Stakeholder Engagement Plan (SEP) update_16.03.2021-1

Midia Gas Development Project
Stakeholder Engagement Plan (SEP) – 2021
Black Sea Oil & Gas SA
Document Number:
D01 15/03/2021
Cristina Rus Ana-Maria
Pericleanu
Rev Date Description Issued By
Checked By Approved By
Midia Gas Development Project – Stakeholder Engagement Plan – 2021

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Contents
1 INTRODUCTION........................................................................................................................... 4
1.1 Scope and Objectives of the Stakeholder Engagement Plan ........................................4
1.2 Brief Project Description ...........................................................................................................5
1.2.1 Ana offshore wellhead platform, including topsides and substructure ................... 6
1.2.2 Subsea infrastructure including Doina subsea facilities, Ana-Doina infield
pipeline and pipeline to shore, including beach crossing ....................................................... 6
1.2.3 Gas Treatment Plant (GTP) and associated onshore pipeline .................................... 9
1.3 Current project status and construction works foreseen for 2021 ...................................... 11
1.3.1 Current project status .......................................................................................................... 11
1.3.2 Construction works foreseen for 2021 ......................................................................... 12
2 REGULATIONS AND REQUIREMENTS ............................................................................... 12
2.1 National Requirements ............................................................................................................ 12
2.2 European Bank for Reconstruction and Development(EBRD) Requirements ...... 14
3 STAKEHOLDER IDENTIFICATION AND MAPPING ........................................................... 14
4 STAKEHOLDER ANALYSIS ....................................................................................................... 17
5 PREVIOUS ENGAGEMENT ACTIVITIES .............................................................................. 18
5.1. Engagement with project affected persons (PAPs) ..................................................... 19
5.2. Corporate Social Responsibility (CSR) programme .................................................... 22
5.3 Other engagement activities ................................................................................................. 22
6 STAKEHOLDER ENGAGEMENT PLAN ............................................................................... 23
6.1 Action Plan................................................................................................................................ 23
6.2 Record keeping ......................................................................................................................... 26
7 GRIEVANCE MECHANISM ...................................................................................................... 26
8 MONITORING AND EVALUATION ......................................................................................... 30
9 REPORTING ................................................................................................................................... 31
9.1 Internal Reporting ......................................................................................................................... 31
9.2 External Reporting ........................................................................................................................ 31
10 ROLES AND RESPONSIBILITIES ........................................................................................... 32

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ABBREVIATIONS AND ACRONYMS
Abbreviation or Acronym Definition

The Convention on Access to Information, Public Participation in
Aarhus Convention Decision-Making and Access to Justice in Environmental Matters, signed
in Aarhus on 25 June 1998.
BSOG Black Sea Oil & Gas

CLO Community Liaison Officer
DDBRA Danube Delta Biosphere Reserve Administration
EBRD European Bank for Reconstruction and Development
EIA Environmental Impact Assessment
EPA Environmental Protection Agency
EU European Union
ESIA Environmental and Social Impact Assessment
AESIA Additional Environmental and Social Information and Assessment
FEED Front End Engineering Design
GTP Gas Treatment Plant

GSP Grup Servicii Petroliere
LPA Local Public Authorities
LRP Livelihood Restoration Plan
LRR Livelihood Restoration Report
MEG Monoethylene glycol
MGD/MGD Project Midia Gas Development/Midia Gas Development Project
NGO Non-Governmental Organisation
NTS National Gas Transmission System
PR Performance Requirement
SEP Stakeholder Engagement Plan
TEG Triethylene glycol
TRANSGAZ National Gas Transmission Company

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1 INTRODUCTION
1.1 Scope and Objectives of the Stakeholder Engagement Plan
Stakeholder engagement is a key element in building strong, constructive and responsive relationships
which are essential for the successful management of a project’s environmental and social risks and
impacts. It aims to inform stakeholders about the potential environmental and social impacts related to
the project through appropriate disclosure of information, to ensure their perceptions of the proposed
development are as accurate as possible, to consult with them to obtain feedback, and to provide a
mechanism for resolving any concerns or complaints they might have.
The Stakeholder Engagement Plan (SEP) is a guiding document that maps the main categories of
stakeholders who will be meaningfully engaged within the development and implementation of a project.
This SEP highlights the way the company plans to communicate with these stakeholder groups who
may be affected by or interested in BSOG operations and activities. It focuses on:
• Identification of stakeholders who are likely to be affected and have an interest to the project;
• Establishment of engagement methods that are suitable for each identified category of
stakeholder;
• Documentation of previous engagement activities and stakeholder feedback;
• Development and implementation of the future stakeholder engagement programme, and methods
of engagement;
• Introduction of the project’s grievance mechanism;
• Monitoring and evaluation of engagement actions, and;
• Roles and Responsibilities
This SEP is prepared in relation to the Midia Gas Development (MGD) Project which is currently in the
process of being worked up and implemented by Black Sea Oil & Gas SRL (BSOG). It sets out the
planned programme for disclosure of project information and consultation with stakeholders, as well as
the methods for recording and addressing comments and grievances from various stakeholders.
While the local regulatory framework in Romania only requires an Environmental Impact Assessment
(EIA), the project’s initiator, BSOG, has decided to examine the social implications of MGD as per best
international practice. In light of the planned Environmental and Social Impact Assessment (ESIA)
process, this document establishes the basis of the stakeholder engagement programme for the whole
project. BSOG is committing to support all the engagement activities included in the SEP and to allocate
sufficient resources (human and financial) in order to ensure its implementation.
The SEP is a ‘live’ document that will be progressively developed through updated versions in line with
the phases of the MGD Project. The SEP will be made publicly available on BSOG’s website and will
also be made accessible to local communities as part of the project information disclosure policy and
programme as described below.
BSOG will respect individual stakeholders’ Right to Privacy which is relevant to this SEP in regard to
information relating to personal or private affairs and the protection of communications, including
grievances.
The current version of SEP has been developed during the construction phase.
Given the changes in the Project construction schedule, the execution of construction works related to
the beach crossing partly overlapped with the tourist season. In particular, the HDD site preparatory
activities started end of June 2020, and continued until early September 2020. Actual HDD drilling and
pipe installation works were however performed between 11 September and 8 October 2020, i.e. mostly
after the end of the touristic season (2020 touristic season at Vadu Beach started late, at 1st of June
and ended in 15th of September).
Given the above, the requirement to develop and implement adequate livelihood restoration planning
measures was triggered. However, circumstances beyond BSOG control and mainly triggered by the
restrictions imposed as result of the COVID-19 outbreak, prevented the development and
implementation of the Livelihood Restoration Plan (LRP) due to the following:
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• The lockdown including strict travel restrictions and social distancing measures did not allow the
development of an LRP upfront of the initiation of the preparatory works at the beach crossing area
(also referred to as “the HDD site” throughout the document). Hence the need for an alternative
approach allowing adequate response to a constantly changing course of events.
• The evolution of the touristic season was unpredictable and consequently the full impacts of the
Project on tourism were unknown and could not be evaluated before the initiation of the Project
works at the beach area.
In this context, to ensure that the commitment to compensate for any Project-induced loss of income or
for Project-induced loss of other means of livelihood is attained, a number of measures were undertaken
as indicated below.
An Assessment of potential economic displacement situations was initially developed with the following
objectives:
• assess the potential economic displacement aspects identified in the LRF;

• identify all potential economic displacement situations related to the MGD Project considering the
new construction schedule;
• identify/update the Project-affected persons/groups (PAP), and
• define required measures to address potential social impacts experienced by the PAPs in line with
national requirements, LRF, EBRD PR5 and IFC PS5.
The assessment resulted in the identification of a number of actions that needed to be implemented by
BSOG during the construction works executed during the touristic season as follows:
• the social impacts associated with the Project activities developed during the touristic season to be
monitored;
• all impacts and their magnitude to be documented;
• additional data to be acquired based on consultations with PAPs from the two categories of
economic displacement situations:
o owner of restaurant - Cherhanaua Bosoancă, and
o owners/users of land situated in the proximity of roads and land used for the Project.
1.2 Brief Project Description

BSOG is the titleholder (together with Petro Ventures Resources SRL and Gas Plus Dacia SRL) and
operator of the Concession Agreement for Petroleum Exploration, Development and Production in Blocks
XIII Pelican and XV Midia, Contract Area B, located on the continental shelf of the Romanian Black Sea.
The Midia Gas Development (MGD) Project will produce and process gas from the Ana and Doina fields
located in the offshore XV Midia Block.
The MGD Project consists of drilling four wells at the Ana field, where a small, normally unmanned
platform will be installed to house the wellheads and product ion control facilities. A further well will be
drilled at the nearby Doina field as a subsea development, with gas being routed to the Ana field platform
via a subsea 18 km-long pipeline. The gas will then be brought to shore through a single 126 km pipeline
(an upstream pipleine) out of which 121 km is the offshore segment of the pipeline which will have a
landfall at Vadu, Corbu Commune, Constanţa County and a 4.3 km onshore segment of the pipeline,
from the landfall site to the new gas treatment plant (GTP) in the Vadu area where it will be treated prior
to delivery into the national gas transmission system (NTS).
The concept of the MGD Project is presented in Figure 1.
Figure 1 Concept for the Midia Gas Development Project

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The Project is divided into three packages as described below.
1.2.1 Ana offshore wellhead platform, including topsides and substructure

The facilities at the Ana wellhead platform comprise:
• 4 x platform wells;
• pipework fully rated to well closed in tubing head pressure;
• cold vent;
• helideck;
• chemical storage and injection pumps for mono ethylene glycol (MEG);
• temporary refuge/equipment room;
• lifeboat;
• facilities to enable temporary installation of pig receivers and pig launchers;
• crane; and
• minimal ancillary facilities.
1.2.2 Subsea infrastructure including Doina subsea facilities, Ana-Doina infield

pipeline and pipeline to shore, including beach crossing
The facilities for the offshore subsea infrastructure are:
• Doina: Up to 2 × subsea wells in a daisy chain arrangement controlled via an electro-hydraulic-
chemical umbilical from the Ana platform (initial development is 1 x Doina subsea well);
• Doina to Ana Platform infield pipeline: 8-inch carbon steel pipeline with no concrete coating,
continuously inhibited against hydrates with MEG
• Ana Platform to shore pipeline: 16-inch steel pipeline with a concrete coating for stability,
continuously inhibited against hydrates with MEG; and
• Beach crossing by the pipeline: horizontal directional drilling (HDD).
The offshore segment of the pipeline will cross: Natura 2000 areas of ROSCI (Romanian Site of
Community Importance) 0066 Danube Delta - marine area; and ROSPA (Romanian Special Protection
Area) 0076 Black Sea, as well as the economic area of the Danube Delta Biosphere Reserve (in Romanian:
“Rezervaţia Biosferei Delta Dunării”).

