Whiting 2019 Sustainability Report

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Dear Stakeholders, W h i t i n g co n t i n u e s t o b u i l d o n i t s commitment to sustainability planning, reporting and execution. In this, our third annual sustainability report, you will see tangible progress and a strong resolve to advance sustainability initiatives. With a clear roadmap anchored in a set of 24 key initiatives established in 2018, our team has progressed across multiple areas. This report further enhances how we communicate this progress as it continues to index to multiple reporting frameworks to include Global Reporting Initiative (GRI), Sustainability Accounting Standards Board (SASB) and International Petroleum Industry Environmental Conservation Association (IPIECA). Whiting improved year-over-year performance in greenhouse gas intensity, water usage intensity and vehicle emissions. Whiting maintained its topquartile performance for lowest spilled hydrocarbons and produced water. Whiting has taken material steps to advance the Company’s safety culture. Whiting expanded Life Saving rules to all employees and contractors based on standards established by the International Association of Oil and Gas Producers (IOGP). And, safety performance was formally integrated as a key component in vendor selection. As these new health and safety management practices take root, we are beginning to see positive improvement in employee and contractor safety metrics. In 2019, Whiting established an ESG Committee under the Board of Directors to assist in oversight responsibilities of the Company’s programs, policies and practices relating to environmental, health and safety, sustainability, corporate social responsibility and other public policy matters. This committee will help ensure the Company continues to move toward best in class disclosure, engagement and implementation of environmental, social and governance standards. As challenges to our industry grow, our dedication to our people, the communities where we live and work, and the environment we all value and enjoy only increases. We will work together with all of our stakeholders to deliver business excellence built on a sustainable foundation anchored by Whiting’s core values. Our commitment to transparent sustainability reporting is unwavering. I am honored and privileged to share our progress with you. Lynn A. Peterson 2


11 Greenhouse Gas Intensity 34% decrease in Greenhouse Gas Intensity compared to 2018 12 Fleet Vehicle CO2 Emissions 16% decrease in total tons of CO2 emissions from 2018 to 2019 18 Water Use in Completions 25% reduction in water intensity from 2018 to 2019 18 Spill Prevention and Response Top 25th percentile of companies with lowest spilled volumes for both hydrocarbons and produced water per the American Exploration and Production Council (AXPC) survey data


27 Employee & Contractor Safety Decreased full year TRIR by 1%, with second half 2019 improving 18%, compared to full year 2018

31 Safety Programs Expanded Life Saving Rules to all employees and contractors based on standards established by the International Association of Oil and Gas Producers (IOGP)

36 Employee Benefits Enacted flexible work-life policy 40 Philanthropy & Volunteering Invested more than $1,000,000 and 4,000 volunteer hours in our local communities


42 Board Governance A formal ESG Committee was established 46 Human Rights Partnered with Truckers Against Trafficking (TAT) to combat human trafficking





ABOUT WHITING Whiting Petroleum Corporation is an independent energy company focused on the exploration and production of the crude oil and natural gas in the United States. Our assets, dedicated professionals, commitment to environmental stewardship and value-focused business execution position Whiting as an industry leader.


3 5








485.4 MMBOE



~10% FROM 2018




1 Corporate Office

3 Williston Office

2 Redtail Office

4 Robinson Lake Office 5 Watford City Office

OUR VALUES Creating a sustainable company has always been a foundation of Whiting’s vision. In 2018, that commitment was further embedded into our culture with the creation of Whiting’s Values. Our values were carefully crafted through thoughtful engagement with employees from various departments and offices. This resulted in the six values below that now form the foundation for how we work, interact, manage and lead with all internal and external stakeholders. In 2019, we formed a committee to recognize employees who epitomize these values. Each quarter, employees nominate colleagues who best represent one of Whiting’s six core values, and the committee reviews all nominations and selects a winner for each value. In 2019, an incredible 347 values nominations were received, proving Whiting employees are committed to delivering the energy our world needs in the right way.



Exhibiting the highest ethical standards

Exchanging information in a purposeful and productive way



Leading, serving and inspiring others

Preserving our environment and enriching our communities



Achieving operational excellence

Protecting people, property and communities


OUR REPORTING APPROACH Whiting began integrating sustainability planning and reporting in 2017 with our initial disclosure of sustainability issues on our website. In 2018, we contracted with a third-party to develop a more robust program. We first compiled a list of 300+ sustainability issues, informed by relevant non-financial reporting frameworks, including the Global Reporting Initiative (GRI) and Sustainability Accounting Standards Board

(SASB). We also cross-checked the issues identified against the key oil and gas priorities disclosed by major institutional investors and Non-Governmental Organizations (NGOs). Whiting bucketed the issues based on commonality and then narrowed the issues list to 24 sustainability topics that are most important to achieving lasting stakeholder success.




Air Quality

Health and Safety Management System

Corporate Governance

Greenhouse Gas Emissions Water Management

Community Safety Engagement

Waste Management

Emergency Response Preparedness

Hydraulic Fracturing and Chemical Management

Diversity and Inclusion

Land Impact and Remediation Biodiversity

Legal & Regulatory Compliance Ethics, Corruption and Anti-Bribery Executive Remuneration

Training and Development

Risk Identification and Management Processes

Employee Engagement

Climate Risk

Local Investment

Supply Chain Sustainability

Community Stewardship

Human Rights

Volunteering and Philanthropy

Scope of Reporting This sustainability report covers calendar year 2019 for the principal assets operated by Whiting and our wholly owned subsidiaries, including our North Dakota and Montana Williston Basin and Colorado DJ Basin operations, unless specified otherwise. Reported metrics take into consideration GRI, SASB and International Petroleum Industry Environment Conservation Association’s (IPIECA) disclosure standards.


Our annual report, U.S. Securities and Exchange Commission Form 10-K filing and proxy statement provide detail of our financials, production by commodity and incremental governance information. http://whiting.com/ investor-relations Assurance Information in this report has been subject to internal review, and we believe it to be correct at the time of reporting. We did not have a third-party assess the report.



GREENHOUSE GAS INTENSITY 34% decrease in Greenhouse Gas Intensity from 2018 to 2019.

CO2 EMISSIONS A 16% decrease in vehicle fleet tons of CO2 emissions from 2018 to 2019 with a 29% decrease since the start of the fleet program in 2017.

ENVIRONMENT LEAK DETECTION 47% decrease in total number of issues discovered during inspections from 2018 to 2019.

WATER REDUCTION 25% reduction in completions operations water intensity from 2018 to 2019.


Whiting is committed to protecting the environment as we safely and responsibly develop our resources. This commitment is a key aspect of the Whiting Value of Meaningful Stewardship. At all levels within our company, we consider how our operations affect the environment and how to reduce our impact. We seek ways to better protect habitats, find alternatives to freshwater use, reduce the lifecycle methane emissions of our operations and encourage waste reduction programs. We dedicate significant staff and resources to ensure compliance with environmental laws and regulations. Whiting is always looking for ways to improve our environmental performance metrics.

In 2019, Whiting, peer companies and the Colorado Air Pollution Control Division (APCD) were awarded the United States Environmental Protection Agency’s Clean Air Excellence Award for State/Tribal/Local Air Quality Policy Innovations. In July 2016, recognizing the need for improved performance, APCD and the oil and gas industry convened a workgroup on the development of a set of flexible guidelines to help ensure compliance with Colorado air quality regulations. The workgroup collaborated for over 22 months to develop the guidelines published in May 2018. The guidelines provide owners and operators with information to assist in designing, operating and maintaining storage tanks and vapor control systems in accordance with Colorado law, while also granting flexibility to adapt the concept to a company’s unique operating practices. The ultimate goal for this project is to improve the performance of storage tank emissions capture and control systems to ensure protection of public health and the environment.

INDUSTRY LEADERSHIP Whiting is dedicated to learning, sharing and operating responsibly. We engage with a number of organizations and participate in developing industry standards through peer group and agency cooperative efforts. Below is a list of some the organizations. Whiting is proud to be an active member in The Environmental Partnership. The Environmental Partnership is made up of U.S. oil and natural gas companies committed to improving the industry’s environmental performance by sharing information on best practices. Learn more about The Environmental Partnership by visiting their website: theenvironmentalpartnership.org AXPC – American Exploration & Production Council

NDPC — North Dakota Petroleum Council

COGA — Colorado Oil and Gas Association

WEA – Western Energy Alliance

TEP — Environmental Partnership


INTELLIGENT PIPELINE INTEGRITY In 2018, Whiting became a founding member of the Intelligent Pipeline Integrity Program (iPIPE), a collaboration of oil and gas operators and the Energy and Environmental Research Center. The focus of this effort is to advance nearly-commercial, emerging technologies that prevent and detect natural gas pipeline leaks. At the 2019 Annual Interstate Oil & Gas Compact Commission (IOGCC) Conference, iPIPE accepted the Chairman’s Stewardship Award for Environmental Partnership, receiving recognition for innovation, dedication and passion for the environment.

AIR QUALITY Whiting estimates air emissions from our operations by using state and federal emission estimation methodologies along with manufacturer-provided or EPA-required emissions factors. Whiting complies with the federal Clean Air Act and companion state laws that regulate emissions of various air pollutants from industrial sources through permitting programs that require emission controls and reductions and that utilize monitoring and reporting requirements to demonstrate compliance. For example, the Environmental Protection Agency (EPA) has issued New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants


(NESHAPs) to reduce the emissions of key pollutants such as volatile organic compounds (VOCs), nitrous oxide (NOx) and carbon monoxide (CO), as well as hazardous air pollutants (HAPs) such as benzene. Among other things, these standards require the application of reduced emission completion techniques (green completions) associated with the completion of newly drilled and fractured wells in addition to existing wells that are refractured. The rules also establish emissions minimization requirements for storage tanks, compressors, dehydrators and other production equipment. In complying with these requirements, Whiting significantly reduces the potential emissions from its operations.

