very high (4).

According to the results, the following ranges are established for the intervention:

From 1 to 6 points, communities with low or no intervention level.
From 7 to 12 points, communities with medium intervention level.
From 13 to 18 points, communities with high intervention level.
From 19 to 24 points, priority communities with very high intervention level.

In addition, the independent valuation of the variables shows the specific aspects to work on in the communities and that require the allocation of resources.

The results in the ranges for the intervention are updated annually and may vary according to the interventions made or the social, economic and environmental changes that occur in the territory.

This assessment scheme provides guidelines for the prioritization of actions aimed at social investment in communities, but does not limit the implementation of programs defined by the operational plan of each unit or the Promigas Foundation. In any case, for the approval of social investments, the procedure applicable within the purchasing policies of each company will be followed.

6.2 STRATEGIC SOCIAL INVESTMENT PLAN

6.2.1 Allocation of Resources

The resources allocated for social management should be based on the Strategic Social Investment Annual Plan that must be prepared and submitted for approval to the area in charge of social management in each company.

The Community Relations Team will be the body that validates whether social investments are made in accordance with the provisions of this manual and the Corporate Social Policy, supporting communities in their development processes, taking advantage of the opportunities offered by the company.

The investments made and prioritized by this strategic plan are additional to the mandatory investments undertaken by the company with the local communities as a result of the need to compensate for environmental and social impacts caused by a particular project.

We consider as social strategic investment the donations, institutional agreements and social management initiatives that serve to support the communities of the area of direct influence.

6.2.2 Protocol for donations to the communities.

For donations to the communities, Promigas and its companies are governed by the Standard for the Compliance with the Foreign Corrupt Practices Act (FCPA) GNA-754[1], which provides in point 5.1.2.6 the procedure to be followed.

The donee, in case of being a natural person, must first complete the Donation Evaluation Request Form - F9-M-AR-AFAC-01 and sign a Delivery Certificate once materials FA-1647 are received.

All documents generated must be stored in the Document Administration Center (CAD) of each company, ensuring the traceability of the actions carried out.

6.2.3 On environmental compensation

Companies must evaluate the economic, social and environmental impacts of all works or activities, and arrange and compensate for any possible damages. This process is not part of the scope of action of the Community Relations Team; however, the information derived from it is essential to generate lessons learned in the development of community relations.

COMMUNITIES RELATIONS MANUAL SUMMARY​

1. PURPOSE​