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Figure 2 Sites of Community Importance (SCI) and Proposed SCI

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Figure 3 Special Protection Areas (SPA) and Important Bird Areas (IBA)
Figure 4 The Danube Delta Biosphere Reserve

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Table 1 Protected sites in the vicinity of the MGD Project, offshore section
Site name Site code Location relative to MGD Project

Danube Delta marine zone SCI Extends into offshore; gas pipeline crosses site over
ROSCI0066
(Delta Dunarii – zona marina) a distance of ~52 km
Black Sea SPA Extends into nearshore; gas pipeline crosses site
ROSPA0076
(Marea Neagra) over a distance of ~12 km
Southern lobe of the Phyllophora
field of Zernov SCI
ROSCI0413 Offshore; 32 km to north from landfall
(Lobul sudic al Câmpului de
Phyllophora al lui Zernov)
Canyon of the Brave SCI
ROSCI0311 Offshore; 12.5 km to south east from Ana Platform
(Canionul Viteaz)
Danube Delta Biosphere Reserve n/a The MGD pipeline crosses through the southern tip
of this site, ~12 km through the marine economic
area and ~4.1 km through the onshore economic
area.
Black Sea IBA RO082 Extends into nearshore; offshore pipeline crosses
through over a distance of ~12 km
The offshore segment of the pipeline will cross a crude oil pipeline and a natural gas pipeline owned by
OMV Petrom SA.
1.2.3 Gas Treatment Plant (GTP) and associated onshore pipeline

The onshore facilities of MGD Project are:
• Trenched and buried 16-inch carbon steel pipeline, continuously inhibited against hydrates with
Monoethylene glycol (MEG); and
• Gas Treatment Plant: pig receiver, slug catcher/separator, single stage turbine driven compressor
(with scrubber and air cooled after cooler), triethylene glycol (TEG), dehydration of gas, fiscal
metering, MEG regeneration and storage, control room, power generation, utilities, cold vent, etc.
The onshore segment of the pipeline will cross the non-built-up area of the Administrative Unit of Corbu
Commune located in Constanta County.
Two settlements are in proximity to the Project (Corbu Village and Vadu Village). Vadu is the nearest
settlement, located approximately 1.9 km from the GTP.

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Figure 5 Settlements and structures located near the MGD Project
The onshore segment of the pipeline will cross: Natura 2000 areas of ROSCI 0065 Danube Delta;
ROSPA 0031 Danube Delta and Razim-Sinoe Complex; ROSPA 0076 Black Sea, as well as the
economic area of the Danube Delta Biosphere Reserve (in Romanian: “Rezervaţia Biosferei Delta
Dunării”).
Also, the ROSPA 0066 Tasaul and Cobu lakes area is located approximately 6.5 km from the GTP. A
16 m-wide corridor will be required for the construction of the underground onshore pipeline segment.
The construction corridor will cross seven local unpaved access roads (De541/31/A,De541/31/B, De
539/80, De 539/79, De 539/78, De 522/9 and De 265). The project will follow the international standards
and national legal requirements for all crossings to ensure Environmental and Social impacts are mitigated.
After the onshore pipeline segment’s construction, the access roads crossings will be restored to the initial
conditions.
The onshore segment of the pipeline will under-cross the crude oil pipeline and a natural gas pipeline
owned by OMV Petrom SA located onshore. Also, the onshore pipeline will cross two Rompetrol
wastewater pipelines and the Balta Mare and Balta de Mijloc wetlands.
A number of onshore natural protected areas are within the project area as indicated in Table 2 below.
Table 2 Protected sites in the vicinity of the MGD Project, onshore section
Site name Site code Location relative to MGD Project

ROSCI0065 Onshore, pipeline crosses southern tip of site
Danube Delta SCI
(Delta Dunarii)
ROSPA0031 Onshore, the pipeline crosses the southernmost tip
Danube Delta and Razim-Sinoie of site; however, the GTP is located outside of this
Complex SPA site
(Delta Dunarii Complexui Razim
Sinoie)
ROSPA0060 Onshore; approximately 6 km to the south west of
Lakes Tasaul – Corbu onshore component of MGD Project
Lacurile Tasaul – Corbu
ROSPA0019 Onshore; approximately 15 km to the west of
Dobrogea Gorges onshore component of MGD Project
Cheile Dobrogei
Danube Delta IBA RO081 Extends from coastline into nearshore; pipeline
crosses through over a distance of ~12 km
Lake Tasaul IBA RO109 Onshore; approximately 6 km to the south west of
onshore components of MGD Project
Dobrogei Gorge IBA RO108 Onshore; approximately 15 km to the west of

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onshore components of MGD Project
Danube Delta Ramsar Site RO521 Onshore, the pipeline crosses the southernmost tip
of site; however, the GTP is located outside of this
site
The project obtained all permits required for construction.
1.3 Current project status and construction works foreseen for 2021
1.3.1 Current project status
As of March 2021, the following main activities were performed by BSOG and its contractors:
• construction of gas treatment plant (ongoing)
• fabrication of the jacket for Ana Platform completed and loaded for sailing out to the Ana location,
fabrication of the topside in progress.
• preparation of access road for HDD (completed)
• preparation of the HDD site (completed)
• beach crossing works with HDD (completed)
• HDD site demobilization (completed)
• preparation of access road to onshore pipeline corridor (completed)
• laying out and welding of onshore pipeline (ongoing).
• laying out the offshore pipeline (completed).
• Testing of the offshore pipeline (completed).
A photo report of the works carried out in 2020 can be found in Appendix I.
The impacts of the above-indicated activities have been fully assessed in the Project ESIA package.
The beach crossing works were performed by employing the Horizontal Directional Drilling (HDD) technology
and consisted of a series of activities that can be summarized as follows:
• preparatory activities related to access road rehabilitation, construction site arrangement and
installation of necessary equipment and machinery
• horizontal drilling
• pipeline pulling into the drilled borehole
• rehabilitation of construction site and access road.
The construction site had a total perimeter of approximately 40 m x 30 m and was located nearby Vadu
Beach at 150 m inland from the shoreline, as indicated in the below figure:
Figure 6 HDD construction site layout (source: Google Earth and MGD-E-GSPOS009-CN-DLP3-
001-B2 Jobsite Layout)

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1.3.2 Construction works foreseen for 2021
The following construction works are foreseen for 2021:
ONSHORE
• Onshore pipeline laying and testing
• Crossing of Balta Mare
• Completion of the construction works of the Gas treatment Plant in Vadu
OFFSHORE
• Transport and installation of the Jacket
• Transport and installation of Ana Platform
• Offshore pipeline laying and testing – completed
• Drilling of 5 development wells
• Start of the gas extraction process
2 REGULATIONS AND REQUIREMENTS

2.1 National Requirements
At national level, there are no specific requirements for preparing a dedicated Stakeholder Engagement
Plan. Nevertheless, some provisions for stakeholder engagement are included in several regulations
and procedures, including:
• The Romanian Constitution, which stipulates in article 31 (1) that “a person's right of access to any
information of public interest cannot be restricted” and in article 31 (2) that “the public authorities,
according to their competence, shall be bound to provide for correct information of the citizens in
public affairs and matters of personal interest”;
• Law no. 86/2000, for ratification of the Convention on Access to Information, Public Participation in
Decision-Making and Access to Justice in Environmental Matters, signed in Aarhus on 25 June 1998
(Aarhus Convention).
• Law no. 544 of October 12th, 2011 regarding the free access to information of public interest, which
defines and details the free access of any person to any piece of information of public interest,
which, as a general principle, constitutes one of the fundamental principles of the relationship
between citizens and public authorities in accordance with the Constitution of Romania and with the
international undertakings ratified by the Parliament of Romania.
• Law no. 544/2011 stipulates further that the public authorities or institutions will ensure that access
to information of public interest shall be done ex officio or upon request, through the intermediary of

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the department for public relations or through the intermediary of the person appointed for this
purpose.
• Government Decision no. 878/2005 on right to access to environmental information transposes EU

Directive 2003/4/CE from 28 January 2003 (on right to access to environmental information and
repealing the Directive no. 90/313/CEE) and ensures the right to access environmental information
held by or for the public authorities and sets out the conditions, general terms and ways to exercise
that right.
• Emergency Government Ordinance no. 195/2005, related to the environmental protection, as

amended from time to time, clearly stipulates in article 5 that the state recognizes the right of any
person to an “ecologically healthy and balanced environment” and for this purpose, the state
warrants, inter alia, free access to environment related information, including the right of any person
to be consulted during a process of making environment-related decisions (i.e. legislation, plans and
programs) and the right to access to justice.
• Further, article 20 of Emergency Government Ordinance no. 195/2005 clearly stipulates that the
Competent Authority for Environmental Protection together with all other local and central public
authorities, if the case, will ensure proper access to information, participation of the public in specific
activities related to decisions and access to justice in accordance with the requirements of the
Aarhus Convention;
• Government Decision no. 445/2009 on environmental impact assessment pertaining to certain

public and private projects. In accordance with the stipulations of this Decision, the relevant
information has to be made publicly available by the investor and/or the national authorities during
each of the EIA stages listed in article 6 of the same. Public Consultations and open disclosure of
documentation connected with the Project have to be carried out and financed by the Investor in
close connection with the guidance given by the relevant authority and consistently with the
requirements of the relevant Romanian legislation (see in this respect, art. 16 of the Decision). We
note that the provisions of this Government Decision were followed in relation to the MGD Project
when the regulatory process was performed. Starting with 09 January 2019 the provisions of this
Decision were replaced by the ones of Law no. 292/2018 on the environmental impact assessment
pertaining to certain public and private projects.
• Order 1284/2010, the Methodology for Environmental Impact Assessment for Public and Private
Projects, which details the necessary stages for the performance of the EIA procedure, as listed in
article 6 of Government Decision no. 445/2009. We note that the provisions of this Order were
followed in relation to the MGD Project when the regulatory process was performed. Like in case of
Government Decision no. 445/2009, starting with 09 January 2019 the provisions of this Order were
replaced by the ones of Law no. 292/2018 on the environmental impact assessment pertaining to
certain public and private projects.
• Law no. 292/2018 on the environmental impact assessment pertaining to certain public and private
projects. This law transposed the new EIA Directive and replaced Government Decision no.
445/2009 and Order no. 1284/2010.
• Order no. 2701/2010, the Methodology regarding the mechanism of information and consultation of
the public on the occasion of preparing or revising the zonal planning and urbanism plans enacted
by the Ministry for Regional Development and Tourism, which provides the legal framework for
performing the information disclosure and public consultation as a prerequisite for approving any
urbanism and zonal planning documents.
• Law no. 52/2003 on decisional transparency in public administration. This law has the role to
enhance the accountability of government to the citizen and the beneficiary of the administrative
decision, and to increase the involvement of citizens in decision-making processes of the
administrative and legislative drafting process, to enhance transparency across government.
• Order no. 863/2002 on approval of the Methodological guidelines applicable to the stages of the
environmental impact assessment procedure. Like in case of Government Decision no. 445/2009,

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starting with 09 January 2019 the provisions of this Order were replaced by the ones of Law no.
292/2018 on the environmental impact assessment pertaining to certain public and private projects.
• Law no.185/2016 regarding certain measures required for the implementation of petroleum
operations by the titleholders of petroleum agreements relating to offshore petroleum blocks. T he
law clearly sets out the way in which landowners are to be engaged during the development and
implementation of an offshore oil and gas project.
2.2 European Bank for Reconstruction and Development (EBRD)

Requirements
According to the EBRD, stakeholder engagement is important for building strong, constructive and
response relationships with all interested and impacted persons/institutions. EBRD’s Performance
Requirement 10 (PR10) states that national laws and regulations regarding public information disclosure
and consultation must always be considered when developing and implementing a project. Also, EBRD’s
Performance Requirement 8 (PR8) states that consultation with stakeholders and affected communities
should be made in the context of cultural heritage issues.
In the event that national laws are insufficient or there are significant discrepancies between national and
PR 10 provisions, then the following principles should be considered:
• Promoting transparent communication between the project promoter, its workforce, the local
communities directly affected by the project, and other interested stakeholders;
• The involvement of the stakeholders has to be a process free of manipulation, interference,
coercion and intimidation;
• The involvement of the stakeholders has to be adapted on the basis of the project impacts over
them (direct/indirect) and their level of influence and interest towards the project. Vulnerable groups
will be identified and specific actions will be undertaken to ensure that the Project will not contribute
to the existing vulnerabilities and possible barriers to their participation in the engagement process
are eliminated;
• The involvement of stakeholders is a process which must take place in the early stages of the
project, and continue throughout the entire life of the project; and
• Ensuring access to an appropriate, fair complaints management mechanism for stakeholders to
submit their questions, concerns or grievances about the project.
• In line with EBRD’s Performance Requirement 1 (PR1), together with PR10, engagement with the
project stakeholders is an integral part of the project environmental and social impacts assessment,
management and monitoring processes. PR1 requires the identification of the project’s stakeholders
and the design of a plan for engaging with the stakeholders in a meaningful manner to take their
views and concerns into consideration in planning, implementing and operating the project. PR10
states that the process of stakeholder engagement should begin at the earliest stage of project
planning and continue throughout the life of the project.
3 STAKEHOLDER IDENTIFICATION AND MAPPING