GREENHOUSE GAS EMISSIONS Whiting tracks and reports GHG emissions pursuant to applicable reporting laws. Whiting estimates emissions in accordance with EPA’s Mandatory Greenhouse Gas Reporting rule (40 CFR Part 98). These emissions are reported to EPA annually, and reports are made publicly available on EPA’s webpage at www.epa.gov/ghgreporting. We measure or estimate emissions of methane, carbon dioxide and nitrous oxide for multiple emission source

types across the production, gathering and processing segments. Where possible, Whiting uses measured emissions rates to complete GHG emission calculations. For example, Whiting measures actual leak rates of reciprocating rod packing vents and gas plant equipment leaks. We estimate other GHG emissions for sources using mandated emissions estimation practices.

Greenhouse Gas (CO2e) Emissions and Intensity BASIN/FACILITIES

CO2e (MT) 2017



Williston Basin




Ray Gas Plant










Total GHG as CO2e




Production (MBOE)




GHG Intensity (MT/MBOE)






Denver Basin Redtail Gas Plant Permian Basin

% Change

Table Notes: This table above summarizes Whiting’s reported emission of carbon dioxide equivalent (CO2e) in metric tons (MT/MBOE). CO2e was calculated as part of the EPA’s Mandatory Greenhouse Gas Reporting Rule. In 2018, Whiting experienced multiple third-party midstream challenges (e.g., maintenance outages, infrastructure delays, and pipeline constraints). Some of these issues carried over into early 2019. Whiting is committed to improving its gas capture rate through better planning and communication with its third-party midstream partners. The numbers are subject to change based on EPA’s comments and interpretations.


Whiting’s commitment to reduced emissions is reflected in the following eight active programs. 1) VEHICLE FLEET MANAGEMENT Whiting’s Vehicle Fleet Management is an integral part of our commitment to environmental stewardship and safe operations. Whiting utilizes Pedigree Technologies GPS Fleet Management System, which has been fully operational since 2017 for all fleet vehicles in North Dakota, Montana, Colorado, Texas and Arkansas. The Pedigree system allows for greater visibility and transparency into the driving habits of our employees. Whiting also utilizes DriverCare, a fleet driver safety and risk management application.

Our Vehicle Fleet management program promotes safe driving, fuel efficient driving practices and lower idle time. This data allows us to see areas for improvement and to customize training for each company driver. Whiting decreased vehicle CO2 emissions by 16% in 2019. At fault accidents also fell by 42% from the previous year. More details are included in the table below.





2018 TO 2019

2017 TO 2019 % CHANGE

Total Metric Tons of C02 emissions






Average Unit Pounds of CO2






2) LEAK DETECTION AND REPAIR (LDAR) PROGRAM Whiting is committed to minimizing methane and other hydrocarbon leaks across our operations. We conduct leak inspections that meet or exceed the scope and frequency of applicable federal or state regulatory standards. As part of these efforts, our staff utilizes optical gas imaging (i.e., forward-looking infrared (FLIR) camera technology) across all our operations. Audio, visual and olfactory (AVO) and FLIR camera inspections are completed by a dedicated internal inspection team in the Williston Basin, field operators in the DJ Basin and by our


environmental staff in other operating areas. In addition to our dedicated inspection staff, we also train field operators to spot and repair leaks during daily rounds. Our inspection teams, environmental staff and production staff are trained annually on equipment, techniques, Standard Operating Procedures (SOPs) and best practices per the table below. Leak inspections are performed on all equipment and associated piping and fittings at subject facilities. Whiting responds expeditiously to repair any leak discovered. Following repair efforts, we re-inspect to ensure the repairs were successful.

Whiting led the industry by implementing FLIR camera inspection across our operations in 2010, years ahead of the regulations that now require these FLIR camera inspections. In 2019, Whiting conducted over 14,000 inspections incorporating FLIR camera and AVO (Audio, Visual, and Olfactory). Of these inspections, 45% were voluntary and over 1 million components were inspected for issues at 872 facilities. Inspection findings were reviewed quarterly, and emissions reduction measures were implemented or refined with the knowledge gained from the inspections. We consider this review essential to our continuous improvement process, which is expanded upon below.

LDAR and AVO Frequency by Region DJ BASIN






Completed By

Field Operators

Field Operators

Field Operators

Inspection Team

Inspection Frequency

Weekly to Monthly

Monthly to Annually


Monthly to Quarterly

For many facilities, this is more frequent than what is required by applicable state and federal leak detection requirements. In other operating areas where there are no state or federal leak detection requirements, we strive to conduct FLIR inspections at least annually.



Our Approach to Reducing Equipment Leaks:

• AVO and FLIR Inspections • Repair Work Orders • Re-monitoring

• Equipment inspection • Clean, repair or replace


Preventative Maintenance

Lessons Learned

Analysis & Data Review

• Continuous feedback loop • Update PMs, inspections, design, construction, or operation

• Inspection data analysis • Effects of design, construction, operation • Repair methods

Whiting collects information during inspection and repair activities. This information is reviewed as part of our Predictive Analysis Program (PAP) in the Williston and DJ Basins. We consider inspection results, repair trends, preventative maintenance activities, operational conditions, environmental factors and facility and equipment attributes during crossfunctional team reviews. Where we identify recurrent issues in this review, we implement corrective actions as necessary. Through our evaluation, we are continually working to identify areas of focus where our efforts can drive improvement.

Whiting’s peer-leading programs in LDAR and PAP have resulted in a reduction of the number of leaks and in enhancements to our repair and maintenance practices. The PAP program helped us incorporate better equipment and component designs that resulted in an overall reduction in emissions. Over the course of our inspection program, we have experienced significant improvement in the performance of our locations, as demonstrated by several key metrics from our Williston basin operations:




decrease in total number of issues discovered during inspections

increase in the length of time between when a previous issues was repaired and when a new issues arises on a respective tank battery

4) PREVENTATIVE MAINTENANCE Whiting has developed a robust program to track and trend maintenance concerns to resolution. This allows Whiting to target recurring maintenance issues and enhance equipment reliability. Whiting has leveraged manufacturer recommendations, industry best practices and input from other sources, including our inspection programs and regulatory requirements to develop and influence our Preventive Maintenance (PM) programs. Our PM plans target equipment critical to storage tank emissions management in addition to other operational equipment. By properly maintaining equipment, Whiting prevents emission releases. Whiting continues to evaluate these PM plans for improvement opportunities.

5) LOW-EMITTING PNEUMATIC CONTROLLERS Whiting has implemented a policy to require that any equipment either purchased, replaced or modified must be fitted with a low-bleed natural gas, no-bleed natural gas, compressed air or equivalent pneumatic controller. Whiting has eliminated high-bleed pneumatic controllers from its operations except where a high-bleed controller is required for safety or operational conditions. This

policy greatly reduces our carbon footprint air pollutant emissions and conserves valuable natural resources. Additionally, Whiting looks for opportunities to eliminate or control emissions from the remaining low-bleed pneumatic controllers by: • Routing their emissions back into the process, • Routing their emissions to a combustion device, • Using electrically actuated controllers, or • Using compressed air as the pneumatic source

6) I NVESTMENT IN GAS GATHERING AND PROCESSING Whiting has made significant investments in natural gas gathering and processing infrastructure to maximize natural resource recovery and minimize natural resource waste. Whiting works to capture and market natural gas resources wherever feasible. Over the last several years Whiting has constructed multiple gas gathering systems and gas plants in areas that lacked critical infrastructure. In 2018, Whiting built the Walleye Pipeline to send gas to the Ray Gas Plant. As a result, over 3 billion cubic feet of gas was sent to the Ray Gas Plant through the Walleye Pipeline in 2019.


7) REDUCED EMISSIONS COMPLETIONS Whiting has implemented techniques, such as dual fuel generators, to minimize venting of gas during drilling and workover operations. The use of these techniques has reduced Whiting’s carbon footprint, air emissions and flaring during completions and workovers.

8) FACILITY ENVIRONMENTAL INSPECTIONS Whiting conducts annual comprehensive facility environmental inspections. These inspections assess compliance with Spill Prevention Control and Countermeasure (SPCC)

and air quality related requirements. These inspections are designed to minimize or eliminate potential hydrocarbon releases and reduce environmental impacts. Periodic stormwater inspections are also conducted at regulated facilities to prevent liquid leaks and sediment discharge caused by stormwater runoff. Through these inspections, Whiting can anticipate failures and make timely repairs of equipment. This practice also realizes an increased retention of land mass and protection of the environment surrounding our operations.

The “Simo-pad” pilot project, which was developed in our Williston office, was initially implemented to accomplish three things. First, it would create a safe working environment for our drilling, completions and facility crews. Second, it reduces cycle times from spud to sales by allowing simultaneous operations. Third, it uses GPS construction technology to develop locations that drain away from critical on-location areas (e.g., well head and tank battery) and that control water from coming onto the location and from leaving the location. Not only did this new design accomplish the goals above, it also results in less impact to the natural landscape and requires less maintenance over the life of the location. Pad containment is designed to better control stormwater runoff. We are also able to mitigate our impact of the natural water flow while also controlling the water on location by designing best management practices that meet or exceed the standards set forward by the NDIC, BLM and USFWS. Environmental factors such as vegetation, trees, wetlands, land use, drainage and topography are considered in pad placement and design in order to mitigate potential impacts to agricultural cropland, rangeland, and recreational areas.

Whiting continued voluntarily removing tanks from service to inspect and retrofit them (if necessary) with improved emissions control features. Whiting also reused some retrofitted legacy tanks at new well sites to enhance environmental performance, while also reducing waste. In 2019, Whiting re-used 374 legacy tanks, eliminating the need to purchase any tanks during this period.


WATER MANAGEMENT Whiting understands and respects water as a limited natural resource and is committed to responsible water use. We recognize that our water use affects neighboring communities, governments, businesses and industries. We remain dedicated to using water responsibly and effectively while developing energy resources.

RESPONSIBLE WATER USE Whiting strives to minimize water consumption by only using the necessary volume of freshwater to achieve our objectives and by obtaining fresh water from nearby water resources whenever feasible. Whiting seeks to:

In North Dakota, Whiting’s primary operating area, all fresh water sources utilized are verified to be appropriately permitted through the state water commission for commercial use. Whiting has mapped every fresh water source in North Dakota and Montana against our operation locations to determine the closest sources for responsible and ethical use. Whiting strives to use pipelines to transport water whenever possible to minimize trucking. Neither North Dakota or Montana are considered regions with high or extremely high baseline water stress.

