Freeport LNG maintains a structure of checks and balances that preserves and creates value for our business, aiming to meet our commitments to our customers and other stakeholders. Our board of managers is comprised of executive leadership, investor representatives and industry experts who oversee our company performance and business operations.

Our corporate governance system is designed to ensure that the company is managed in the interests of its equity investors, including minority investors, and that the board has appropriate control and oversight responsibilities.

Board of Managers

Our board of managers is responsible for risk oversight, including financial, construction and operational risks. The board works to ensure that Freeport LNG conducts its business responsibly and ethically, with a focus on sustainability, safety and strict adherence to all laws and regulations. The board appointment rights in favor of our shareholders ensures the independence of our board, with seven of our eleven board members being independent. The remaining four members of our board are members of the company’s executive leadership. Our board is actively engaged in the management of our business, with near perfect attendance by all of our board members at our quarterly and special board meetings in the past year.

Bios for our current board members are available on our website at www.freeportlng.com.

Audit Committee

Our audit committee oversees accounting and financial reporting processes and the audits of our financial statements. The audit committee is chaired by an independent manager. The audit committee supports adherence to internal controls over financial reporting and encourages continuous improvement and maintenance of open channels of communication among the board, our independent auditor, financial and accounting management, internal audit and legal and compliance functions.

Construction Committee

Our construction committee oversees the permitting, construction and planned operation of projects constructed or proposed to be constructed by Freeport LNG, and advises the board and management of the company on the development and progress of such projects, including project health, safety, and environmental policies and performance, project execution status, project management team resources, project staffing, and EPC contract matters and claims. The construction committee is chaired by an independent manager, and supports adherence to company policies and procedures with respect to health and safety, regulatory and legal compliance, and project execution objectives.

Under our corporate governance structure, the board is directly representative of and accountable to our equity investors, and the short- and long-term interests of our investors and the board are directly aligned. This seamless alignment of interests between our company, its board and its investors, and the direct access that our investors have to company management and information, uniquely positions Freeport LNG to protect investor rights and interests and ensure strong corporate governance.

Oversight

Our ethics and integrity efforts are led by our VP, Government Affairs, Risk and Compliance and our SVP, Chief Human Resources Officer. These senior officers of the company manage and implement our ethics and compliance policies, and work with executive leadership to address concerns that may arise.

Policies

Our codes of conduct apply to all of our employees, and provide the framework for adherence to Freeport LNG’s values of honest and ethical conduct, and having a respectful workplace. Our policies outline our commitment to ethical behavior, timely and accurate reporting, regulatory compliance, and accountability. Our policies are reviewed and updated annually. We also conduct annual compliance and ethics training across our organization, with all applicable employees certifying that they have received, reviewed, understand and agree to adhere to our ethics and compliance policies. Our key policies, include:

• Anti-corruption policy;
• Gifts, favors and entertainment policy;
• Know-your-customer due diligence procedures policy;
• Conflict of interest policy;
• Guidelines for appropriate conduct policy;
• Internet code of conduct policy;
• Prohibition against threats and workplace violence policy;
• Equal employment opportunity policy;

• Anti-retaliation policy; and Anti-discrimination policy

Our employees completed over 1000 hours of compliance and ethics training in 2022.

Our anti-corruption and know-your-customer due diligence policies establish the necessary requirements to comply with applicable anti-corruption, anti-bribery and economic sanctions laws. Our anti-corruption policy prohibits facilitation payments and establishes guidelines for ethical behavior. Our suppliers are required to meet our standards of ethical business conduct, as well as comply with all applicable laws, including labor, health and safety, and environmental laws. During the prequalification process and throughout supplier engagement, we conduct risk assessments of our suppliers on their regulatory compliance and financial stability.

Collectively, our policies support our ability to maintain the highest standards of conduct and ethics among our employees, suppliers and business partners.

Reporting Concerns

If an employee observes a violation of our codes or policies, they have been trained to contact their supervisor, another member of company management, or a human resources representative. Employees may also report concerns confidentially, with the option to remain anonymous, via email or through our employee hotline. Once we receive a report, it is assigned to the appropriate person for investigation. As part of our annual compliance and ethics training, we inform employees on methods to report ethics concerns. Our anti-retaliation policy strictly prohibits any form of retaliation against employees who make good-faith complaints, or report, file, testify, assist, or participate in any manner in any investigation or other proceeding conducted by or with respect to the company. Any personnel involved in retaliation are subject to appropriate disciplinary action, which may include termination of employment.

In addition to implementing robust internal control processes to comply with existing regulations and proactively develop control mechanisms, we emphasize a focus on risk governance and implementation of processes to maintain an effective risk culture.

Risk Governance

Our VP, Government Affairs, Risk & Compliance is generally responsible and accountable for our Enterprise Risk Management (ERM) program, and chairs our risk committee, which is comprised of senior executives and managers from across the organization. The risk committee meets on a quarterly basis to define, review and update the top existing and emerging risks to the organization. Once defined, risks are assigned to risk owners, and measured based on probability and severity. Risk mitigants are detailed and those mitigants are updated regularly. Annually, our VP, Government Affairs, Risk & Compliance briefs the board regarding the status of the company’s ERM program and top risks. Internal Audit periodically audits the entire ERM program process and reports findings to the Audit Committee.