Mapping (classifying) stakeholders is an on-going process throughout the life of the project, with some
parties being identified in the initial phase of the implementation, while others are added as they gain
influence or interest in the project. Stakeholders are individuals or organizations that:
• Are directly or indirectly affected by a project (or company’s operations);
• Have “interests” in a project or a company or its area of influence that determine them as
stakeholders; and/or
• Have the potential to influence project outcomes or company operations.
In the current project context, several key stakeholders have already been identified, while others will be
included in future project stages.
The stakeholder’s identification process started at early Project preparation stages and was performed by

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BSOG employees during direct meetings with authorities, key stakeholders and representatives of local
community (Corbu and Vadu). The stakeholders have been identified:
• During the preparation of the social baseline;
• Via direct meetings with the BSOG team;
• Based on the available documentation and research;
• Based on the observation notes made during the site visits; and
• Based on previous experience with similar oil and gas projects and on local knowledge.
As part of the Project environmental and social impact assessment process, BSOG has also performed a
vulnerability assessment as detailed in the Additional Environmental and Social Impact Assessment
(AESIA). This assessment was based on the analysis of the local context performed as part of the impact
assessment process and summarized in the ESIA Package (including the project ESIA and AESIA reports).
The assessment took into consideration the socio-economic profile of the community (looking at the
structure of population, their level of education, age, ethnicity, etc) in order to be able to understand if there
are vulnerable persons living in the impacted communities. Further on, the assessment looked at the project
activities that may potentially generate situations of vulnerability (i.e. land acquisition, traffic, dust, noise,
beach crossing, and offshore activities). According to the vulnerability assessment performed, there are no
persons or groups of persons in the communities that may be differentially or disproportionately affected by
the project construction and operation. Therefore, no project vulnerable groups1 were identified in relation
to the project. Nevertheless the children enrolled in schools in Corbu and Vadu villages are considered as
being vulnerable persons2 in relation with the project and specific measures to address associated risks
and impacts on them were defined and will be implemented during project execution in the frame of the
environmental and social management system.
The following list presents the key stakeholders who were actively engaged in all project ( preparation ,
permitting, construction) phases:
• National Authorities – Ministry of Environment (through the Environmental Protection Agency of
Constanta and Danube Delta Biosphere Reserve Administration), Ministry of Culture and National
Identity (through the Direction of Culture of Constanta County), Ministry of Waters and Forests
(through the Romanian Waters National Authority), National Committee of the Coastal Area,
Romanian Intelligence Service, Ministry of Defence (through the General High Staff), Ministry of
Interior, National Agency for Mineral Resources, Hydrographic Marine Directorate, Forests’ National
Authority, Office of Cadastre and Real Estate Publicity, National Energy Regulatory Authority.
• Regional/Local Public Authorities (LPAs) – Local Council and the Mayor’s Office of Corbu,
Environmental Protection Agency (EPA) of Constanta, Land Improvement Agency, Direction for
Agriculture of Constanta, Direction of Public Health of Constanta, Prefecture of Constanta,
Environmental Guard of Constanta, County Council of Constanta, State Inspectorate for Emergency
Situations – Dobrogea.
• Other central authorities involved in the upcoming permitting process will also be considered as
stakeholders and added in the updated version of the SEP.
Beside the above, there are other categories of stakeholders who will be directly or indirectly
engaged either at this stage or in future stages. These include the following key stakeholder groups
for the overall project:
• Fishermen and Fishery organisations representing those who perform fishing activities in the project
area.
• Landowners/users in the proximity of the project.
• Persons living in houses located along the roads that will be used for transporting materials and
equipment
• Tourists that are using Vadu beach
1 In line with the EBRD requirements we have defined project vulnerable groups and persons as “people who, by virtue of gender
identity, sexual orientation, religion, ethnicity, indigenous status, age, disability, economic disadvantage or social status may be
more adversely affected by project impacts than others and who may be limited in their ability to claim or take advantage of project
benefits”.
2Vulnerable persons are defined as “people living below the poverty line, the landless, the elderly, women and children-headed
households, refugees, internally displaced people, ethnic minorities, natural resource dependent communities or other displaced
persons who may not be protected through national legislation and/or international law”

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• Owners of the restaurants located on or near Vadu beach, in the proximity of the future construction
corridor.
• Women, children, elderly people and any other vulnerable people who live in the project affected
villages including those villages affected by the project traffic, Transgaz pipeline project and by
construction and operation of associated facilities and construction camp.
• Other businesses in the region – especially other oil and gas companies that are present in the same
general area as BSOG (either offshore or onshore)
• Non-governmental organizations (NGOs) – active both at international/national and/or regional/local
level that are working in the fields of environmental protection, gender equality and social protection,
forestry, nature conservation and agriculture.
• Media – represented by both national and local television, radio stations, newspapers and social
media and other online publications.
• Community Leaders and Opinion Makers – high profile local leaders (mayor, priest, etc.)
• Public at large – all interested persons that have an interest in the project.
There are also two categories of stakeholders that are considered to be internal to BSOG which shall be
taken into account. The first category is represented by BSOG employees and contractors and worker
organisations, while the second one is represented by BSOG shareholders/investors.
By plotting influence together with impact/interest on a matrix diagram and taking due account of
further criteria such as expertise (i.e. knowledge to contribute and legitimacy) and the stakeholders’
willingness to engage, the relative needs of key stakeholders in terms of the level and type of consultation
and engagement are determined and can therefore be properly planned by BSOG throughout the project
lifecycle.

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4 STAKEHOLDER ANALYSIS
Stakeholder analysis is achieved by assessing the position of each stakeholder in the context of the
project preparation phase.
Each identified stakeholder has been analysed from following perspectives: the project impacts on them
(direct / indirect impacts), their estimated interest in the project and their potential influence over the project.
Table 3 presents the main outcomes of this analysis.
Table 3 Results of Stakeholder Analysis
External Stakeholder Potential Interest on the project

Directly impacted stakeholders
Affected communities (Corbu and Vadu Interested in understanding the benefits and project impacts, as
villages) well as measures to reduce the negative ones.
Local key opinion leaders (Mayor, Vice Interested in obtaining timely and effective information on project
Mayor, members of the County Council, implementation and maximize the BSOG engagement at
priest, school director and teachers) community level, via their CSR programme
Fishermen organisations Interested in understanding the restrictions for fishing, if
the case and how to overcome such restrictions.
Tourists Interested in using the beach and having no disturbance during
their holiday.
(It should be noted that within the area of the Delta Danube
Biosphere Reserve, informal touristic activities are taking place.
BSOG is considering all touristic activities within the project area
and tourists are considered key stakeholders, especially for the
beach crossing section of the project)
Local businesses (especially those Interested in understanding the impacts of the project on
focused on tourism) and other businesses in their business activities.
the area
Land owners/users – Interested in having no disturbances on their property during
neighbouring BSOG land construction and operational periods.
Vulnerable groups: children, elderly people, Reduce ay risks for accidents during transportation
disabled and any other vulnerable people
who live in the project affected settlements
including those affected from traffic and
associated facilities
New neighbours to the GTP (farm, guest house Interested in understanding the impacts of the project on
currently being built) their business activities.
Indirectly impacted stakeholders
National Authorities Project to be developed and implemented according to

national and international standards.
Regional/ Local Public Authorities Project to be developed and implemented according to
national standards.
Local authorities are interested in obtaining benefits for the local
community.
Non-Governmental Interested in monitoring and oversight of how the project
Organisations will comply with the environmental and social provisions and
commitments.

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External Stakeholder Potential Interest on the project
Mass media Interested in understanding the project and
monitoring how all provisions are complied with, especially
the ones related to environment and social safeguards.
Public at large Interested in understanding the benefits and disadvantages

of the project.
Employees of BSOG Being informed about the project

Receive timely payments
Contractor employees Good working conditions
Employee Organisations (trade unions) Protection of workers

Good working conditions
MGD gas buyer (Engie) Interested in buying gas from the project installation.
Main contractor (GSP)/ Sub-contractors Interested in fulfilling contractual obligations and respecting
deadlines.
IFIs Interested in implementing the project according to the time
schedule and recovering loans - in case of creditors, and in
maximizing investments - in case of investors.
Transgaz Owner of the associated facility and operator of national gas
transmission system.
Note: If you are not on the list and would like to be kept informed about the project, please liaise with
BSOG by using the contact details provided in section 7 of this document.
5 PREVIOUS ENGAGEMENT ACTIVITIES

Previous engagement activities have been related mainly to (1) the permitting process that started in 2014
and successfully finalized in 2019 for the construction phase of the project, (2) the land acquisition process
that was finalised in 2016, (3) the ESIA development process, (4) during construction works, and (5)
implementation of Corporate Social Responsibility (CSR) programme.
BSOG Community relations team was initially appointed on 13 March 2017 and communicated to Corbu
Municipality through formal letter. The team initially comprised of: the Communications & CSR Manager,
HSE Manager, Regulatory Manager. The BSOG HR Manager also joined the team in December 2018 and
this update was communicated to Corbu Municipality during a meeting with the Corbu Local Council
members on 18th December 2018. In 2019 a Community Liaison Officer has also joined the Community
relations team.
BSOG has developed the first SEP in 2016. Since then, all its engagement activities are documented and
properly recorded. This chapter presents the engagement activities performed by BSOG in 2020. Detailed
description of actions performed in 2019 is provided in Appendix C.
Annual reports on stakeholder engagement activities performed are also disclosed on BSOG website:
https://www.blackseaog.com/sustainability/environmental-policy/.
As specific cultural feature of the project-area countryside, rural communities are led and influenced by key
opinion leaders enjoying special respect from the community members. Such opinion leaders include the
Mayor, Vice Mayor, members of the Local Council, the priest, school directors and teachers. During the
engagement performed to date, the preference of the local community members was to express their
enquiries with respect to the MGD Project through the key opinion leaders who typically acted as
ambassadors between the community and the project.