• Increase water use efficiency • Evaluate water sources with less impact on the environment and communities, and • Investigate the viability of water recycling technologies


WATER USE INTENSITY Water intensity values require context with respect to the baseline production numbers, as well as the number of completions in a given year. For this reason, water intensity is tracked as a gallons of water used per million BTU’s produced (GAL/MMBTU). In years with few completions scheduled, water usage will be lower while production numbers may reflect modest growth or even modest decline. In years with more completions scheduled, water usage will appear higher while production numbers reflect higher growth. Likewise, higher baseline production numbers are less impacted by increases from new completions compared to lower baselines. The decrease in water use intensity observed in both 2018 and 2019 is a result of “Right-Sizing” our completions, which Whiting continued to refine in 2019, requiring less water per completion activity. Water Intensity for Whiting Assets in Gallons of Water Used per Million BTU’s Produced

Whiting routinely audits produced water injection facilities to ensure compliance with applicable laws and regulations. To date, 69 of the audited facilities meet or exceed our minimum standards. In addition, Whiting began using software to track produced water and ensure it goes to disposal facilities that meet or exceed our minimum standards. This project also helps minimize truck traffic by auto dispatching trucks to optimize load size and minimize the number of trips.








Whiting is committed to responsible resource development and protecting all sources of water in the areas within which we operate. Whiting’s commitment to the protection of water sources is reflected in the following two active programs.




PRODUCED WATER MANAGEMENT As is industry standard in Whiting’s operational areas, Whiting’s produced water, as well as flowback water from hydraulic fracturing operations, is typically disposed of via deep well injection. Produced water is injected into porous


geologic formations through wells that are permitted and regulated for produced water injection. We leverage Whiting-owned, as well as third-party, injection wells for our disposal needs. Injection rates and pressures are closely monitored to ensure there are not adverse effects from the injection process. In rare occasions, produced water is of a high enough quality to be discharged for beneficial use. All disposal and discharge methods must follow applicable rules and regulations.

Whiting has chosen targets each year to be in the top 25th percentile of companies with the lowest spilled volumes of produced water and hydrocarbons per the American Exploration and Production Council (AXPC) survey data. In 2018, those targets were 0.029 barrels (BBL) per 1,000 BBL of hydrocarbon produced and 0.049 BBL per 1,000 BBL of

produced water generated. For 2019, Whiting lowered those targets by more than half of the previous year’s target, to 0.010 BBL per 1,000 BBL produced for hydrocarbons and 0.023 BBL per 1,000 BBL of produced water generated. For both 2019 targets, Whiting met or exceeded these 25th percentile targets. In addition, Whiting tracks and trends spills to find patterns in the types and causes of releases. Through these evaluations, we identified patterns that allowed Whiting to implement more proactive approaches to spill prevention through improved facility design, equipment maintenance and selection, and training. Whiting Hydrocarbon and Produced Water Release Goals and Metrics HYDROCARBONS

















*Units in barrels released/1,000 barrels produced

Whiting has developed and maintains a robust Oil Spill Contingency Plan and Spill Prevention, Control and Countermeasure (SPCC) Program that provide personnel with the tools necessary to efficiently and effectively prevent releases and respond to them if they occur. Strategically located spill response trailers throughout our drilling and production areas offer quick response times to Whiting assets. Whiting also prepares for potential incidents through rigorous emergency response training and an Incident Command System.

Whiting is a founding member of the Sakakawea Area Spill Response, LLC (SASR), which is a company composed of 17 oil, gas and pipeline operators in the upper Missouri River and Lake Sakakawea region of North Dakota. SASR members have agreed to share resources by collectively purchasing and maintaining equipment to facilitate a quick and comprehensive response to an open water spill. The goal is to minimize impacts to the area and protect local residents and the environment.

2) BASELINE GROUNDWATER SAMPLING PROGRAM Whiting evaluates and monitors pre- and post-drilling groundwater quality through its Baseline Groundwater Sampling Program. Prior to the well conductor being set, available water sources (e.g., stock wells, drinking water wells and surface water features) within a half-mile radius are sampled to assess the baseline groundwater quality. Following hydraulic fracturing, additional samples are collected from the same water sources to evaluate if groundwater quality was affected by completion activities. Baseline groundwater sampling is required by law in Colorado and is regulated by the Colorado Oil and Gas Conservation Commission. In states that don’t require baseline groundwater sampling, such as North Dakota, Whiting voluntarily implements our Baseline Groundwater Sampling Program. In 2019, Whiting drilled a total of 110 wells in North Dakota and identified only one potable water source within a half-mile radius of a new oil and gas well location. That water source, along with five postdrilling water sources, were sampled as part of our voluntary baseline groundwater sampling program in North Dakota. No impacts due to drilling activities were identified. In Colorado, no new wells were drilled in 2019, and four water sources were sampled to comply with baseline groundwater monitoring regulations for wells drilled during previous years. No impacts due to drilling activities were identified.


WASTE MANAGEMENT Whiting has developed an effective waste management program to minimize our impact on the environment and to limit the risk and liability of handling and disposing waste. Our corporate Waste Management and Minimization Plan and third-party audits of disposal locations ensure that waste generated at our locations is properly stored, transported and disposed of or treated. Whiting continuously seeks new ways to improve management of waste disposal and to reduce waste generation.

WASTE MANAGEMENT AND MINIMIZATION PLAN We believe waste minimization is the key to sustainable, environmentally conscientious and responsible waste handling. Source reduction, combined with recycling, conserves our natural resources and energy, saves landfill space and reduces pollution. Reducing, reusing and recycling are essential elements of Whiting’s plan. Whiting provides employees with waste awareness training to help identify, classify and properly handle waste streams. As part of the awareness training, we actively challenge our operations teams to look for alternative products that are cleaner and safer, while seeking efficiencies that will result in less waste generated. These efforts help reduce the risk and liability associated with the handling and disposal of waste. Waste generated at Whiting facilities must be properly disposed of or treated at appropriately licensed and permitted facilities that meet Whiting standards, as identified through the Whiting’s Waste Facility Audit Program.


WASTE FACILITY AUDIT PROGRAM Whiting’s Waste Facility Audit Program ensures the thirdparty waste disposal and treatment facilities we utilize meet our standards. Since 2012, we have audited 151 Treatment, Storage and Disposal Facilities for compliance with state and federal regulations and best management practices. We audit the following standards: • Compliance with applicable state and federal permits, laws and regulations, • Implementation of Environmental, Health and Safety programs, • Possession of adequate liability insurance, • Maintenance of facility structural integrity, • Responsible operation and recordkeeping, and • Adequate overall housekeeping. These audits ensure all waste generated from our drilling, completion and operational activities is disposed of or treated responsibly.

DRILLING MANAGEMENT Whiting’s drilling operations are conducted with industry standard practices and utilize drilling fluids designed to minimize environmental impacts and optimize well control. When possible, we employ water-based drilling mud systems, and we recycle produced water rather than use fresh water. Drilling fluids from these oil and waterbased mud system operations are separated from the drill cuttings for reuse in the drilling process. Whiting is committed to responsible drilling residuals management and reduction. Every drilling rig contracted by Whiting uses a closed loop system, which eliminates

the need for open pits to store drilling residuals. Waste generated from drilling activities is disposed of or treated at facilities that are compliant with applicable laws, regulations and Whiting standards.

NATURALLY OCCURRING RADIOACTIVE MATERIAL (NORM) MANAGEMENT During oil and gas production operations, naturally occurring radioactive materials (NORM) may be brought to the surface with produced fluids where, over time, they can accumulate in surface and subsurface equipment. Whiting is committed to responsibly managing the hazards and risks associated with NORM. Our Certified Industrial Hygienist and select radiation contractors support NORM-related activities involving risk of exposure to employees and contractors. Whiting has evaluated NORM exposure risks and identified health and safety controls to reduce the potential for NORM exposure. Whiting also provides employees with NORM awareness and NORM surveyor training classes. Whiting conducts NORM assessments of its facilities. These NORM surveys are performed by trained personnel and cover active production equipment, inactive equipment and pipe slated for sale or disposal.

Whiting uses and maintains calibrated radiation detection equipment in each production office to conduct NORM surveys. When NORM is identified, Whiting ensures that workers are aware of the risk and are protected. Once the safety of our workers is verified, engineering controls and preventive maintenance are applied first and are supplemented by administrative controls as necessary. In addition, Whiting ensures environmental risks associated with NORM are minimized by safely handling, storing, transporting and disposing of or treating NORM impacted materials.

RECYCLING AND WASTE MINIMIZATION Whiting’s recycling program continues to grow on a company-wide basis. Our offices continually look for opportunities to contract with local vendors to recycle wastes such as scrap metal or reuse materials like production equipment. Whiting has also implemented universal waste recycling programs for fluorescent light bulbs, batteries and electronic waste across all our assets. Whiting personnel continually look to identify available equipment or parts for reuse. These practices combine to reduce the volume of waste we contribute to landfills.


HYDRAULIC FRACTURING AND CHEMICALS MANAGEMENT Hydraulic fracturing has become a key element of oil and natural gas development within the United States. Today, it is part of the process of drilling and completing most onshore oil and natural gas wells. This well-stimulation method is a process that has been used since the 1940’s to coax oil and gas out of tight shale formations more than a mile underground. Currently, more than 90% of all crude oil and natural gas wells drilled in the U.S. employ hydraulic fracturing. Although the injection process for each well typically lasts only two to three days, the well may produce for 20 years or more. Hydraulic fracturing involves pumping a mixture of mostly water and sand, and a small amount of additives, under high pressure into the reservoir to create fractures, or cracks, in the rock formation. This increases the production rate and ultimate recovery of oil and natural gas from a well. In combination with horizontal drilling, hydraulic fracturing makes it possible to develop shale plays that were previously uneconomic. In keeping with our commitment to environmental stewardship, we take steps to minimize the potential impacts from hydraulic fracturing by ensuring well integrity, conserving water, reducing air emissions from flaring and other sources, and managing waste responsibly. Whiting believes trust and transparency is essential to the continued progress of energy development. In furtherance of this belief, Whiting is dedicated to disclosing the chemicals used in our completion fluids. We provide a Hydraulic Fracturing Fluid Product Component Information Disclosure Report for each of our wells. Nearly 1,900 of


these reports may be found on the FracFocus website. In addition to the operator and the fluid content, each report identifies the API number, job start and end dates, state, county and well name.