Sensitivity Analysis and Stress Testing

We conduct comprehensive scenario analysis and stress testing. The risk committee evaluates top risks of the organization, and conducts stress testing or sensitivity analyses on selected top risks annually. Analysis and testing is performed at the functional department level, where deep subject matter knowledge can drive thorough consideration of specific risks, various potential events and outcomes, and scenario evaluation. Results of these exercises are presented to the risk committee, and included in the reports to the board.

Risk Culture

In order to promote and enhance an effective risk culture, company goals and compensation are tied to certain risk mitigants, including safety performance. In addition, the ERM process provides members of the risk committee with training on risk management principles and processes, and encourages promotion by those managers of an effective risk culture across the organization. Our personnel are trained to report potential risks to supervisors, senior management, or confidentially via our employee hotline. Our anti-retaliation policy strictly prohibits any form of retaliation against employees who make good-faith reports of potential risks.

LNG exports from Freeport LNG offer an opportunity to play a key role in the global transition to cleaner, less carbon-intensive energy sources. This compels our board and executive leadership to clearly articulate and execute upon strategies for managing such risks and capitalizing on such opportunities.

Oversight of sustainability is formally integrated into our governance structure, with established executive and board oversight of sustainability and social-responsibility issues. Our SVP & Chief Legal Officer chairs our ESG committee comprised of Freeport LNG personnel with relevant subject matter expertise from across the organization. The chair of the ESG committee liaises with the board regarding ESG risks and opportunities impacting our business, and our efforts to manage and address them.

Our supply chain management strategy is to access industry leading and innovative solutions that reduce cost, add value, while uncompromisingly supporting our safety, ethics, and business controls. Our procurement efforts prioritize local suppliers, provided they are able to supply competitive and quality goods and services, while meeting our high-performance standards. In addition to requiring that our suppliers commit to our standards for environmental protection, health and safety, regulatory compliance, cybersecurity, and insurance, we identify and actively manage the performance of our critical suppliers.

Awareness

Critical suppliers are those who provide products or solutions that are not easily substitutable, and the loss of which could result in significant adverse impact to our operations. We currently rank our critical suppliers into three categories: (1) those with respect to which supply chain failure could result in suspension of operations; (2) those with respect to which supply chain failure could disrupt operations, though not resulting in significant interruption of operations; and (3) those for which there are no practical substitutes.

Risk Exposure and Management

In evaluating supplier conduct, we place particular focus on compliance with health and safety protocols and insurance requirements. As part of the supplier onboarding process, all suppliers performing services at our operating facilities must attend a safety orientation in which they are familiarized with Freeport LNG’s health, safety, and environmental policies and procedures. Additionally, all suppliers performing risk-based services at our operational facilities must be qualified through a third party that reviews and certifies a supplier’s safety track record. This safety compliance is then monitored on a continual basis following onboarding to ensure continued compliance. We also use a third-party service to verify compliance with insurance requirements, both at onboarding and the full term of the supplier service. We also perform in-person risk review, including site visits if appropriate, with selected suppliers when quality issues or other important service issues are identified.

Organizations, large and small, have had their operations impacted by a range of breaches. At Freeport LNG, we take an aggressive approach towards cybersecurity, working daily to mitigate and manage threats and risks in order to maintain business continuity and prevent reputational harm.

Incremental improvements to Freeport LNG’s robust cybersecurity program continued to be made in 2022. These efforts primarily centered around enhancement of our detection and response solutions, cybersecurity hardening of vendor solutions, procedure refinement, risk measurement, microsegmentation and disaster recovery.

In the year ahead, we look forward to building on these efforts, bolstering our commitment to mitigating and managing cybersecurity risks. Key 2023 cybersecurity initiatives include:

• Penetration testing of the Industrial Control System (ICS) and Business Network;

• Implementation of enhanced detection capabilities on ICS, enhanced adaptive identity management and autonomous ransomware protection;

• Process enhancements, including a holistic approach to ICS disaster recovery testing, of cybersecurity awareness training adjusted to current techniques, greater network microsegmentation granularity, and enhanced change management and task workflows; and

• Review of next generation security solutions.

Freeport LNG advocates for appropriate representation in legislative, political and public discourse in a manner that protects our interests, and maintains the integrity of our business.

Our legal department organizes and manages government advocacy efforts pertinent to our business and public policy interests. Led by our VP, Government Affairs, Risk & Compliance, we develop and advocate policy positions through our participation in trade associations and partnerships, and engagement with federal, state and local government officials. All of our employees are expected to maintain the highest standards of ethical behavior in conducting any political advocacy, and to maintain full compliance with applicable laws and company policies. The board is provided regular updates regarding our governmental affairs advocacy.

Freeport LNG prioritizes engagement with industry, trade and business associations. Our participation in these organizations allows us to provide insight and expertise on policy and regulatory issues that affect our industry, business and operations. Major associations of which we are members include Natural Gas Supply Association/Center for LNG, National Association of Manufacturers, Texas Association of Manufacturers, Texas Oil & Gas Association, Texas Pipeline Association, and Texas Civil Justice League. In 2022, we incurred expenditures of

approximately $208,000 toward our membership with these trade associations.

Political Contributions

Freeport LNG does not have a political action committee or use company funds or assets make direct political contributions.

Lobbying

We engage with policymakers and advocate for policies, rules and legislation in the United States that support our strategic business objectives and promote the success of our organization. We comply with all regulatory standards associated with any political engagement activity. In 2022, we incurred expenditures of approximately $334,000 with external state and federal lobbyists.