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BSOG’s community engagement strategy acknowledged the above-indicated and held several meetings
with such key stakeholders to present the MGD project, progress status, principles of running the business,
implications for the community and understand the community needs. Minutes of these meetings are
available upon request.
Engagement activities for 2020 have mainly consisted of the engagement of project affected persons
(PAPs) that could potentially be affected by the start of the HDD beach crossing, such as tourists and
business owners in the beach area, the implementation of the Corporate Social Responsibility (CSR)
program, and the launch event that was organized on the 17 th of September, to mark the start of the work
on the pipeline.
All engagement activities performed in 2020 have been organized while taking into consideration the
restrictions imposed by the COVID-19 pandemic. As expected, the pandemic has limited the number and
scope of the engagement activities (public events being banned), yet BSOG has undertaken considerable
efforts to engage the stakeholders in a meaningful way while also taking into consideration their wellbeing
and potential risks.
5.1. Engagement with project affected persons (PAPs)
The start of the HDD work within the tourist season has provided a number of challenges in terms of
stakeholder engagement, since it is the most socially active period of the year in Vadu, which is an attractive
tourist destination for those seeking a more “wild” beach. More so, due to the international travel restrictions
imposed by the COVID-19 pandemic, the Romanian seaside has seen in 2020 an increase in the number of
tourists, even though the season has started with a slight delay, the tourist activities having been allowed
only at the start of June, while the summer tourist season would otherwise usually start in the 1st of May.
A Livelihood Restoration Framework (LRF) has been prepared in 2019 in order to detail all the possible
project impacts on the community and identify the affected persons, and a Livelihood Restoration Report
(LRR) has been prepared in the beginning of 2021 in order to evaluate the Projects’ compliance with the
LRF and any potential remedial actions.
Table 4 below details all the PAPs that were identified in the process and the engagement activities that
have been undertaken by BSOG.
Midia Gas Development Project – Stakeholder Engagement Plan - 2020

Page 19 of 64
Table 4. Engagement with Project Affected Persons
Stakeholder Engagement method Main results Responsibility

Tourists Flyer and brochure distribution The surveys indicate that tourists were not disturbed by the presence of BSOG
the site, nor they perceived any annoying noise from the site, machinery, Communications & CSR
5 Beach surveys or workers. Manager
2 Information boards installed at the HDD No interaction between tourists and workers have been recorded. CLO
site perimeter
Daily (Monday to Friday) reporting on

beach occupancy next to HDD site
Weekly opinion survey among tourists

Grievance Mechanism in place. No grievances have been received from the tourists. BSOG
Communications & CSR
7 Grievance boxes installed as follows: Manager
1. Corbu Mayor House
2. Agigea shipyard CLO
3. GTP
4. Corbu Cultural Center
5. Vadu Cultural Center
6. Vadu beach, near HDD site
7. Vadu Beach, HDD site
Owner of the The owner of the Bosoanca restaurant has No grievances have been received from the restaurant owner. BSOG
restaurant on been engaged by BSOG on several Communications & CSR
Vadu beach occasions. While BSOG has attempted on a number of occasions to engage with the Manager
owner, he has remained hostile towards the Company and couldn’t reach
An attempt has been made to contract the any agreement.
restaurant to provide food for the workers,
but an agreement on the price could not
be reached.
BSOG has used the services of the
restaurant occasionally and monitored the
restaurant occupancy during the HDD
work.
The owner of the restaurant has been

engaged several times. BSOG has
provided information materials and
updates regarding the project status.
The owner of the restaurant has been

Page 20 of 64
Stakeholder Engagement method Main results Responsibility
interviewed for the LRR purposes to
identify and potential impact on the
restaurant’s activity.
Owners of the Owners of the tourist accommodations in The owners have confirmed that there are not expected Project impacts BSOG
tourist Vadu and Corbu have been engaged as on their businesses and that despite the COVID restrictions, they were at Communications & CSR
accommodation part of the LRF elaboration process. the time almost fully booked for the upcoming tourist season. Manager
facilities from
Vadu village Face to face interviews have been No grievances have been filed by accommodation owners. CLO
performed in May 2020.
The CLO has provided informative

materials to the owners of accommodation
units in the area
Fishermen and Local fishermen organizations have been The organizations have confirmed that there are no impacts on the local BSOG
fishermen engaged by telephone prior to the field fishermen due to the construction work and that most commercial fishing Communications & CSR
organization visit in May 2020. is taking place in the lake, not in the section of the Black Sea near the Manager
Vadu shore.
CLO
No grievances have been filled by fishermen or fishermen organization.

Page 21 of 64
5.2. Corporate Social Responsibility (CSR) programme
BSOG have designed and started implementation of its Corporate Social Responsibility (CSR) programme
based on the Company’s CSR policy (See Appendix D). The BSOG CSR programme aims at developing
positive community relations and create a social partnership with the representatives of the local community
impacted by the Project. 2020 pandemic required adapting the CSR activities. However, BSOG has
succeeded the implementation of several CSR activities in Corbu and Vadu.
The following community development actions have been performed in 2020:
• Advocating for improved measures to protect Vadu beach

• Support to Vadu school in implementing BSOG grant
• Improving access to online education for all pupils in Vadu kindergarten and school in the context
of COVID 19 Pandemic
• Preserving local traditions and history by supporting the creation of Corbu 1st monography
• Christmas gifts to Vadu school pupils
The above activities are described in the CSR activities Report for 2020, in Appendix E.
5.3 Other engagement activities

Besides the above, the following engagement activities have also been performed:
Engagement with key stakeholders
On 17th September 2020, a formal ceremony for the commencement of works for offshore pipeline laying
was organized by BSOG together with its main contractor, GSP. The ceremony was attended by several
high officials including the Prime Minister, US Ambassador, the Minister of Economy, Minister of
Environment and representatives of Transgaz, EBRD, National Agency for Mineral Resources, National
Agency for Energy Regulations, Corbu Municipality, ACROPO, EBRD, EPA Constanta, Romanian Naval
Authority, DDBRA, etc. The event was circulated in different national and international online and printed
newspapers and on the most popular news channels in Romania.
Media coverage and press releases
BSOG has also prepared press releases and media announcements, especially when a project milestone
is achieved and whenever a public was organised; Information on MGD Project progress have been
published in national newspapers such as: Ziarul Financiar, Bursa, G4media, Capital, Profit.ro, Romanian
Business Journal, Adevarul, Agerpres, etc.
BSOG is also making use of social media in order to be able to provide meaningful and timely information
to any interested party (approximately 1 update/month). For further information you can access the LinkedIn
profile, or YouTube channel.
Details regarding the social media coverage and press releases are included in Appendix F.
Internal communication and engagement activities
Internal communication is done by using several channels: emails, newsletters (once at every 2 months),
staff meetings (once at every 3 months or whenever necessary) and intranet platform. The objectives of
the staff meetings are to present the MGD project progress, the business development plans, staff logistics
going forward, team targets, COVID updates related to working conditions, etc. During the lockdown, these
meeting were organized once per month.
To reach out to internal stakeholders, BSOG has developed an intranet platform where employees of BSOG
and collaborators that receive access can visualize important documents and receive information on project
development. Also, the intranet platform has an online feedback mechanism. Please see Appendix G.
With respect to the CSR mechanism, the employees are informed of the actions perform by the Company
either directly via regular meetings, either via e-mail. Appendix H presents the internal announcements for
CSR actions performed in 2020.
6 STAKEHOLDER ENGAGEMENT PLAN

6.1 Action Plan
The following action plan has been designed for 2021 and is presented in Table 7. This plan corresponds
to the construction phase of the project, which is set to end by the end of the year.
The objective of these external communications is to provide continuous engagement with targeted
audiences to inform about the activities, performance, development and investment plans and their
implementation. The exact dates and venues of the proposed activities will be communicated with the
stakeholders prior to, during construction and operation phases. The tables be low include detailed
information on engagement actions to be performed by BSOG during the construction period and a set
of generic actions that will be performed during operation period. This plan will be updated at least once
per year or according to the project needs and the achieved results.
Table 5 Stakeholder Engagement Action Plan for 2021
STAKEHOLDER ENGAGEMENT PURPOSE OF INFORMATION LOCATION/ RESPONSIBILITY

METHOD ENGAGEMENT DISCLOSED/ ESTIMATED
COLLECTED TIMELINE
Local communities CSR Social licensing BSOG will Corbu and Vadu BSOG
of Corbu and Vadu programme of the project continue to – yearly Communications & CSR
implement the programme Manager
CSR programme
and will intensify CLO
their community
engagement
during this year.
The previous
experience with
working with a
local NGO
proved to be
mutually
beneficial.
Community To address the Provide Corbu and Vadu BSOG
Liaison Officer concerns and information about Communications & CSR
expectations of the project’s Ongoing Manager
the community impacts and
mitigation
To provide measures
information and
consult
interested
parties
Facilitate
community
meetings,
events etc.
Owners of the Direct meetings Address their Follow up to the Vadu village BSOG
restaurants located concerns and claims that have Communications & CSR
on or near the expectations (if surfaced in the Q2 2021 Manager
beach any) LRR about
potential impacts
due to the HDD
works
Landowners Direct meetings Address their Engage owners if Vadu village BSOG
adjacent to access concerns and impacts have Communications & CSR
roads expectations (if been identified Q2 2021 Manager
any)
CLO
Contractors Direct meetings Ensure that Provide required Construction BSOG:

project is information site – during Technical department
Reporting correctly and Regular updating construction
timely meetings with Project manager
implemented main contractor
Site visits for

observing the
progress and for
monitoring
purposes (based
on monitoring
plan and internal
audit
requirements)
Discuss the
monthly progress
reports
Transgaz Direct meetings Ensure that Regular BSOG Office, BSOG:
(when needed) project is meetings Transgaz Office, Technical department
correctly and (quarterly) – On site
Official timely project progress
corespondence implemented Ongoing –
Redirecting during project
Reporting received construction
grievances
IFIs Reporting Reporting Project Progress BSOG office BSOG: Financial
Reports IFI office manager - Daniela Gătin
Direct meetings Direct meetings –– reporting
(when needed) (when needed) Monitoring Ongoing
meetings CEO - Mark Beacom -
Direct meetings
Mass media Press releases Offering timely Provide Local/ Regional

and social information information newspapers that BSOG:
media coverage about: are accessible Communications & CSR
- the project to residents of Manager
development affected
- imposed communities/wh
restrictions en necessary
- official mass
media articles / Social media
answers to
official request Ongoing
for public
information
- development of
information
movie (bilingual)
on project
construction
steps –
onshore/offshore
– publish the
movie on
website/social
media (linkedin/
youtube)
During the operations period, BSOG will implement a Stakeholders Engagement Plan, based on the
feedback and strategy established for such phase. A detailed timeline for the engagement activities during
operation period will be developed 3 months prior to starting the operation.
Table 6 Stakeholder engagement action plan – generic actions during operation period
Stakeholder Engagement Purpose of Information Location and Responsibilities3

method engagement disclosed/collected period of
disclosure
All Website To provide Project operation BSOG website BSOG
access to reports / EBRD Communications & CSR
information in website Manager
a timely and
Press releases efficient BSOG office /
and social manner national and
media local
coverage newspapers
Meeting Lauching Technical description GTP Vadu BSOG
event for GTP of GTP and offshore Communications & CSR
operation infrastructure Manager
IFIs Reporting Ensure that Project Progress BSOG office BSOG: CFO
information is Reports IFI office
Direct provided on a Monitoring meetings
meetings timely and
(when efficient
needed) manner
Local communities CSR Social BSPG will continue Corbu and BSOG
of Corbu and Vadu programme licensing of to implement the Vadu – yearly Communications & CSR
the project CSR programme programme Manager
during operation
period.
3
Further information on the responsible person from BSOG is presented in the contact sheet attached to present document
Stakeholder Engagement Purpose of Information Location and Responsibilities3
method engagement disclosed/collected period of
disclosure
National / Local Direct meeting Inspections Information related to BSOG offices / BSOG: CFO
Authorities /Permitting operation both in
Bucharest and
Vadu GTP
Children and Study visit Information on Technical information GTP BSOG
students GTP operation on GTP operation Communications & CSR
/ research, and offshore Manager
educational operation
purposes
CSR activities foreseen in 2021
In 2021, BSOG will continue implementing CSR activities within the local community. The Company is
currently developing the CSR Strategy for year 2021. The main focus areas of the strategy will go in the
same directions as in the previous years: education, environment and community development.
6.2 Record keeping