LAND IMPACT AND REMEDIATION Whiting is committed to sustainable land use in our operations. We engage with governmental agencies and landowners early to formulate development plans that minimize impacts to the land and sensitive environmental areas. Where possible, Whiting implements development through multi-well pads, which allows for significantly reduced surface disturbances and environmental impact. At the end of the completion phase, the well pad is generally reduced in size as the space allocated for temporary drilling and completions equipment is removed. Thereafter, the area is ecologically and aesthetically reclaimed. After the producing life of a well pad ends and the existing well(s) on a pad are plugged, processing equipment is removed (recycled, reused or properly disposed of in accordance with our waste minimization practices), and the site is reclaimed to its original condition, including reestablishment of native vegetation. Reclamation activities in the upstream oil and gas industry address and eliminate or minimize the impacts caused by the following: • Wells • Surface Facilities • Access Roads • Flowlines • Gathering pipeline Well plugging and facility reclamation is regulated by state and federal agencies, as applicable.

TOPSOIL SALVAGE AND RECLAMATION PLANS In 2019, prior to any earth work activities being conducted to build pads in Colorado, topsoil salvage and reclamation plans were prepared in conjunction with soil samples collected by a soil scientist. The data collected includes: • Detailed description of soils at various depths • Topsoil depths throughout the planned pad location • Laboratory analysis of agronomic soil properties • Inspection for presence of undesirable weedy species • Photographs of site prior to soil disturbance The resulting data was utilized to develop the reclamation plan that includes: • Summary of the chemical and physical soil properties to identify barriers to reclamation success • Recommended seed mix based upon existing vegetation and soil properties • Recommended soil amendments (e.g., nitrogen, phosphorus, etc.) and application rates during reclamation • Depth of viable topsoil throughout pad to properly salvage and preserve for interim and final reclamation. Using this information, Whiting will be able to implement a successful topsoil salvage and reclamation program to reduce our footprint and positively impact the environment.


BIODIVERSITY Whiting understands that being a responsible operator includes taking proactive steps to protect biodiversity. Whiting has developed an informational program consisting of brochures that communicate the importance of awareness of the flora and fauna in the areas in which we operate and their inter-relationship with the natural world and the web of life. Informational brochures, complete with identification pictures, are distributed annually to personnel, contractors and field offices to help workers at Whiting locations identify threatened or endangered species. This guidance on how to avoid sensitive areas is vital to ensuring minimal disturbance to the wildlife around our operations. Links to Colorado Wildlife, North Dakota Wildlife and North Dakota Wetlands brochures can be found below. Colorado Wildlife Brochure The Colorado Endangered & Threatened Species Protection Guide identifies both state specific listed and federally listed species. The brochure details how to avoid species conflicts and offers suggestions to Whiting employees, contractors and the public on what they can do to protect the wildlife and environment in which we operate and live. Species of interest in areas where Whiting operations are present includes the Plains Sharp-Tailed Grouse, Piping Plover and the BlackFooted Ferret North Dakota Wildlife Brochure The North Dakota Endangered & Threatened Species Protection Guide identifies federally listed species which, by default, are incorporated for protection by the State of North Dakota under North Dakota law; North Dakota does not have a separate, state-specific listing of threatened and endangered species. The brochure details how to avoid species conflicts and offers suggestions to Whiting employees, contractors and the public on what they can do to protect the wildlife and environment in which we operate and live. Species of interest in areas where Whiting operations are present includes the Dakota Skipper, Sprague’s Pipit and the Western Prairie Fringed Orchid.


North Dakota Wetlands Brochure Whiting’s Guide to the North Dakota Wetlands presents an overview of the unique Prairie Pothole region of North Dakota. The guide identifies the type of wetlands that can be found in North Dakota and indicators of wetlands based on soil types, hydrology and indicator plants that have evolved to withstand extended periods of saturated conditions and occasional dry conditions. This guide further explains why wetlands are important in providing habitat to unique wildlife habitat, flood control, groundwater recharge and recreational opportunities.

BIODIVERSITY PROGRAMS Whiting pursues activities to benefit biodiversity conservation beyond required mitigation measures. In 2019, Whiting once again supported programs of the Bird Conservancy of the Rockies with volunteers and a monetary donation. In addition to the funding for a wildlife biologist and an integrated population mode for the Baird’s sparrow, we also funded their Growing Scientists Program. Our financial support allowed the Bird Conservancy to work with third grade classrooms at schools throughout the Denver Metro area through the Growing Scientists program. This unique collaborative allows them to provide a forum that creates enthusiastic learners of STEM education through the natural world now and in the future. This program provides professional development support for educators and students, as well as provides opportunities for families to engage in STEM learning programs both in and out of the classroom in assessable ways. The Growing Scientists Program provides early exposure to STEM concepts that can significantly affect a child’s development and future interest in STEM. Through real world experiences and powerful science learning for students, teachers and their families, the program builds a community of learners.




SERIOUS INJURIES Zero serious injury or fatal incidents among Whiting employees over last 3 years

SOCIAL TRIR EMPLOYEES & CONTRACTORS Decreased full year TRIR by 1%, with second half 2019 improving 18%, compared to full year 2018

DIVERSITY 29 of 63 employees (46%) hired at Whiting’s Corporate Office in 2019 were female or minority

At Whiting, protecting the health and safety of our employees, contractors and communities is paramount in sustaining a culture that values caring for others, quality of work, productivity and company pride. Our health and safety programs are designed to guide employees in the recognition of hazards and the assessment of those risks inherent to our industry. Through health and safety training, we prepare our employees to use industry best practices and standards to mitigate risk in a manner that protects themselves, co-workers, the public and property.

HEALTH AND SAFETY MANAGEMENT SYSTEM Whiting’s Health and Safety Management System includes programs that address:

COMMUNITY INVESTMENT Invested more than $1,000,000 and 4,000 volunteer hours in our local communities


• Risk assessment, hazard recognition and mitigation • Emergency response preparedness • Incident investigation practices designed to identify cause • Control of hazardous energies • Fire risk and protective measures

• Selection and use of personal protective equipment • Electrical safety • Working in confined space and communication of hazards • Recurring hands-on and classroom training focused on safety to ensure proficiency

• Comprehensive health and safety audits to assess the effectiveness of Whiting’s Health and Safety Management Systems and compliance with applicable agency regulations and industry consensus standards • Contractor safety management

EMPLOYEE AND CONTRACTOR SAFETY METRICS Safety is the foundation value within Whiting’s core values. We believe safe operations is a prerequisite to sustainable business success. Whiting has taken material steps to advance the Company’s safety culture. Some of the steps in 2019 included: quarterly safety summits, life-saving rules, contractor onboarding and safety stand-downs. Full-year

2019 TRIR and DART results were similar to 2018. As new safety processes took root in 2019, Whiting saw marked improvement in employee and contractor metrics. Second half 2019 combined TRIR and DART decreased 18% and 45%, respectively, compared to full year 2018.

Performance Summary WHITING






























2019 (Jan – June)







2019 (Jul – Dec)







TRIR: Total Recordable Incident Rate. DART: Days Away, Restricted, and/or Transferred rate.


Whiting established Quarterly Safety Summits to bring together Whiting leadership, employees and contract partners in an environment where it is safe to showcase both successes and learning opportunities. The Quarterly Safety Summits have resulted in deeper bonding, greater understanding of each other’s safety culture and processes, and more collaborative ways to address the industry’s most common safety challenges. Additionally, we expanded Safety Summits to cover supply chain issues and develop trainings that educate vendors on Whiting’s newly implemented supply chain policies.

CONTRACTOR SAFETY MANAGEMENT Whiting has established a robust and proactive contractor safety management program. Elements of this program include but are not limited to: • Safety Stand Down meetings with Whiting representatives. • RigUp On Demand Network and Services Marketplace to assist with the vetting and management of sole proprietor and low-risk, low spend contract partners. • Stressing to contractors Whiting’s dedication to their right to invoke Stop Work Authority without fear of retribution. • Clear communication of Whiting’s Key Expectations and Responsibilities for Contractors and Subcontractors.

• Field level Contractor Safety Reviews and site inspections by operations and health and safety personnel. • Continued partnership with ISNetworld, an online contractor and supplier management platform that evaluates contractor safety performance, health and safety programs and regulatory requirements. • In 2019, Whiting screened over 800 vendors for safety criteria. • Streamlined Contractor Safety and One-call orientation program.

In 2019, Whiting formally integrated safety performance as a key component in vendor selection for services on oil and gas development locations. All formal solicitations for services on oil and gas development locations included safety in the criteria for award. Whiting also required all approved vendors to acknowledge our health and safety requirements and drug and alcohol policy. 28


Rollout of Life Saving Rules in each office and operational area for all employees and contractors.

Emergency response training and drills in all major field offices.

Formation of Quarterly Safety Summits led by Whiting executive leadership. Contractors are invited to the quarterly meetings.

Partner surveys to assess awareness on Whiting’s safety culture and adjust communication accordingly to increase understanding.

Creation of weekly executive-level reviews for Whiting and contractor incidents. Contractor involvement (when applicable) ensures open and honest reporting and reinforces Whiting’s expectation of and dedication to our core value of Safety Always.


In 2019, Whiting leadership expanded Whiting’s Life Saving Rules (LSRs), which are based on the International Association of Oil and Gas Producers’ consensus safety standards, to all employees and contractors. These LSRs have been integrated into the Health and Safety Management System to establish support for employees and contractors, to promote standardization and accountability with the goal of continuous improvement and to provide opportunities of shared learning.


LIFE-SAVING RULES LIFE-SAVING RULES Bypassing Safety Controls Confined Space Bypassing Safety Controls Confined Space

Obtain authorization Obtain authorization Obtain authorization Obtain authorization before overriding or before entering a before overriding or safety before entering disabling confineda space controls disabling safety confined •space I confirm energy controls • I understand and use safety-critical• I confirm energy sources are isolated. and procedures which • I understandequipment and use safety-critical apply to my task. equipment and procedures which I obtain authorization before: apply to my• task. – Disabling or overriding safety • I obtain authorization before: equipment – Disabling or overriding safety equipment– Deviating from procedures – Crossing a barrier – Deviating from procedures – Crossing a barrier

• • • • •

Energy Isolation zero energy before Verify isolation workand begins

Control flammables Hot Work

and ignition sources


zero energy before • I have identified all work begins energy sources. 0

• I confirm • I have identified all that hazardous energy sources have been isolated, energy sources. and tagged. • I confirm thatlocked, hazardous energy • I have sources have beenchecked isolated,there is zero energy and tested for residual locked, and tagged. or stored energy. • I have checked there is zero energy and tested for residual or stored energy.

Safe Mechanical Lifting Plan lifting

Safe Mechanical operationsLifting and

control the area Plan lifting I confirm that the lifting operations •and equipment and load control the area have been inspected and

Control flammables • I identify and control and ignition sources ignition sources.

• I identify•and control Before starting any hot work: ignition sources. – I confirm flammable material hasany been • Before starting hotremoved work: or isolated. I obtain authorization. – I confirm– flammable material • Before starting hot work in a has been removed or isolated. area, I confirm: – I obtain hazardous authorization. – A gas has completed. • Before starting hottest work in been a Gas will be monitored hazardous–area, I confirm: continually. – A gas test has been completed. – Gas will be monitored continually.

Work Authorization Work with a valid

Work Authori zation permit when

required Work with a valid • I have confirmed if permit when a permit is required. required

for purpose. • I confirm thatare thefitlifting • equipment•and load I only operate equipment that I am qualified to use. have been inspected and • • I establish and obey barriers and are fit for purpose. exclusion zones. • I only operate equipment that I am • I never walk under a suspended qualified to•use. • load. • I establish and obey barriers and

exclusion zones. • I never walk under a suspended load.

Follow safe driving Follow rules safe driving rules • I always wear a

• I alwaysseatbelt. wear a • I do not exceed the speed seatbelt. andthe reduce my speed for I confirm the atmosphere has been • I do not limit, sources •are isolated. exceed speed tested and is monitored. road conditions. limit, and reduce my speed for I confirm the atmosphere has been • I is check and use my breathing • I do not text or email while driving. tested and monitored. road conditions. apparatus when required. • Itext am or fit, email restedwhile and fully alert while I check and use my breathing • I do not driving. • Iwhen confirm there is an attendant driving apparatus required. • I am fit, rested and fully alert while standing by. I confirm there is an attendant driving•. I will conduct a 360 degree walk• I confirm a rescue plan is in place. around before departing. standing by. • I will conduct a 360 degree walk• I obtain authorization to enter. I confirm a rescue plan is in place. around before departing. I obtain authorization to enter.

Hot Work

Verify isolation and Energy Isolation

Driving Driving

• I am authorized to perform I have confirmed if the work. a permit•isI required. understand the permit. I am authorized perform that hazards are • I have to confirmed the work. controlled and it is safe to start. • I stop reassess if conditions I understand theand permit. change.that hazards are I have confirmed

controlled and it is safe to start. • I stop and reassess if conditions change.

Line of Fire

Line ofKeep Fireyourself and others out of the Keep yourself and line of fire others out of the • I position myself to line of fire avoid:

– myself Movingto objects; • I position avoid: – Vehicles; – Pressure – Moving objects; releases; – Dropped objects – Vehicles; • I establish and obey barriers and – Pressure releases; exclusion – Dropped objectszones. • I take action to secure loose objects • I establish and obey barriers and and report potential dropped exclusion zones. objects. • I take action to secure loose objects and report potential dropped objects. Working at Height

Protect yourself

Working at Height against a fall when

working at height Protect yourself my fall against• aI inspect fall when protection equipment before use. working at height

• I secure tools and work materials to • I inspectprevent my falldropped objects. protection before use.anchor • I tieequipment off 100% to approved whilework outside a protected • I securepoints tools and materials to prevent area. dropped objects. • I tie off 100% to approved anchor points while outside a protected area.


COMMUNITY SAFETY ENGAGEMENT Whiting and its employees are involved in many activities that promote public awareness and safety within their local communities. Our employees volunteer at their local fire departments and rescue services. Additionally, Whiting employees take part in several community outreach and agency sponsored “Community Right to Know” programs. Examples include: • Annual Superfund Amendments and Reauthorization Act (SARA) Reporting. • Volunteering at local fire departments: • Fire Departments where Whiting employees volunteer include the Stanley Fire Department, Watford City Fire Department, Culbertson Fire Department, South Heart Fire Department, Dickinson Fire Department, Wiggins Rural Fire Protection District and Ryder Makoti Fire Department. • Annual State Emergency Response Commissions (SERC) training for SARA Title III Tier Two Reports. • Participation in quarterly Local Emergency Planning Committees (LEPC) Meetings.

• Invitations to LEPCs and Emergency Responders to participate in our Incident Command System drills. • Subject matter expert presentations to public forums and safety conferences. • Facility tours for the public and state university students.

COMMUNICATION OF SAFETY DATA SHEETS We communicate our health and safety performance expectations with our employees, contractors and the public to ensure that our decision-making process incorporates significant safety topics. An important aspect of this communications process is easy access to Safety Data Sheets for Whiting Products. These Safety Data Sheets provide workers the necessary information to identify the hazards of the product, how to safety handle and work with the product and what to do in the event of an emergency involving the product. Safety Data Sheets can be downloaded at whiting.com/ sustainability/health-safety.

Organizations and activities Whiting employees are actively involved with to promote oil and gas awareness include: SASR (Lake Sakakawea Area Spill Response, North Dakota (ND) Neutral Grounds Safety Consortium Bakken Basin Consortium Department of Emergency Services’


Hazardous Materials Conference North Dakota Industrial Commission Colorado Oil and Gas Commission Weld County, CO. LEPC Bureau of Land Management

US Forest Service North Dakota Petroleum Council

National and Regional STEPS Network

811 Call Before You Dig

National Institute of Occupational Safety and Health

North Dakota State Fire Conference

Occupational Safety and Health Administration

North Dakota Safety Council Conference and Expo

EMERGENCY RESPONSE PREPAREDNESS Whiting’s environmental, health and safety practices, design standards and preventative maintenance programs are developed to prevent events that may cause harm to the public, the environment and our employees. Although prevention is key, Whiting recognizes that emergency situations may occur and that we must be prepared to respond safely, quickly and effectively. Our response objectives demonstrate Whiting’s ability to: • Exercise “command and control” of the response; • Minimize impact to people, property and the environment; and • Achieve continuous improvement of our response capabilities through after-action reviews.

Whiting’s Emergency Response Plan has an established Incident Command Structure (ICS), based on Homeland Security’s National Incident Management System. It provides guidance for our employees to respond during an emergency event. To ensure emergency preparedness, Whiting employees receive annual ICS roles and responsibilities training and participate in regional ICS drills to evaluate the overall effectiveness of our response capabilities. For drills and actual events, Whiting uses specialized software to manage documents and evaluate our response. In 2019, a flood event required the stand-up of an ICS Team.

In March 2019, a historic river crest caused by localized spring ice jams resulted in flooding along the Yellowstone River near Fairview, North Dakota. High waters impacted numerous private residences, agriculture land and Whiting production facilities. Whiting proactively identified the risk to facilities and personnel and activated the Incident Command System. Area management and support personnel coordinated the stand up of an Incident Command Team and established an Incident Command Post in the Watford City, ND production office. Critical intelligence was soon gained, objectives established and a Incident Action Plan was formalized to support a safe mission for on-scene operations. Preemptive efforts, such as shutting down artificial lift and filling tanks to minimize float potential, protected Whiting assets and proved successful as an overnight water surge completely cut off road and well access isolating seven of Whiting’s production facilities. Whiting’s ICS application proved successful and numerous lessons learned were gained from an After Action Review (AAR) following the waters recession.


DIVERSITY AND INCLUSION At Whiting, we believe our people are our greatest asset. We recognize the advantages of a company culture that embraces diversity, constructive debate, differing viewpoints, continuous learning, servant leadership and an engaged workforce. We encourage open and transparent communication among our teams and strive to set the highest ethical standards. Our commitment to diversity and inclusion goes beyond our compliance with all applicable equal employment opportunity laws. At Whiting, we do not allow unlawful discrimination or unlawful harassment against applicants or employees. We recruit, hire, promote and perform personnel actions without regard to race, color, religion, sex, national origin, age, disability, genetic information, or any other applicable status protected by federal, state or local law. We also comply with all applicable federal, state and local laws. We make reasonable accommodations for qualified individuals with known disabilities and employees whose work requirements interfere with a religious belief, unless doing so would result in an undue hardship to Whiting or a direct threat. Employees needing such accommodation are instructed to work with Human Resources. We seek to handle every employee concern, of any nature, with appropriate respect. If an employee has a work-related problem or concern, they are encouraged to following these resolution steps: • Discuss the issue with their supervisor in a timely manner, usually within three to five working days. This allows both time for reflection upon the issue, while also beginning the process of addressing any issues rapidly.


• If a resolution is not reached with the supervisor or if the issue is with the supervisor, discuss the situation with their department manager in a timely manner, usually within five to seven working days. • If the problem is not resolved to an employee’s satisfaction at that level, they are encouraged to communicate the problem directly to the Human Resource Department, the V.P. of their department and/ or another member of senior management. • Should further resolution be required, the CEO will make the final determination. Any employee who witnesses violations of our guidelines is instructed to report the incident to Whiting’s Ethics Hotline, the Human Resources department or General Counsel. Whiting will investigate all reports and take corrective action as necessary. Whiting has an Ethics Hotline for the purpose of allowing all employees an avenue for confidential, anonymous submission of concerns. If for any reason an employee is uncomfortable using the direct face to face procedures outlined above, this hotline provides a method of reporting concerns through a confidential and anonymous third-party system. The Ethics Hotline may be accessed by calling 1-866-691-1972. Retaliation against any individual who makes a report or participates in an investigation is prohibited. Any employee who feels he or she has been retaliated against for making a report or participating in an investigation is encouraged to immediately notify Whiting’s Human Resources department or General Counsel. Whiting will investigate all reports and take corrective action.