The project related activities that will require stakeholder engagement processes may help to identify a
range of issues that are directly associated with the project or with more strategic issues. Each individual
issue raised needs to be considered and addressed by BSOG and, where appropriate, individual
responses compiled, and further meetings arranged. All environmental or social concerns raised by
stakeholders specific to the MGD Project should be taken forward for consideration in the decision-making
processes.
To help manage this, all responses received will be documented in a register and appropriate actions
identified and tracked. The register will be maintained and updated as appropriate throughout the project.
Minutes will also be produced from all consultation meetings and documented within the consultation
register.
7 GRIEVANCE MECHANISM
The current grievance mechanism is referring only to external stakeholders and workers contracted by
BSOG. The detailed grievance mechanism for external stakeholders is included BSOG internal procedure
BSOG-GV-PRO-001-D02. A dedicated grievance procedure for internal stakeholder is included in HR
Handbook available for BSOG staff.
Stakeholders have the right to be informed about the project development and implementation and they
also have the right to raise concerns and suggestions during the decision-making process. Effective and
timely response to grievances is essential for maintaining good community relations, and this includes
potential issues related to the project and its associated impacts.
Any request, objection, complaints or proposal filed by any stakeholder related with the project will be
classed as a grievance. The stakeholders have the possibility to file anonymous grievances, which will be
taken into account and resolved following the same basic steps as with non-anonymous grievances, with
the mention that in this case the stakeholder will not receive a formal answer to its complaint. The
anonymous grievances have to be recorded in the grievance register as any other regular grievance.
A stakeholder may raise a grievance related to any BSOG operation during the development and
commissioning of the MGD project. Also, a stakeholder may also raise a grievance related to projects
developed by other parties in proximity of the BSOG operational areas or other facilities that are considered
as associated with BSOG operational areas. All these grievances will be recorded within BSOG grievance
register and re-directed towards the other project developers. BSOG will provide written answer to the
known persons who filed in such grievances informing that their grievance was redirected towards another
project developer (offering also the contact details of the person/institution where the grievance was
redirected).
The objectives of the BSOG grievance mechanism are to ensure that all grievances are promptly and
effectively addressed, in a fair and transparent manner, throughout the Project lifetime. All complaints will
be investigated to establish their validity and to ensure that all accepted grievances are dealt with in a
correct and prompt manner; where relevant, corrective actions will be implemented to prevent any
recurrence of problems.
The grievance mechanism will be available at the level of BSOG and will include but not be limited to: a
template (record form) for logging complaints and suggestions; a direct phone line made available for
anybody interested in communicating about the project; an appropriate access via emails and direct
meetings with responsible project persons before, during and after construction works; and an online
complaint form.
The following elements are included in the external grievance mechanism for the current project:
• A simplified grievance template that was available in 6 locations(one at the mayor’s office, one at
Agigea Shipyard, one at the Gas Treatment Plant in Vadu, one at Corbu Cultural Center, one at
Vadu Cultural Centre and two at the HDD site). The grievance template is also made available in
Turkish language for the workers of the main contractor. BSOG collects the lodged grievances
once per week. Appendix A includes the Romanian language official template.
• A direct phone number and email address from BSOG community liaison officer was made
available to all interested parties for enabling them to contact BSOG’s representatives whenever
necessary (please also see Appendix B BSOG Contact List).
• Direct meetings with representatives of local communities where they could raise their complaints
and/or suggestions, verbal complains.
• An online complaint form that can be easily filled in by any interested party is posted on BSOG’s
website: https://www.blackseaog.com/make-a-complaint/
• Public statements: where statements made in the public domain (e.g. in the press, on television,
on social media etc.) are considered to be grievances these are recorded and documented by the
BSOG’s Communication & CSR Manager for further processing per this procedure.
A complaint is considered to be valid if it is submitted using one of the above-mentioned channels. All
valid complaints received during the project ESIA disclosure and implementation process will be processed
and registered by CO in a dedicated grievance log. BSOG should keep these grievance registries in
order to track all grievances and to be able to present these registries upon any request from EBRD
or other relevant entity. The period of time for registry keeping and the methods for archiving documents
should be established by internal procedures.
The central log includes the following information:
• Date lodged by complainant or date received by CO;
• Contact details of complainant;
• General information
• Actions to be undertaken;
• Due date;
• Decision;
• Feedback from the complainant;
• Results; and
• Closing date of the issue.
• Close out form signed off by the complainant will be obtained and registered into the system.
The BSOG Grievance Committee is responsible to review all aspects of each grievance and reach a decision
on the next step. Where the committee does not reach a decision the BSOG CEO shall be responsible to
determine the next steps which amongst others may involve additional experts/personnel being added to the
BSOG Grievance Committee for a further review or may involve the BSOG CEO determining the decision
to be implemented. BSOG will make all reasonable efforts to address the complaint upon acknowledgement
of the grievance, progress chasing with the responsible person/department if actions are overdue and
escalating any major problems to senior management. All grievances will be acknowledged within 7
days and responded to no later than 30 days. Once a grievance is logged, the related E&S event(s) that
caused the grievance will be tracked to ensure proper closed-out of the grievance and prevent similar
grievances.
If the complainant is not satisfied with the solutions proposed/implemented by the CO to address the
grievance, he/she may seek other legal remedies in accordance with the legal framework of Romania.
All stakeholders will be able to deliver complaints personally by post, e-mail, web site or facsimile.
Any complaint may be delivered to the company at:
Black Sea Oil & Gas main office
Bucharest
Calea Floreasca nr. 175, etaj 10
Sector 1, 014459
Bucharest, Romania
Phone: +40 21 231 32 56
Contact person: Ana-Maria Pericleanu/Daniela Stroe

Web site: http://www.blackseaog.com/en/home/. Email: grievance@blackseaog.com
Community Liaison Officer: Elena Cretu

Corbu Commune
Phone number: 0790 69 08 57
E-mail: elena.cretu@blackseaog.com.
Figure 7 Overview of Grievance Mechanism

In 2020, BSOG has received and registered 18 complaints/requests for information. These are mostly (14)
grievances referring to the delay of receiving the salaries for the work performed during the offshore
operations for the MGD Project. BSOG has addressed these grievances in witing with the contractor, has
conducted an audit with relevant parties to better understand the difficulties in paying the salaries to
employees on time and has performed weekly follow ups by phone with the Contractor on the topic of
salaries. In the end, all complainants confirmed the receipt of the salaries and the favourable resolution of
the grievances raised.
With respect to the works carried out on Vadu beach during summertime, it has to be mentioned that no
grievances have been received by BSOG from tourists and/or owner of the restaurant located in the
proximity of the construction site.
The grievances received in the last year are presented in the below table:
Table 7 Grievances received in 2020
Date Stakeholder Subject of complain Communication Steps and Resolution

channel
14.02.2020 Member from Information request - Grievance box - 1) Grievance review by the
Corbu Concern about the Letter Grievance Committee
Community impacts of the GTP on 2) Preparing and sending the
environment and life, in answer together with the
general package of documents
describing the impacts of the
project on the local community
and environment
07.08.2020 Member from Jobs request Grievance box - 1) Grievance review by the
25.08.2020 Corbu Letter Grievance Committee
Community 2) BSOG has discussed with the
complainant about the
employing procedure
3) BSOG has provided the
contact details of the
contractor to the complainant
02.09.2020 GTP neighbour Restore the private road Grievance box - 1) Grievance review by the has
impacted by the works Letter Grievance Committee
2) After internal review it have
been concluded that the road
was impacted by the works at
Transgaz pipeline
15.07.2020 GSP employees Delay in payment of Email – Phone - 1) Grievance review by the
05.08.2020 salaries Letter Grievance Committee
18.08.2020 2) BSOG has carried out
09.09.2020 discussions via
25.09.2020 email/telephone with the
03.11.2020 complainer and liaised with
05.11.2020 the contractor to solve this
17.11.2020 issue
19.11.2020 3) BSOG has performed weekly
24.11.2020 phone follow ups with the
26.11.2020 contractor on the topic of
03.12.2020 salaries
28.12.2020
31.12.2020
Figure 8 Grievance box for tourists, near the HDD site at Vadu beach
8 MONITORING AND EVALUATION
The objective of the monitoring and evaluation process is the continuous improvement of the environmental
and social performance of the company.
Subsequent to signing the financing contract, BSOG has to comply with the environmental and social
provisions included in the financing agreements, to monitor the project’s performance and to provide
periodic environmental and social reports to the EBRD. In 2020, BSOG has prepared two Reports for
EBRD. The last report was prepared for the period July – December 2020 BSOG will also have the
responsibility to facilitate any monitoring visit or audit requested by EBRD.
Monitoring activities will be commensurate with the environmental and social impacts and issues
associated with the project. They may also reflect any significant stakeholder concerns and include an
environmental and social project completion review or audit, where relevant.
In the monitoring and evaluation process for stakeholder engagement, all the consultations undertaken,
all the issues raised, and the actions taken will be recorded. Also, this process implies the description of
the lessons learned and any changes to the consultation process.
All queries in relation to the project will be filed in the comments registry, analysed and reported by
BSOG project implementation team to management team on a two-month basis during project
development and implementation.
The results and feedback from information disclosure and public consultation will be documented and
reported as appropriate. Summary reports – in both English and Romanian - will contain details about
suggestions or concerns raised by stakeholders and how their comments have been considered.
BSOG Grievance Committee will constantly monitor the engagement level of their stakeholders by
developing a set of indicators which will include at least the following items:
• Number of communications;
• Type of communications;
• Frequency of communications;
• Number of valid complaints (and number rejected as unclear, problematic or dubious);
• Type of complaints;
• Sources of complaints;
• Number of resolved complaints;
• Average time for resolution of complaints;
• Number of presentations on environmental, social and economic status of the company;
• Number of mass media articles and / or announcements;
• Number of stakeholders involved per action;
• Level / degree of involvement for each stakeholder;
• Number of visitors on the websites; and
• Number of requests for information via websites.
A clear record of all these indicators will be kept at BSOG Communications & CSR department. Where
possible the indicators shall be differentiated by gender and type of stakeholder, according to the categories
defined in the Stakeholder Analysis chapter. Gender based data collection will be considered for the green
marked indicators from the above list.
Another important aspect is the manner in which the public is informed about the SEP. BSOG
Communications & CSR Department will make publicly available the SEP on its website. Also, the SEP will
be part of the annual environment and safety report of BSOG.
9 REPORTING
9.1 Internal Reporting
A review of stakeholder engagement will be presented on a regular basic within the BSOG project team,
including:
• Annual CSR report;

• Monthly EHSQ project progress reports;
• Annual EHSQ report (including ISO 14000 provisions).
9.2 External Reporting

External reporting will include timely updates to relevant stakeholders regarding Project advancement.
The main responsibilities for reporting are attributed to the Communication and CSR Manager. The
following activities shall be undertaken as part of the external reporting process:
• Public disclosure of the SEP;

• Environmental reporting to national and local authorities including:
o Annual and quarterly reports on project development for the National Agency for
Mineral Resources;
o Annual report on number of offshore operation hours for ACROPO.
• Annual E&S report for IFIs;
• Mass media reports including:
o Public announcements regarding the beginning of the construction, the
implementation of certain activities, restrictions and the ceasing of certain
31
activities;
o Press releases;
o Social media updates
10 ROLES AND RESPONSIBILITIES

The main departments within BSOG responsible for implementing this Stakeholder Engagement Plan are
Communication & CSR and Regulatory & PGA. Moreover, starting with April the 1st, BSOG will have a
Community Liaison Officer within the local community. Some of these roles and responsibilities might change
over time to reflect the changing needs of the stakeholder engagement process.
Communication and CSR Manager responsibilities:
• Overall SEP implementation: monitoring and reporting;