EMPLOYEE DIVERSITY Whiting’s leadership team is mindful of ways to increase the diversity of our workforce. At the end of 2019, Whiting had 504 employees across our operating areas. We strive to maintain a workforce that is diverse in age, and our corporate office in Denver remains in line with industry trends for gender representation. In fact, 29 of 63 employees (46%) hired at Whiting’s Corporate Office in 2019 were female or minority. Cultivating internal talent is a priority for Whiting. We further the diversity cause by making an effort to ensure that the diverse talent pool we have hired can see a long and successful career path ahead of them within Whiting. If a current employee is interested in a different position within the company, we encourage them to contact their supervisor and submit a request to Human Resources. Whiting reserves the right to hire anyone for any position, including internal or external candidates. Candidates identified both internally and externally are assessed based on performance, relevant business knowledge, job fit and skillset.

Individual Contributor Corporate

Count of workforce

% of workforce













Field Female








Manager Corporate


















Females in Corporate Office



Grand Total



Percentage of employees in major age brackets: 30 Yrs or Less













EMPLOYEE BENEFITS AND POLICY In 2019, Whiting took several steps towards extending trust to employees to self-manage their workdays and to independently adjust personal practices based on their particular needs and individual situations. This effort spanned from smaller but extremely well-received gestures (like the replacing of a formal dress code with a flexibility in dress policy) to more significant flexible work-life policy. We allow for flexible work hours around a core mid-day work block. This is of value to many individual employee situations, most especially to parents of young children who have a greater flexibility around the drop off and pick up of children from childcare and school. Whiting allows for any employee to request that their manager consider approving a part time schedule for the employee. This again could be of value to many individual employee situations, most especially to employees with dependent care commitments that span several hours of the day. Where an employee would historically have felt pressure to choose between caring for a dependent or furthering their career, they can now accomplish both simultaneously. Whiting allows for employee paid and unpaid leaves for a number of situations: • In accordance with the Family and Medical Leave Act of 1993, Whiting provides unpaid, job-protected leave to eligible employees, for childbirth and related care, for adoption or foster care, for dependent care through a serious health condition, self-care due to a serious health condition, and military obligations. • We also offer paid vacation leave based on longevity of service. Vacation leave is accrued up to each employee’s maximum number of hours allowed, and that same amount may be carried over from one calendar year to the next. Each employee is trusted to manage, report, and track their vacation leave. Employees are encouraged to use vacation every year to refresh and recharge themselves. • Whiting offers paid sick leave, which is accrued at one day of sick leave for every month worked at Whiting, up to a maximum accrued total of 480 hours. • Many other unique leave situations are also honored and facilitated by Whiting, including paid jury duty leave, voting leave, holiday time off, military leave, and domestic abuse leave.




Whiting is committed to the personal and professional development of its employees, with the belief that a greater level of knowledge, skill and ability is of personal benefit to the employee and fosters a more creative, innovative, efficient and therefore competitive company. Through a comprehensive approach, we empower our employees to develop the skills they need to perform their current jobs while developing acumen for future opportunities. In 2019, we offered our employees a generous tuition reimbursement program and abundant job-relevant training and seminar opportunities.

Effective Communication is a core value at Whiting. Sharing information with our employees and seeking feedback about our business, culture and opportunities for improvement drives growth. In 2019, we utilized performance reviews, surveys, town halls and small group meetings with the CEO to directly engage with our employees. We also utilize the company intranet and safety meetings in the field to share information and connect with employees in a timely and meaningful manner.

In 2019, Whiting continued our companywide customtailored leadership training program, WLL Lead. The goal of WLL Lead is to foster more effective leadership throughout the organization, which drives increased employee retention and engagement. Employees in the program have access to both classroom training, on the job exercises and an executive coach. Our goal in 2019 was to offer every leader of people in the company the opportunity to participate in the WLL Lead program. We continue to see an immediate difference in leadership within our teams, which translates into a positive impact on business dynamics. We also made available a broad set of development opportunities for all employees via the Learning Management System in 2019. Content covers an array of topics from technical training to soft skills. Furthermore, our managers have utilized the tool in personnel development situations to increase employee engagement and productivity.

In 2019, Whiting launched employee focus groups, spanning every level of employee and covering most locations within the company. Employees were given the opportunity to describe exactly what programs and policies keep them retained and what programs help them engage. From this effort, we identified four main areas that drive our employee retention and engagement – two-way communication, competitive compensation, the extension of trust by offering flexibility and access to development opportunity. Throughout the year, we took action on many of the fronts identified by employees, with an effort to balance the cost of programs that address employee feedback with the impressive benefits reaped by reacting to employee input. Examples of action taken include the introduction of more flexibility in work schedules, introduction of new competitive rewards policies, a concerted effort to increase and improve communication and a redesign of the employee performance appraisal process and its tie to incentives. Whiting will continue to survey its employees in an effort to seek outstanding engagement. We understand that employee engagement can change rapidly in reaction to both our internal and external environments at a given time, and that we must be vigilant and dynamic in our approach.


LOCAL INVESTMENT Whiting makes every effort to competitively bid high-volume and frequently purchased goods and services while consolidating awarded goods and services over a period (e.g., quarterly, semi-annually). This practice helps support small, local suppliers and contractors by providing scheduling and financial certainty. These commitments can also help local suppliers with employee retention and business planning. Whiting hires locally from reputable small businesses, with employees who live in the communities near our operations. In 2019, we began collecting vendor demographic information to help quantify the impact we have on the communities in which we operate. All statistics are self-reported by the vendors when registering with Whiting • COMMUNITY ENGAGEMENT AND SUPPORT: 85% of the vendors we work with have primary offices or are headquartered in the states in which we operate. • COMMUNITY ECONOMIC AND JOB GROWTH: 39% of our vendors were established in the last 10 years. • SUPPORT OF DIVERSE BUSINESSES: 44% of our vendors self-identified as a diverse business.

• SMALL BUSINESS SUPPORT IN THE COMMUNITIES IN WHICH WE OPERATE: • 61% of our vendors have less than 50 employees. • 73% of our vendors reported as having less than 100 employees. • 68% of our vendors have less than $10 Million in revenue per year.

This local engagement has helped Whiting maintain strong relationships with our employees, suppliers and communities that have become an essential part of why and how we do business.


COMMUNITY STEWARDSHIP At Whiting, community engagement is integral to our identity as a company and individuals. Employees selected Meaningful Stewardship as a core value because the way we interact with our communities is what sets Whiting apart. We want to enhance the quality of life in our communities, making each one a healthy, safe and eminently livable place. Our community commitments are a direct reflection of our culture, driven by the needs of our employees and with a focus in these key areas: • EDUCATION AND WORKFORCE DEVELOPMENT. At Whiting, we believe that investments in education and the development of a sustainable workforce is critical to the continued success of the energy industry. We are proud to support education and realize that education comes in many forms - from providing the tools needed for early education to distributing scholarships for students through institutions that boast successful science, technology, engineering and mathematics business programs. We also endeavor to support organizations that provide work and life skills training as well as continuing professional or industry education. • ENVIRONMENTAL, HEALTH AND SAFETY. Our goal is to produce oil and gas responsibly, reduce our impact on the environment, conserve natural resources and respond when necessary to keep

our employees and communities healthy and safe. From trail restoration and supporting our first responders, to building a maternity wing at the county hospital, we look for partners and projects that uplift the communities where we work and live. • COMMUNITY WELLNESS. Whiting believes that improving our community’s overall wellness advances individual and community prosperity. We fund organizations that provide access to affordable health care and support, affordable food and housing, as well as programs that guide individuals and families to achieving economic opportunity and self-sufficiency.

OUR APPROACH Throughout the year we assess the effectiveness of our social investment approach. This process allows us to collaborate, identify best practices and align our social investment with the areas of greatest community need. We accomplish this by: • Seeking out community partners. • Communicating openly and including our partners in the design and implementation of the engagement process. • Seeking solutions that create mutually beneficial business and engagement approaches and build long-term value for both the company and our community partners. • Following through on our commitments.


EDUCATION & WORKFORCE DEVELOPMENT: A PRECIOUS CHILD Whiting has partnered with A Precious Child (APC), who assists children and families facing difficult life challenges such as abuse and neglect, crisis situations and poverty. APC works with more than 440 agency partners throughout the following eight Denver Metro counties: Adams, Arapahoe, Boulder, Broomfield, Denver, Douglas, Jefferson and Weld. APC and its agency partners identify children and families in the most need of services and provide to them basic human needs and assistance navigating community resources. Whiting supports APC annually through both volunteer time and participating in its corporate “Fill A Backpack” challenge. In 2019, Whiting employees volunteered more than 100 hours, collected 345 school supplies and 142 stuffed backpacks for APC, as well as donated $24,523 in corporate, individual and matched donations.

ENVIRONMENTAL, HEALTH & SAFETY: MCKENZIE COUNTY HEALTHCARE SYSTEM Whiting began working with the McKenzie County Healthcare System in 2017 to bring obstetrics services back into the community. We discovered that obstetrics services haven’t been provided in McKenzie County for more than 30 years. While more than 200 babies were born to Watford City families in recent years, none were delivered there. Instead, families were commuting to other towns to deliver their babies, either by ambulance or by driving themselves. Babies were often being delivered in homes or even on the side of the road because they couldn’t make it in time. We knew we wanted to improve the safety and wellbeing of the mothers and children in this community by bringing back this resource. In 2018, Whiting made an initial gift of $50,000 to underwrite the cost of one Labor and Delivery Wing at the McKenzie County Health Care Center. The gift allowed local mothers to receive all pre-labor care there immediately. In 2019, we continued our investment and donated an additional $200,000 to the Labor and Delivery Wing to purchase equipment and hire personnel.