• Website: Provide access to relevant information about the project;
• Public consultations: organize public consultations with the local community in order to provide
information and consult interested parties regarding the project;
• Focus group meetings: organize focus groups in order to understand the community needs and
identify the needs of vulnerable groups;
• Mass media coverage/ Press releases/ Information disclosure: offer relevant information to
the mass media and third parties;
• Grievance mechanism:
o Grievances received or identified, including filling out case details (General Information,
Reported Party and Incident or claim Description/consequences sections) in the Grievance
Analysis Report form (format included in Attachment 2) in readiness for the BSOG Grievance
Committee meeting;
o Maintain central log of all grievances ensuring it is kept up to date with current status;
o Act as member of the BSOG Grievance Committee;
o Prepare minutes of BSOG Grievance Committee Meetings, formally recording all decisions
made by completing the Analysis, Analysis Results and Decision sections in the Grievance
Analysis Report form for the case;
o Prepare responses to grievance raisers and agree content with other members of the BSOG
Grievance Committee;
o Issue all responses to grievance raisers and ensure BSOG Management Team are informed.
Regulatory and PGA manager responsibilities:
• Public debates: organize public debates related to the permitting processes and project
compliance;
• Meetings with local authorities and official correspondence: organize meetings and
correspondence in order to offer information about the project, request feedback, identify concerns
and obtain permits;
• Meetings with national authorities and official correspondence: organize meetings and
correspondence in order to offer information about the project, request feedback, identify concerns
and obtain permits;
Community Liaison Officer responsibilities:

• Grievance mechanism:
o represent community concerns and grievances to the company;
o report the concerns and grievances to the company fairly and consistently;
o deliver back the resolution to the issues raised;
• Community engagement:
o build relationships based on trust and mutual respect;
32
o secure and maintain broad and long-term community support for the company’s activities.
Further details on responsibilities and specific tasks associated with the above-indicated roles as well as the
lines of responsibility within the overall project organization are provided in the Environmental and Social
Management Plan (ESMP) and in the Job descriptions. The ESMP defines the overall environmental and
social management planning for the entire project.
33
APPENDIX A Grievance Form
Acest formular poate fi depus:

- direct în cutia de reclamații și sugestii a BSOG plasată în orice sediu al BSOG sau al
contractorului principal sau la sediul Primariei Comunei Corbu, Str. Principala nr. 38, județul
Constanța,
- prin poștă în atenția dnei Ana-Maria Pericleanu, Communications & CSR Manager, Tel.: +40
(0) 724 254 909, adresa Calea Floreasca, nr. 175, et. 10, Sector 1, Bucharest, sau E-Mail:
grievance@blackseaog.com
Cererea dvs. va fi înregistrată și vă vom răspunde în termen de maximum 30 de zile.
Black Sea Oil & Gas SRL – Politica de confidenţialitate a datelor cu caracter personal
Această Politică de confidenţialitate vă informează cum Black Sea Oil & Gas SRL şi afiliaţii sau partenerii săi
(„BSOG” sau „noi”) colectăm, distribuim şi folosim informațiile dvs. personale în legătură cu completarea unei sugestii
sau reclamaţii legate de activităţile BSOG.
Respectăm confidenţialitatea dvs. şi ne angajăm să colectăm, să menținem şi să utilizăm informaţii personale despre
dvs. în mod responsabil şi în conformitate cu această politică de confidenţialitate a datelor cu caracter personal.
34
Colectarea şi utilizarea informaţiilor personale
Colectăm informaţii personale care vă identifică:

• Nume complet
• Email
• Număr de telefon
• Adresa de corespondenţă
BSOG are un interes legitim pentru a utiliza informaţiile personale pe care le colectează pentru:
(i) a ţine o evidenţă; şi
(ii) asigura comunicarea cu persoana care a depus sugestia/plângerea pentru a primi soluţonarea acesteia.
Perioada de retenţie
BSOG va păstra informaţiile dvs. personale atâta timp cât este necesar în scopurile prezentate în această politică de
confidenţialitate, precum şi pentru a respecta obligaţiile noastre legale;
La sfârşitul perioadei de păstrare, BSOG va şterge informaţiile dvs. personale într-un mod în care acestea nu pot fi
reconstruite sau citite.
Angajamentul nostru pentru securitate
Folosim tehnici de stocare şi securitate a datelor actualizate pentru a vă proteja informaţiile personale împotriva
accesului neautorizat, a utilizării sau dezvăluirii necorespunzătoare, a modificărilor neautorizate sau a distrugerii
ilegale ori a pierderii accidentale. Toţi angajaţii noştri sunt obligaţi să respecte confidenţialitatea informaţiilor dvs.
Drepturile dumneavoastră
În legătură cu informaţiile personale pe care le prelucrăm, aveți următoarele drepturi:

• dreptul de a fi informat cu privire la modul în care informațiile dvs. personale sunt procesate de BSOG;
• dreptul de acces la informațiile dvs. personale;
• dreptul de a rectifica informațiile dvs. personale dacă sunt inexacte sau incomplete;
• dreptul de a șterge (elimina sau șterge) informațiile dvs. personale atunci când acestea nu mai sunt necesare
în raport cu scopul pentru care au fost prelucrate inițial;
• dreptul de a restricționa procesarea dacă considerați că interesul legitim al BSOG a depășit drepturile dvs.
sau informațiile dvs. personale sunt ilegal procesate;
• dreptul la portabilitatea datelor care vă permite să mutați, să copiați sau să transferați date cu caracter
personal din BSOG către orice altă persoană indicată de dvs.
Informaţii de contact
Dacă doriţi:
• să accesaţi informații personale referitoare la dvs;
• să solicitaţi corectarea sau ștergerea informațiilor dvs. personale;
• să vă opuneți prelucrării sau să solicitați o restricție privind utilizarea informațiilor dvs. personale;
• pentru a ridica orice altă preocupare cu privire la utilizarea informațiilor dvs. personale;
• atunci vă rugăm să ne contactați folosind formularul nostru de contact și vom lua măsuri rezonabile pentru a
rezolva aceste probleme cât mai curând posibil.
Controlor de date
Controlorul de date este: Black Sea Oil & Gas SRL
Dacă aveți întrebări în legătură cu această politică, vă rugăm să ne contactați la adresa:
Calea Floreasca, nr 175, etaj 10, Sector 1, Bucureşti, România;
Telefon: +40 21 231 3256
Fax: +40 21 231 3312
Email: dpo@blackseaog.com
35
APPENDIX B BSOG CONTACT LIST
Overall SEP implementation Ana-Maria Pericleanu

Communications & CSR Manager
Grievance Mechanism
Mass media coverage Black Sea Oil & Gas SA
Public Consultations 175 Calea Floreasca St. 10th floor District 1, Bucharest
T: +40 212 313 256 | F: +40 212 313 312 | M: +40 724 254 909
Ana-Maria.Pericleanu@blackseaog.com
www.blackseaog.com
Elena Cretu
Community Liaison Officer
Corbu village
Phone number: 0790 69 08 57
E-mail: elena.cretu@blackseaog.com.
Daniela Stroe - Grievance Mechanism

HR Manager

175 Calea Floreasca St. 10th floor District 1, Bucharest, 014459, RO
T: +40 212 313 256 | F: +40 212 313 312 | M: +40 731 199 444
Daniela.Stroe@blackseaog.com
IFIs Mark Beacom
CEO
Contractors
175 Calea Floreasca St. 10th floor District 1, Bucharest
T: +40 212 313 256 | F: +40 212 313 312 | M: +40 729 199 316
Mark.Beacom@blackseaog.com
www.blackseaog.com
Daniela Gătin
Financial manager –– Reporting
Regulatory / Permitting aspects Oana Ijdelea

Public debates Email: Oana.Ijdelea@blackseaog.com
36
APPENDIX C Engagement actions performed between 2017 – 2019 – extract from Stakeholder Engagement
Reports
The below table highlights the main aspects of our company has focused in 2017, 2018 and 2019 in terms of engagement with specific stakeholders and public
at large:
Stakeholder Engagement Actions performed in 2017 Actions performed in 2018 Actions performed in 2019
method
All Website The BSOG website is available to all Via its website, the company constantly The website and social media pages of
stakeholders, both in Romanian language and provides information to all interested BSOG have continued to provide the same
English. stakeholders about the project’s functionalities as in 2018.
development and makes public
The website provides general and specific announcements about key
information about the project development such stakeholders’ decisions, public
as: information on SEA / EIA processes, public consultation processes, and decisions
announcements, invitations to public debates, related to permitting process; To reach
decisions of environmental authorities, out to internal stakeholders, BSOG has
environmental reports for project components, developed an intranet platform where
etc. employees of BSOG and collaborators
that receive access can visualize
Beside its website, BSOG is also using social
important documents and receive
media (LinkedIn) for disseminating information
information on project development.
about its activity.
Also, the intranet platform has an online
Based on the official statistics, the total number feedback mechanism.
of visitors on the BSOG website was at about
18,456 users. Out of these, about 32% have The website contains a link for
been from Romania. Most of the users are submitting grievances that can be easily
accessing the news section of the website. filled in by any interested party is:
https://www.blackseaog.com/make-a-
The website does not include a grievance complaint/
template (currently under preparation) but the
company receives about 5 emails per month
that are requesting information or provides
suggestions for the company.
Beside the official webpage that is available for
public at large, BSOG has also developed an
internal page that can be accessed only by the
shareholders and employees of BSOG. On this
37
method
dedicated webpage there are information

available about all the activities of BSOG.
Visual materials - BSOG edited two videos about specific

for educational project activities in the offshore industry
purposes to educate the public on offshore
industry dynamics, get understanding
and support for its activities and
endeavours. One video presents an
offshore exploration drilling campaign
from BSOG drilling campaign in 2018,
the other is a 3D animation of the MGD
Project.
Public Information about the public consultations have On June 12th, 2019 a public
In 2018, 4 public consultations were consultation has been organized in
consultations been provided via BSOG website throughout organized in during the permitting
the entire year and through posting of Vadu had to inform the community
processes: members on the MGD Project impacts
announcements on the information board of the
local authority and on site, as the case may be, and works calendar in the area, once the
- 1 consultation on the environmental construction works will start.
based on the steps of the permitting process. impact assessment process and report
The website includes announcements about the for MGD-onshore component
public debates and the decisions issued by the BSOG sent out by email on June 14th,
(14.01.2019) 2019, all ESIA documents issued in
national /local environmental protection
agencies. - 1 consultation on the preparation of relation to the MGD project to a list of
the urban planning document for the NGOs active in the environmental
During 2017, BSOG together with the beach segment of the onshore pipeline protection sector, as advised by its
representatives of national and local authorities (20.04.2018) public relations consultants and asked
have organised/participated at the following to review the documentation and send
public debates: - 1. consultation on the environmental
comments or ask for additional
impact assessment process and report
information.
- 1 public debate for consulting on the for Madalina-1 exploration well
preparation of the urban planning document for
- 1. consultation on the environmental As part of the engagement with local
the GTP
impact assessment process and report NGOs from Corbu and Vadu, a request
- 1 public debate for consulting on the strategic for MGD-offshore component has been made from Bankwatchin July
environmental assessment process for the GTP (17.12.2018) 2019, for them to be involved in the
consultation process and have
- 1 public debate for consulting on the One written enquiry was received from formulated 10 questions regarding the
environmental impact assessment process for an NGO in Constanta on 30 th January MGD Project. At the time of this report,
the GTP 2018 in relation to the Environmental the engagement with Bankwatch has
Impact Assessment Report for the remained a virtual one, communication
GTP. The NGO (Dominocost)
38
method
- 1 meeting for the obtaining of the consent of challenged a statement in the EIA being performed through email, as
the National Committee of the Coastal Area for regarding the overall positive climate detailed in the Grievance section of the
the urban planning document for the GTP change project impact (as result of document
displacement of more greenhouse gas
No questions or remarks regarding the emission-intensive fuels) suggesting it As part of the CSR programme, 2
documentation were received by BSOG during is irrelevant as the assessment is to be sessions of community consultations
the period of time allocated for questions or focused on the air emission impacts on have been organized in Corbu with the
comments. nearby project areas including Vadu aim to validate with local key
Village. Furthermore, the NGO raised stakeholders the CSR directions and
the fact that an urban zoning plan engage community in solving local
indicating the intention for a potential needs. Organized on 12th July and
future construction of a touristic facility 28th August 2019, the meetings
on land parcels within less than 150 m gathered 16 members from the local
from the GTP has been approved. The community -representatives of the City
NGO questioned whether the project Hall, teachers, priests, owners of local
and the potential future development business, NGOs representatives,
may be in conflict e.g. as result of regular citizens. The community
establishing a sanitary protection zone meetings conclusions were used to
around the GTP that would prevent the better draft the next stages of the CSR
future touristic development. Although strategy and better tailor future
the enquiry was raised after the formal programs to the needs of the
disclosure and public consultation community.
period of 30 days elapsed, in February
2018 BSOG replied in written form
providing adequate response to the
issues raised by the NGO. The answer
provided guidance to the relevant
sections in the EIA addressing the
issues raised and demonstrating that
all project impacts, including the air
emissions were assessed, are within
acceptable levels and aligned with the
regulatory requirements. Also, the
answer indicated that the applicable
safety zone would not exceed 30 m
from the project equipment and, given
the location of the project facilities
within the GTP site, this safety
distance does not extend beyond the
fenced site boundaries. Hence the
39
method
potential future development of the