COMMUNITY WELLNESS: HABITAT FOR HUMANITY Habitat for Humanity helps individuals and families achieve strength, stability and selfreliance through affordable homeownership. Between the Denver Metro and Greeley-Weld County chapters of Habitat for Humanity, Whiting employees donated a combined 264 hours of volunteer time to work on home construction sites. In Greeley, our employees volunteered with students from Jefferson High School as part of their Construction Pathway Program. This program is an innovative, two-year workforce readiness and mentor program for at-risk youth. During lunch, they were able to talk with the students about different career paths and how to find job opportunities within the oil and gas industry.


PHILANTHROPY AND VOLUNTEERING At Whiting, we strive to strategically invest in the communities where we live and work. We know our employees and their gifts make communities stronger. Whiting’s community investments support education, health and safety, natural resources, social services and disaster relief. In 2019, Whiting invested more than $1,000,000 in our local communities. More than 500 Whiting employees volunteered 4,100 hours in local communities within our operating areas. We encourage and recognize employee volunteerism in several ways: 1. Each employee receives 16 hours of paid time annually to volunteer during business hours at the non-profit of their choice, either at events hosted by their office or by the partner organization. 2. Community relations representatives work to create volunteer opportunities for employees or connect them with volunteer opportunities hosted by Whiting’s community partners. 3. Employees leverage our internal communications platform to find volunteer opportunities, sign up to volunteer and share local opportunities by posting event details. Beyond volunteering for accredited non-profits, Whiting employees are also encouraged to support their local communities through involvement in their municipalities, school systems and sports programs.

WHITING CORPORATE GIVING Whiting considers grant proposals from non-profit organizations within the communities we operate that focus on: Guidelines • The applicant is a 501 (C)(3) charitable organization or political subdivision. • The proposal seeks funds for an area where Whiting Petroleum Corporation has a strong business presence including facilities, assets or employees. • The request is not for an individual, religious organization or an endowment. • A breakdown of relevant costs for the funding request is included. To request a donation please visit our website or email donations@whiting.com to request the current application link.





The highest level of Sustainability oversight resides with Whiting’s Board of Directors. Whiting’s Board of Directors has an Audit Committee, a Nominating and Governance Committee and a Compensation and Human Resources Committee. In 2019, a formal ESG Committee was established. The ESG Committee assists the Board in fulfilling its oversight responsibilities relating to the Company’s programs, policies and practices pertaining to environmental, safety, sustainability and social responsibility issues and impacts.

The oil and gas industry is subject to a complex regulatory framework, and Whiting has developed systems and programs to ensure compliance with all regulations. Our Regulatory Group provides guidance, training, oversight, enforcement and reporting.

Committee charters and a list of our current Board members can be found on our website. For more on our Corporate Governance Principles, please visit: whiting.com/corporategovernance/governance-principles.

For additional discussion on these regulations and Whiting’s approach to compliance, please review our 2019 Form 10-K filing.

ETHICS, ANTI-CORRUPTION AND ANTI-BRIBERY In Whiting’s Code of Business Conduct and Ethics manual, we describe the business conduct and behaviors we expect of our employees, officers, directors and contractors. Any

POLITICAL CONTRIBUTIONS Whiting participates in the political and public policy process in a responsible and ethical way that serves the best interests of our shareholders and the safety and wellbeing of our workforce and other stakeholders. In 2019, employees could support candidates for office through Whiting’s Political Action Committee, which was funded exclusively through voluntary contributions from eligible employees. The Whiting PAC contributes to federal and state political candidates who support responsible oil and natural gas activities and other business issues of interest to the company. Whiting is committed to complying with all applicable state and federal rules pertaining to lobbying and disclosures. Relevant reports regarding our activities are publicly available via the appropriate state and federal websites and the various state ethics commissions. Whiting does not have international operations. Therefore, it is not actively engaged with foreign governments or officials.


individual or company working on behalf of Whiting or our subsidiaries is expected to follow similar principles. Failure to comply with the Code of Business Conduct and Ethics and related policies, or applicable laws, will result in disciplinary action, up to and including termination. Our annual review and acknowledgement of the Code reinforces that all employees have a responsibility to report any suspected misconduct, unethical behavior or illegal activity. To facilitate this reporting, we maintain an ethics hotline. This 24-hour resource is externally hosted and managed by a third party so employees and external stakeholders may anonymously report any alleged violations. All communications to the Ethics Hotline are tracked and investigated by an internal team including relevant personnel from Human Resources, Accounting, Legal and other departments. Ethics Hotline Number: 1-866-691-1972 All employees and directors of Whiting must act with honesty and integrity in all matters. Day-to-day observance of this Code creates an attractive, healthy working environment for all employees that is consistent with Whiting’s core values and further builds on positive relationships with customers, suppliers and the public at large. To learn more about our Corporate Code of Conduct, please visit: http://whiting.com/corporate-governance/code-ofconduct

EXECUTIVE REMUNERATION The Nominating and Governance Committee of the Board of Directors periodically reviews and reports to the Board at large with respect to executive compensation and benefits. The Compensation and Human Resources Committee reviews and approves the philosophy, goals and objectives relative

to the CEO’s compensation, determines and approves the compensation of the other executive officers, and administers our incentive compensation plans. The primary objectives of our program are to facilitate pay for performance, encourage creation of long-term stockholder value and compensate our employees competitively. The Compensation and Human Resources Committee periodically evaluates market-best practices in executive compensation programs to ensure it continues to provide balanced incentives, while managing compensation risks appropriately in the context of our business objectives. Whiting’s environmental, health and safety (EH&S) performance is a key indicator of company performance. Understanding this, Whiting has tied a portion of executive compensation to EH&S performance metrics.

RISK IDENTIFICATION AND MANAGEMENT PROCESSES A critical component of a sustainable business is its ability to identify and manage risk. We apply a number of key processes in our company that help to identify and mitigate risks in potential, new and existing operations. Our Board of Directors reviews and evaluates existing risk assessment processes, management’s assessment of major risks, and risk mitigation options. These assessments, and the periodic review thereof, help Whiting achieve operational excellence, properly evaluate investment opportunities, and plan intelligently for future growth. While these processes are focused on our operated assets, we also review potential risks in Whiting’s non-operated assets. For an in-depth discussion of Whiting’s approach to risk identification and management, please review our most recent Form 10-K filing here.


ENTERPRISE RISK MANAGEMENT In 2019, Whiting established the Interdisciplinary Review (IDR) process to guide the development of company practices and standards. The IDR process created a system of “checks and balances” to ensure proposed risk mitigation strategies are appropriate for the size and objectives of the various departments as well as the overall company. IDR principles were applied to the development of multiple risk management practices that are used to guide Whiting’s risk assessment and mitigation processes. Whiting adopted the Structured What-If Technique (SWIFT) as a preferred methodology to assess the risk of individual sets of equipment and/or processes. In addition to the SWIFT, Whiting will utilize a Hazard and Operability Study as a systemic risk assessment approach for more complex systems, such as entire facility design.

ASSET INTEGRITY MANAGEMENT As part of ongoing efforts to improve operational and process safety, we initiated the Asset Integrity Management (AIM) program in 2019. AIM focuses on enhancing the safety and reliability of our production infrastructure throughout its lifecycle. Through the AIM program, we have developed multiple processes to evaluate and reduce the process risk in facility design, construction, operation, maintenance and equipment decommissioning. As part of AIM, we implemented the Risk Management Practice, which provides guidance for process risk assessment and appropriate mitigation strategies. Also, the AIM program adopted a Fault-Tree Analysis (FTA) as the preferred investigation method for high-risk incidents. FTA allows Whiting to identify process upsets and root causes and develop remediation actions. To further enhance our risk-based thinking and decision making, we have developed and launched implementation of the Management of Change (MOC) Practice. The MOC program’s objective is to ensure that changes to the process and/or equipment do not negatively impact the process safety and operational goals. The AIM program enables Whiting to build and operate safer and more reliable facilities and lower the risk of environmental, safety and process-related incidents.

Results of completed risk assessments and detailed incident investigations were used in the development of a standardized well facility design for Whiting. The resulting design will contribute to increased process safety and efficiency realized through our enhanced ability to supervise material, equipment procurement and facility construction. The most impactful change in the new facility design is a flowline emergency shutdown valve, which enables automatic and remote shutdown of the facility in adverse conditions and/or specific events. Another safety enhancement of the new facility design includes the addition of safety shutdown valves that help prevent flare flashbacks.


CLIMATE RISK Whiting recognizes the increasing public concern around greenhouse gases and other air emissions and global climate change. With this concern and focus comes the potential for new regulations. Oil and natural gas will continue to play an important role in meeting the country’s long-term energy demands despite increasing diversity of energy sources. Understanding our critical role in supplying affordable, reliable and efficient energy, we are committed to sustainable and responsible development of our oil and gas resources. This commitment includes understanding and mitigating climate change risk. To that end, Whiting’s Board of Directors evaluates climate risk issues on a regular basis.

For additional details on climate risk, please review our 2019 Form 10-K filing.

SUPPLY CHAIN SUSTAINABILITY An integrated and collaborative approach with supply chain vendors is good for sustainability and corporate value. Whiting has developed strong procurement policies that create savings, reduce supplier risk and advance stewardship. In 2019, we began requesting vendors acknowledge new policies to define minimum expectations related to labor and human rights and conflicts of interest/anti-corruption.

We maintain Master Service Agreements (MSAs) designed to have vendors adhere to regulations and Whiting specific safety and environmental standards. Select MSAs also include specific compressor and generator Environmental Addendums to address air emissions. Between our MSAs and procurement policies, we are elevating Whiting’s partner selection standards and improving safety, human rights and the environment. Whiting performs routine audits to ensure compliance, which is covered in more detail in the Social section of this report.


HUMAN RIGHTS Whiting supports the principles described in the United Nations’ Universal Declaration on Human Rights, which aligns with our core values, our corporate philosophy and our code of conduct. We strive to foster an everimproving culture, with emphasis on health and safety,

environmental sustainability, the health and welfare of our employees and partners, and the wellbeing of the communities in which we operate. A copy of Whiting’s Human Rights policy can be found here.