indicated touristic facility or of other
developments is not prevented in any
manner.
Local/ Regional/ Meetings Several meetings have been held with different BSOG has organized and participated During 2019, BSOG representatives have
National local/regional authorities in Constanta and various meetings with representatives of participated in meetings organised by
Authorities Official Tulcea Counties. Among these, the most the authorities in order to explain and state authorities regarding different
correspondence important stakeholders engaged during 2017 present the project. As an example, the specific technical aspects. As example,
were: BSOG representatives have ACROPO organised consultation
participated at a meeting organized in meetings with offshore operators,
- Local authority of Corbu commune Corbu with the members of Local regarding issuance of a Stand-By Vessel
Council where they have discussed and Guideline. Another meeting organised by
- Environmental Protection Agency of Constanta
presented the project progress. ACROPO had the purpose of presenting
-Danube Delta Biosphere Reserve their results of reviewing the initial
Administration. BSOG has fully participated in the Reports on Major Hazards prepared by
various permitting procedures for the offshore operators.
Beside the official meetings with representatives components of the project. These
of Ministries, the BSOG management team had correspondences are ongoing and shall
high level meetings with the Romanian expand to cover elements of the entire
Government, the President of the Senate and project. On-going relevant engagement
representatives of the Chamber of Deputies to with a large number of authorities will
discuss about BSOG’s activity in the Black Sea continue throughout the life of the
region. project.
(https://www.linkedin.com/company/10198071/)
1. Grindeanu meeting of 19 April Local and national NGOs were invited
to each public debate meeting
2. Ciolacu meeting of 14 November organized during the environmental
permitting process, however, with a
3. Tariceanu meeting of 15 November
single exception (Dominocost which
4. Mihalcescu meeting of 15 November attended the GTP public debate in
December 2017), no one else showed
For the purpose of preparing the ESIA report, their interest in attending the debates.
the following supplementary meetings have
been held:
- National Agency for Fishing and Aquaculture
(ANPA)
- Romanian Naval Authority (ANR)
40
method
Official correspondence was initiated with

different stakeholders. A stakeholder
engagement registry is kept by BSOG where all
the official correspondence is registered.
Representatives of BSOG have also
participated at different working group meetings
organised by national authorities for
development or improvement of sectoral
legislation or specific procedures for oil and gas.
BSOG reviewed and provided technical input to
several sectoral policies that are currently under
preparation.
Study visits - In July 2018 BSOG has organised a site

visit with three authorities (NAMR, EPA
and Corbu Mayor House) by helicopter at
Paula-1 exploration well during the
drilling stage.
Representatives Direct meetings During the preparation of the ESIA scoping Several meetings and site visits were On June 12th, 2019 a public
(and potentially and site visits report, BSOG has been in contact with the performed for collecting environmental consultation has been organized in
individual representatives of local community directly and social data required for the Vadu had to inform the community
members) of the impacted by the project. There were three purposes of ESIA and AESIA. During members on the MGD Project impacts
affected local missions conducted for data collection at the these site visits, the representatives of and works calendar in the area, once
communities / level of local community. During these missions, BSOG and external consultants the construction works will start.
Professional direct meetings with members of local performed meetings with local
groups community have been held and socio-economic authorities, residents of Vadu and
(fishermen/local data have been collected. The scope of these Corbu, owners of local businesses,
businesses) data collection missions were to understand the road users, other construction
socio-economic context of the project companies active in proximity of the
development and to capture the concerns and project area, representatives of local
expectations of local community. NGO, etc. All the persons met
considered that the BSOG project will
bring benefits to the local community
and have no objections or concerns
related to the project construction and
operation period.
41
method
Mass media Press releases The project development and the environmental BSOG has also prepared press BSOG has also prepared press releases
permitting process was reflected in the mass releases and media announcements, and media announcements, especially
media both at local and national level. BSOG especially when a project milestone is when a project milestone is achieved and
has published 12 public announcements in achieved and whenever a public whenever a public consultation session
2017, either on permitting process or decision consultation session was organised; was organised; Information on MGD
on permits issued. Information on MGD project progress project progress have been published in
have been published in national national newspapers such as: Ziarul
Beside these, BSOG activity has also been newspapers such as: Ziarul Financiar, Financiar, G4media, Capital,
reflected in 12 mass media articles either at G4media, Capital, Profit.ro, Romanian Profit.ro, Romanian Business Journal,
national level or international one. Business Journal, etc. etc.
BSOG is constantly monitoring the way they
BSOG is also making use of social BSOG is also making use of social
company activity /name is reflected in social
media in order to be able to provide media in order to be able to provide
media. According to the mass media report for
meaningful and timely information to any
the period October – December 2017, the name meaningful and timely information to
interested party (approximately 1
BSOG appeared 45 times in social media. (the any interested party (approximately 1
update/month). For further information
Social Media Analysis Report is available upon update/month). For further information you can access the LinkedIn profile, or
request) you can access the LinkedIn profile, or YouTube channel.
YouTube channel.
Employees/ Internal Official Prepared for presenting the results of the Prepared for presenting the results of Prepared for presenting the results of the
shareholders Reports performance monitoring and evaluation to the performance monitoring and performance monitoring and evaluation to
internal stakeholders and in order to provide evaluation to internal stakeholders and internal stakeholders and in order to
meaningful information to all the investors that in order to provide meaningful provide meaningful information to all the
are supporting BSOG. information to all the investors that are investors that are supporting BSOG.
supporting BSOG.
42
Stakeholder Engagement Activities during the Design and Implementation of Corporate
Social Responsibility Programme:
BSOG has also designed and started the implementation of its Corporate Social Responsibility (CSR)
programme based on the Company’s CSR policy. The BSOG CSR programme aims at developing positive
community relations and create a social partnership with the representatives of the local community
impacted by the Project.
Table 1 CSR activities performed in 2017
During 2017 several meetings were held with the representatives of Corbu Local Council, a local NGO
(Corbu Cultural Centre) and the Corbu School director to understand the community issues and needs.
Following the meetings, a CSR programme including 11 actions was implemented in 2017 (refer to Table
3 below). The majority of the actions part of this programme were implemented in cooperation with a local
NGO from Corbu. BSOG’s contribution was visible at local level as result of the support provided in the
organization of different cultural events and due to the support provided to vulnerable persons from the
local community.
Other activities supported and/or financed by BSOG in 2018 and 2019 in the community are indicated in
table 2 and 3 below.
43
The following engagement activities and community development actions have taken place in 2019:
• Community consultations - As part of the CSR programme, 2 sessions of community

consultations have been organized in Corbu with the aim to validate with local key stakeholders
the CSR directions and engage community in solving local needs. Organized on 12th July and
28th August 2019, the meetings gathered 16 members from the local community - representatives
of the City Hall, teachers, priests, owners of local business, NGOs representatives, regular
44
citizens. The community meetings conclusions were used to better draft the next stages of the
CSR strategy and better tailor future programs to the needs of the community.
• Mentorship program for Corbu School teachers - 12 teachers from Corbu school and NGO
representatives actively participated to a 4-half day working sessions, organized to the Cultural
Youth Center in Corbu. They learned how to write a project proposal, tips and tricks for successful
projects, and they succeeded to finalize the narrative for the 2020 project that will be implemented
in Corbu, as well the budget. The project, to be implemented starting with January 2020, aims to
reduce aggressivity in school and increase pupil’s life skills. More than 170 pupils and 150 parents
will benefit from the project activities, such as counselling, summer school, study visits in
museums, theatre shows, competitions, movies projections and workshops in school.
• Tourists and visitors impact report - The report was elaborated by the Romanian Ecotourism
Association (AER) who conducted the diagnosis of the region which concluded the following:
o even though the beach is part of ABRDD, there is no evidence of management,
information, interpretation and control.
o the municipality is supporting the costs of waste management, collecting the waste bins
ones per week, however no income or other benefits are present for the municipality.
o there is a mixture of arguments provided by various interviewed visitors, why are they
there: freedom, wild and unspoiled beach with constructions, back to nature;
o there is a higher degree of responsibility towards nature for some of the visitors.
In this regard, three meetings were organized in 2019 with DDBRA Governor and the Executive
Director which resulted in three actions that will be developed together with DDBRA in 2020:
o BSOG will assist DDBRA in better mapping Vadu beach by sending DDBRA the
biodiversity study completed recently for the Horizontal Directional Drilling feasibility study.
o BSOG will explore if any recommendation can be made to identify camping and parking
lots on Vadu beach.
o BSOG will start working on a promoting/communication plan to disseminate in 2020
DDBRA measures to protect Vadu beach, based on DDBRA’s new Regulation Plan
During the third meeting with the Governor, in November 2019, is was agreed that a
partnership agreement should be signed between the 2 institutions as a base for the future
joint projects. Before the partnership was officially closed, a new Governor was appointed by
the Romanian Government, in the last week of December 2019. In consequence all
discussions were postponed for 2020.
• Tree planting action in Corbu and Vadu - On October 27th, more than 130 trees were planted
in Vadu and Corbu by a joint team of volunteers from the local community and BSOG. A group of
45 teachers, pupils, teenagers from the Youth Center, local volunteers and BSOG staff gathered
to the Youth Center in Corbu and the school yard in Vadu to plant oaks and lindens.
• Vadu Patrol – Ecological education workshop - In response to the need identified by the
citizens in Corbu to act as environment guardians for the beaches, BSOG developed Vadu Patrol
– Patrula de la Vadu, a long-term program for environment protection education. The program
aims to raise awareness among adults and children in Corbu and Vadu regarding the importance
to keep unaltered flora and fauna, a key element for ensuring the sustainability of area. The first
action of the program was addressed to pupils (40 children from Vadu primary school and
kindergarten, aged 3-11), from Vadu School and brought an innovative educational approach to
environment education, combining learning and discovery lessons in classroom and nature. The
action was implemented with Oceanic Club Association, a well-respected NGO from Constanta.
• Dolphinarium visit - On December 20th, 50 pupils from the kindergarten and primary school in
Vadu, took the school bus to Constanta and enjoyed a special day in the Complex.
A Photo Report of the meetings performed in 2017-2019 is presented below:
45
Picture 1 Public Consultation Meeting – 27th of December 2017
Picture 2 Meeting of the National Committee for Costal Area
46
Picture 3 Meeting with the Prime-Minister of Romania
Picture 4 Site tour with local authorities, July 2018
47
Picture 5 Community consultation meeting, July 2019
Picture 6 Mentorship program for Corbu School teachers, November 2019
48
APPENDIX D CSR policy
CSR POLICY
BSOG–CO–POL–001–D01
BSOG's CSR policy is rooted in the Company's core values of safety, perseverance, pioneering, team work and
accountability and aims to meet the expectations of the Company's stakeholders that BSOG runs its business guided by
international standards and best industry practices.
Employees & people
BSOG values diversity and seeks to provide all staff with the opportunity for employment, career and personal
development on the basis of ability, qualifications and suitability for the work as well as their potential to be developed at
the job, while working towards our business objectives.
We seek to guarantee that all employees are treated fairly and with dignity and consideration for their goals and
aspirations.
Health & Safety
We are committed to conducting our operations safely and responsibly, which means supporting local communities and
protecting the environment, as well as looking after the health and safety of our employees and contractors hired by
BSOG.
Our goal is to maintain a zero-accident record and we are continually looking for ways to improve our Health and Safety
Management System.
Community
We seek to make positive contributions to the local economy by improving and maintaining the wellbeing of the
community local to our operations. To this end, we work to establish long-term relationships with the local community,
understand its needs and assist the community help itself.
Our CSR activities focus on education, community development and environmental protection and are conducted in
partnership with local people, NGOs, local authorities and other stakeholders. BSOG is committed to making a positive,
sustainable impact in these areas.
Corporate Governance
BSOG is committed to ensuring that its daily operations are conducted in all respects according to rigorous ethical,
professional and legal standards.
To this end, BSOG has put in place a system of procedures that enhances the transparency of its business through the
strict compliance with the applicable laws and regulations and has zero tolerance to bribery and corruption.
Environment
BSOG recognizes that minimising environmental impact and the prevention of environmental incidents are essential to
the operation of our business. We continuously improve our performance by setting and reviewing environmental
objectives and targets and monitoring our progress.
Our environmental responsibilities are addressed throughout the value chain and we are constantly investing in ways to
reduce our carbon footprint and waste as well as to enhance our energy and water efficiency.
Mark Beacom Signed:
Chief Executive Officer