At Whiting, we are we are proud to partner with Truckers Against Trafficking (TAT). TAT is a 501(c)(3) nonprofit created to educate, equip, empower and mobilize the trucking industry to combat human trafficking as part of their regular jobs. TAT also partners with law enforcement and government agencies to facilitate the investigation of human trafficking. We have engaged not only our employees, but also our contractors in our support of TAT. In 2019, Whiting partnered with TAT to provide an in-person training to our employees, vendors and peers through a Lunch and Learn event in Williston, ND. We also hosted TAT’s mobile exhibit, the Freedom Drivers Project, to provide a glimpse into the realities of human trafficking, how industry is driving positive change in the area and simple action steps anyone can take to fight it. Employees and community members toured this powerful multimedia exhibit. Conversations with those walking through the exhibit revealed that this is an issue that Whiting employees are passionate about and want to combat in their community. We will continue to help create awareness about the risks of human trafficking while working to keep the communities we work and live in safe.



WHITING REPORTING GUIDANCE — DISCLOSURE REFERENCE TABLE This table is intended to demonstrate how Whiting may identify the location of sustainability content that aligns to disclosures required by selected reporting frameworks. This table lists disclosures from:

• t he Global Reporting Initiative Sustainability Reporting Standards (GRI Standards), and • IPIECA’s oil and gas industry guidance on voluntary sustainability reporting, and • SASB’s Oil and Gas - Exploration and Production Standard

A number of the disclosures required by these frameworks address similar topic areas. The table has been structured to identify where the reporting requirements of the frameworks address similar content.






102-1 Name of organization

SR: Page 4

102-2 Organization's activities

SR: Page 4

102-3 Location of headquarters

SR: Page 4, Website: About Whiting

102-4 Location of operations

SR: Page 4, Website: About Whiting

102-5 Ownership and legal form

2019 Annual Report and SEC From 10-K

102-6 Markets served

2019 Annual Report and SEC From 10-K

102-7 Scale of organization

2019 Annual Report and SEC From 10-K

102-8 Information on employees and other workers

SR: Page 35

102-9 Supply chain

SR: Page 45

102-11 Precautionary principle/approach

We evaluate identified risks and develop and implement mitigation plans.

102-13 Membership of associations

SR: Page 9





102-14 Statement from senior decisionmaker

SR: Page 2

102-16 Values, principles, standards, and norms of behavior

SR: Page 5

102-17 Mechanisms for advice and concerns about ethics

SR: Pages 42-43

102-18 Governance structure

SR: Page 42

102-29 Identifying and managing economic, environmental, and social impacts

SR: Page 42

102-30 Effectiveness of risk management processes

SR: Page 43

102-35 Remuneration policies

SR: Page 43

102-36 Process for determining remuneration

SR: Page 43

102-37 Stakeholders’ involvement in remuneration

SR: Page 43

102-43 Approach to stakeholder engagement

The frequency of our engagement varies by stakeholder and issue.

102-44 Key topics and concerns raised

SR: Page 6

102-45 Entities in consolidated financial statements

2019 Annual Report and SEC Form 10-K

102-46 Defining report content and topic boundaries

SR: Page 6

102-47 List of material topics

SR: Page 6





102-50 Reporting period

SR: Page 6

102-51 Date of most recent report

SR: Page 6

102-52 Reporting cycle

SR: Page 6

102-53 Contact point for questions regarding the report

SR: Page 54

102-54 Claims of reporting in accordance with GRI standards

SR: Page 6

102-55 GRI content index

SR: Pages 48 - 51

102-56 External assurance

SR: Page 6

201-1 Direct economic value generated and distributed

SE4: Social investment

201-2 Financial implications and other risks and opportunities due to climate change

E3: Alternative energy sources

205-1 Operations assessed for risks related to corruption 205-2 Communication and training about anti-corruption policies and procedures



SR: Page 41 SR: Page 45 "EM-EP-420a.1: Sensitivity of hydrocarbon reserve levels to future price projection scenarios that account for a price on carbon emissions EM-EP-420a.2: Estimated carbon dioxide emissions embedded in proved hydrocarbon reserves EM-EP-420a.3: Amount invested in renewable energy, revenue generated by renewable energy sales EM-EP-420a.4: Discussion of how price and demand for hydrocarbons and/or climate regulation influence the capital expenditure strategy for exploration, acquisition, and development of assets" "EM-EP-510a.2: Description of the management system for prevention of corruption and bribery throughout the value chain"

SE11: Preventing corruption

SR: Pages 42-43

SR: Pages 42-43





205-3 Confirmed incidents of corruption and actions taken

SR: Pages 42-43

206-1 Legal actions for anti-competitive behavior, anti-trust, and monopoly practices

SR: Pages 42-43

303-1 Water withdrawal by source

E6: Fresh water

303-3 Water recycled and reused

304-1 Operational sites owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas

E5: Biodiversity and ecosystem services

EM-EP-140a.1: (1) Total fresh water withdrawn, (2) total fresh water consumed, percentage of each in regions with High or Extremely High Baseline Water Stress

SR: Page 17

EM-EP-140a.2: Volume of produced water and flowback generated; percentage (1) discharged, (2) injected, (3) recycled; hydrocarbon content in discharged water

SR: Page 18

"EM-EP-160a.1: Description of environmental management policies and practices for active sites EM-EP-160a.2: Number and aggregate volume of hydrocarbon spills, volume in Arctic, volume impacting shorelines with ESI rankings 8-10, and volume recovered EM-EP-160a.3: Percentage of (1) proved and (2) probable reserves in or near sites with protected conservation status or endangered species habitat"

SR: Page 24

304-2 Significant impacts of activities, products, and services on biodiversity

SR: Page 24

304-3 Habitats protected or restored

SR: Page 24

305-1 Direct (Scope 1) Emissions

"E1: Greenhouse gas emissions E2: Energy use"

305-4 GHG emissions intensity

E1: Greenhouse gas emissions

"EM-EP-110a.1: Gross global Scope 1 emissions, percentage methane, percentage covered under emissions-limiting regulations EM-EP-110a.2: Amount of gross global Scope 1 emissions from: (1) flared hydrocarbons, (2) other combustion, (3) process emissions, (4) other vented emissions, and (5) fugitive emissions EM-EP-110a.3: Discussion of long-term and short-term strategy or plan to manage Scope 1 emissions, emissions reduction targets, and an analysis of performance against those targets"

SR: Page 11

SR: Page 11



306-1 Water discharge


E7: Discharges to water


"EM-EP-140a.3: Percentage of hydraulically fractured wells SR: Page 18 for which there is public disclosure of all fracturing fluid chemicals used EM-EP-140a.4: Percentage of hydraulic fracturing sites where ground or surface water quality deteriorated compared to a baseline"

306-2 Waste type and disposal method

SR: Page 20

306-3 Significant spills

E9: Spills to the environment

SR: Pages 18-19

306-4 Transport of hazardous waste

E10: Waste

SR: Page 20

307-1 Non-compliance with environmental laws and regulations

"EM-EP-530a.1: Discussion of corporate positions related to government regulations and/or policy proposals that address environmental and social factors affecting the industry Note for Whiting - this disclosure also aligns to GRI 419-1"

308-1 New suppliers that were screened using environmental criteria 401-1 New employee hires and employee turnover

SR: Page 42

SR: Page 45 SE16: Workforce engagement

SR: Page 35 SR: Page 36

"401-2 Benefits provided to full-time employees that are not provided to temporary or part-time employees"



403-2 Types of injury and rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities

HS3: Occupational injury and illness incidents

404-1 Average hours of training per year per employee

SE17: Workforce training and development

"EM-EP-320a.1: (1) Total recordable incident rate (TRIR), (2) SR: Page 27 fatality rate, (3) near miss frequency rate (NMFR), and (4) average hours of health, safety, and emergency response training for (a) full-time employees, (b) contract employees, and (c) short-service employees EM-EP-320a.2: Discussion of management systems used to integrate a culture of safety throughout the exploration and production lifecycle" SR: Page 37




404-2 Programs for upgrading employee skills and transition assistance programs 405-1 Diversity of governance bodies and employees


SR: Page 37 SE15: Workforce diversity and inclusion

SR: Page 35

406-1 Incidents of discrimination and corrective actions taken

There were no incidents of discrimination reported in 2019 with employees.

412-1 Operations that have been subject to human rights reviews or impact assessments

SE8: Human rights due diligence

SR: Page 46

412-2 Employee training on human rights policies or procedures

SE10: Security and human rights

SR: Page 46

413-1 Operations with local community engagement, impact assessments, and development programs

SE1: Local community impacts and engagement

414-1 New suppliers that were screened using social criteria

SE9: Human rights and suppliers

419-1 Non-compliance with laws and regulations in the social and economic area

"SE5: Local content practices SE6: Local hiring practices SE7: Local procurement and supplier development"

"EM-EP-210b.1: Discussion of process to manage risks and opportunities associated with community rights and interests EM-EP-210b.2: Number and duration of non-technical delays"

SR: Pages 38-39

SR: Page 28 "EM-EP-530a.1: Discussion of corporate positions related to government regulations and/or policy proposals that address environmental and social factors affecting the industry "

SR: Page 42

"EM-EP-210a.1: Percentage of (1) proved and (2) probable reserves in or near areas of conflict EM-EP-210a.2: Percentage of (1) proved and (2) probable reserves in or near indigenous land EM-EP-210a.3: Discussion of engagement processes and due diligence practices with respect to human rights, indigenous rights, and operation in areas of conflict EM-EP-510a.1: Percentage of (1) proved and (2) probable reserves in countries that have the 20 lowest rankings in Transparency International’s Corruption Perception Index"

SR: Page 45


QUESTIONS OR COMMENTS? We’d love to hear form you. Contact Kevin Kelly, Whiting’s VP of Business Development and ESG or Emily Caldwell, Corporate Communications and ESG. Kevin.Kelly@whiting.com Emily.Caldwell@whiting.com