Black Sea Oil & Gas
Date: 27.02.2019
49
APPENDIX E
CSR activities report 2020
2020 pandemic required adapting the CSR activities planned to be implemented in Corbu. A string of
challenges came also with the new context, impacting the development of potential activities:
- Quarantine restricted travel and direct meetings
- Schools closed for more than one semester and all activities involving direct contact were halted.
Many regular educational activities could not be any longer implemented.
- As classes moved online, many pupils in Corbu, from poor social backgrounds, could not attend
classes as they lacked access to internet or devices (tablets).
- Vadu beach popularity among tourist increased significantly in 2020 and in consequence the no.
of tourist and their negative impact on the beach and surrounding wildlife. Even though the no. of
tourists reached a never-before-seen peak of 25.000 in a weekend by August, there are still not
sustainable measures taken to ensure lower tourism impact in 2021.
Considering the challenging year we have succeed to implement a range of impactful activities for the
community, responding in this way to the newly emerged needs pandemic brought:
1. Advocating for improved measures to protect Vadu beach
In 2020 we continued our efforts to connect with relevant stakeholders involved in protecting Vadu beach.
The most important action in this direction was to start discussions with one of the main environmental
NGOs working for protecting Romanian shores, Mare Nostrum Association. Together with Mare Nostrum
we debated the main environmental challenges and solutions for Vadu beach, and we agreed on a string
of potential actions that could be implemented in 2021. One of them will be an awareness campaign
among tourists and campers on the beach.
We informed ARBDD about our intentions to develop projects aiming to protect Vadu ecosystem and we
shared with the new leadership of the institution (appointed in December 2019) our proposals.
Together with our partner, AUDITECO, we assessed and discussed potential awareness measures to be
implemented together with local and national authorities to protect wildlife in Corbu. Among them are
installing informative boards in various points in the reservation on the road connecting Vadu village with
the beach, informing tourists about the ecosystem and warning them about overspeeding impact in the
reservation.
Together with Raluca Serban (Auditeco) we followed the road to the beach and draw an imaginary road
map of protected species (like turtles). Based on the current ARDD boards distributed on the cars road,
we decided to propose ARBBB to place new boards with relevant signs (Attention turtles, Drive carefully,
Description of protected species) at various points along the road to the beach. For each of this point
Auditeco will present an information board proposal to be discussed with ARBDD and the Corbu Town
Hall.
2. Support to Vadu school in implementing BSOG grant
The start of the project UBUNTU, implemented by Corbu school with a 12.000 euro grant from BSOG,
50
was marked with the beginning of pandemic in 2020. Therefore, we discussed with the project team to
adapt the activities though keep in mind the objectives of the project.
The main activities implemented by the school in 2020 included:
- Counselling sessions with pupils and parents
- Online drawing contest for pupils A friendly school
- Movie and theatre viewing on bullying thematic for pupils
- Training for teacher’s development.
3. Improving access to online education for all pupils in Vadu kindergarten and school
In October 2020 awarded a sponsorship of 6380 Euro to Save the Children Romania to provide 46 Alcatel
tablets connected to internet for 24 months, for all pupils attending Vadu kindergarten and primary school.
The donation was publicly endorsed by Omid Ghanadi, the architect for one of the most popular TV social
shows in Romania.
Due to Covid-19 protection measures, the ceremony was organized outside the school yard and no
children were present. The tablets were given to the School Mayor and teachers and were provided to
children after they were carefully disinfected.
The ceremony organized on October 7th, was attended by 5 BSOG 5HDD site and office staff, including
Ana Maria Pericleanu, Save the Children personnel, including Gabriela Alexandrescu, director, Omid
Ghanadi, school Mayor and teachers.
Media mentioning of BSOG donation:

• https://www.protv.ro/evenimente/omid-ghannadi-sustine-campania-salvati-copiii-romania-de-
dotare-a-scolilor-cu-tablete-pentru-cursuri-la.html
• https://www.agerpres.ro/comunicate/2020/10/07/comunicat-de-presa-salvati-copiii--586842
• https://spotmedia.ro/stiri/educatie/salvati-copiii-doteaza-scoala-din-vadu-cu-tablete-si-acces-la-
internet-alte-40-de-scoli-inca-mai-au-nevoie-de-ajutor
• https://stirileprotv.ro/stiri/social/zeci-de-copii-sarmani-din-vadu-au-primit-tablete-pentru-scoala-de-
la-salvati-copiii-si-omid-ghannadi.html (no direct, but BSOG colleagues were part of the story
• https://copaculcufaptebune.ro/uncategorized/salvati-copiii-doteaza-scoala-din-vadu-cu-tablete-si-
acces-la-internet/
• https://romaniaresponsabila.ro/salvati-copiii-romania-doteaza-scoala-din-vadu-cu-tablete-si-
acces-la-internet/
4. Preserving local traditions and history by supporting the creation of Corbu 1st monography.
In 2020 we also awarded a sponsorship of 5000 RON (approx. 1000 EURO) for the publishing of Corbu
1st monography. The launching event, organized on March 7th at Cherhana Moesia in Vadu, brought
together the authors as well as other local KOLs who presented the importance and value of this
document for the local community.
51
Media mentioning of BSOG donation:
• https://www.tvlitoral.ro/monografia-comunei-corbu/
• https://www.cugetliber.ro/stiri-social-istoria-comunei-corbu-publicata-intr-o-ampla-monografie-
397603
• https://www.ziuaconstanta.ro/stiri/cultura/eveniment-editorial-monografia-comunei-corbu-o-
calatorie-prin-istorie-713238.html
• https://www.facebook.com/centrulculturalcorbu/posts/2757300281018667
5. Christmas gifts to Vadu school pupils
2020 was the fourth year in a row when BSOG became Santa for Vadu school pupils, despite the
pandemic restrictions which did not allow direct interaction with the children. Gifts consisting of a puzzle
adequate to the age group, book, sweets, toy, personalized wooden globe, MGD bag (total value 1000
EUR) were delivered to Vadu schoolteachers who went with a dressed Santa home to each of the Vadu
pupils to offer them. All were delighted to see that BSOG Santa reached them in the pandemic year.
52
APPENDIX F Social media coverage and press releases in 2020
LinkedIn Statistics (data retrieved on 05.03.2021)
53
Mass Media coverage for 2020:
54
55
56
57
58
Youtube Statistics (retrieved on 05.03.2021)
59
APPENDIX G Feedback form on BSOG intranet for employees
60
APPENDIX H Employee engagement in CSR activities and internal
announcements
61
APPENDIX I Photo report of the works carried out in 2020
Picture 1 Ana platform - Jacket load out - Agigea
Picture 2 Construction of Ana Platform in Agigea
62
Picture 3 and 4 Gas Treatment Plant in Vadu
Picture 5 HDD site on Vadu Beach
63
Picture 6 and 7 Pipeline laying in Vadu
64

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Midia Gas Development Project

Stakeholder Engagement Plan (SEP) – 2021

Black Sea Oil & Gas SA

Midia Gas Development Project – Stakeholder Engagement Plan – 2021

Midia Gas Development Project – Stakeholder Engagement Plan – 2021

Abbreviation or Acronym Definition

BSOG Black Sea Oil & Gas

DDBRA Danube Delta Biosphere Reserve Administration

EBRD European Bank for Reconstruction and Development

EIA Environmental Impact Assessment

EPA Environmental Protection Agency

ESIA Environmental and Social Impact Assessment

AESIA Additional Environmental and Social Information and Assessment

FEED Front End Engineering Design

GTP Gas Treatment Plant

LPA Local Public Authorities

LRP Livelihood Restoration Plan

LRR Livelihood Restoration Report

MEG Monoethylene glycol

MGD/MGD Project Midia Gas Development/Midia Gas Development Project

NGO Non-Governmental Organisation

NTS National Gas Transmission System

SEP Stakeholder Engagement Plan

TEG Triethylene glycol

TRANSGAZ National Gas Transmission Company

Midia Gas Development Project – Stakeholder Engagement Plan – 2021

• assess the potential economic displacement aspects identified in the LRF;

1.2 Brief Project Description

The concept of the MGD Project is presented in Figure 1.

Figure 1 Concept for the Midia Gas Development Project

Midia Gas Development Project – Stakeholder Engagement Plan – 2021

1.2.1 Ana offshore wellhead platform, including topsides and substructure

1.2.2 Subsea infrastructure including Doina subsea facilities, Ana-Doina infield

Midia Gas Development Project – Stakeholder Engagement Plan – 2021

Midia Gas Development Project – Stakeholder Engagement Plan – 2021

Figure 4 The Danube Delta Biosphere Reserve

Midia Gas Development Project – Stakeholder Engagement Plan – 2021

Site name Site code Location relative to MGD Project

1.2.3 Gas Treatment Plant (GTP) and associated onshore pipeline

Midia Gas Development Project – Stakeholder Engagement Plan – 2021

Site name Site code Location relative to MGD Project

Midia Gas Development Project – Stakeholder Engagement Plan – 2021

The project obtained all permits required for construction.

1.3.1 Current project status

Midia Gas Development Project – Stakeholder Engagement Plan – 2021

The following construction works are foreseen for 2021:

2 REGULATIONS AND REQUIREMENTS

Midia Gas Development Project – Stakeholder Engagement Plan – 2021

• Government Decision no. 878/2005 on right to access to environmental information transposes EU

• Emergency Government Ordinance no. 195/2005, related to the environmental protection, as

• Government Decision no. 445/2009 on environmental impact assessment pertaining to certain

Midia Gas Development Project – Stakeholder Engagement Plan – 2021

2.2 European Bank for Reconstruction and Development (EBRD)

3 STAKEHOLDER IDENTIFICATION AND MAPPING

Midia Gas Development Project – Stakeholder Engagement Plan – 2021

Midia Gas Development Project – Stakeholder Engagement Plan – 2021

Midia Gas Development Project – Stakeholder Engagement Plan – 2021

Table 3 Results of Stakeholder Analysis

External Stakeholder Potential Interest on the project

National Authorities Project to be developed and implemented according to