Board of Directors’ report
14
DNO
Annual Report and Accounts 2022
notwithstanding sometimes lengthy delays, payments
have
ultimately been received by DNO.
At yearend 2020, the Group had accumulated
a receivable
against the KRG of USD 259 million after certain 2019
and
2020 entitlement and override payments to the
Group and other
KRI oil exporters were withheld early in 2020 by
the KRG in
connection with the Covid-19 pandemic. Payment
plans were
put in place by the KRG by which the outstanding
arrears were
reduced to USD 2 million at yearend 2022 (from
USD 169
million at yearend 2021), not including any interest.
The
Company continues to work to collect the remaining
balances
and expects to be paid accordingly.
Over the course of 2022, KRG payments to
international oil
companies were increasingly delayed. At the time of
issuing this
report, the invoices related to August and September
2022 oil
deliveries were paid in January and March
2023, respectively.
The Company is in dialogue with the KRG, seeking
timely
payments to support timely investments. Moreover, in
September 2022, the KRG proposed a change in
the previously
agreed pricing formula for oil such that prices
should, with effect
from 1 September 2022, be based on the
purported actual price
realized by KRG during the delivery month. The
KRG proposal
has not been accepted by DNO and the Company
continues to
invoice the KRG for oil sales based on the
previously agreed
pricing formula (including the September 2022 invoice) until
such time that protocols are put in place to ensure
that realised
prices are transparent, based on arms-length transactions
and
subject to third-party audit. The payment for the September
oil
delivery received after yearend reflects the formula proposed
and unilaterally applied by the KRG in September
2022. The
payment received was USD 5.2 million (net to DNO)
lower than
invoiced (see notes 12 and 18). The Company
is in continuing
dialogue with the KRG to resolve this matter and
collect
DNO also notes the ongoing arbitration case,
commenced in
2014, by the FGI against the Turkish Government and its state-
owned pipeline operator BOTAS relating to the Iraq-Turkey
Pipeline. It is unclear if a ruling, when
it comes, may have an
impact on future transportation of Kurdish oil in said
pipeline.
Operational risk
DNO is exposed to operational risks across its
portfolio.
Operational risk applies to all stages of upstream operations,
including exploration, development and production.
Failure to
manage operations efficiently can manifest itself in project
delays, cost overruns, higher-than-estimated operating
costs
and lower-than-expected oil and gas production
and/or
reserves. Exploration activities are capital intensive
and involve
a high degree of geological risk. Sustained exploration
failure
can affect the future growth and upside potential
of DNO.
Our ability to effectively manage and deliver value from
our
exploration, development and production activities is
dependent
on the quality of our staff and contractors. Inefficiency or
interruption to our supply chain or the unwillingness
of service
contractors to engage in our areas of operation
may also
negatively affect operations.
Environmental risk
Oil and gas exploration and production, by its
nature, involves
exposure to potentially hazardous materials. The loss of
containment of hydrocarbons or other dangerous substances
could represent material risks. Through our operational
controls, environmental impact assessments, asset integrity
protocols and management systems related to health,
safety
and the environment, we aim to mitigate hazards
with a
potentially adverse impact on people, the environment,
our
assets, our profitability and our reputation.
Climate-related risk
The most important risks to DNO’s business prospects
from
concerns about the impact of fossil fuel use on
climate derive
from the uncertain consequences of environmental
action on oil
and gas demand and supply, and therefore prices. Increasing
concerns about adverse climate impact may affect investor
appetite for oil and gas investments both within equity
and debt
markets, inhibiting the Group’s ability to obtain funding. Such
concerns could also reduce the attractiveness of
the oil and gas
sector (including DNO) as an employer.
In the North Sea, carbon prices have been rising
through CO
2
taxes, emissions trading schemes and carbon price
floors.
Policies requiring electrification of offshore oil and gas
production may also increase North Sea operational
costs.
In Kurdistan, the Government in 2021 introduced a
requirement
that oil and gas companies curb gas flaring and
thus reduce
emissions. While the Group is a pioneer in flaring
reduction
measures in Kurdistan, having built the first gas
capture and
injection facilities in the region at the Tawke license, stricter
policies or sanctions may increase the Group’s operational
cost
or preclude development of fields with high gas-oil-ratios.
In preparing these financial statements, management has
considered the impact of climate-related risks by assessing
the
potential effects of stricter climate policies on its oil and gas
portfolio. To assess the robustness of its oil and gas assets, the
Company has run sensitivities with the oil and gas
price
assumptions described by scenarios outlined by
the
International Energy Agency (IEA), namely the
Stated Policies
Scenario, Announced Pledges Scenario and the Net
Zero
Emissions by 2050 Scenario (see Note 9).
In addition to the financial aspects mentioned above,
climate
change may represent a physical risk to personnel
and facilities
in the form of increased frequency and severity of
extreme
Security risk
Although some of our operations are in regions
with security
risks, we continuously work to manage these risks
through
clearly defined protocols and practices. Nevertheless,
we are
often dependent on the quality of the security
and protection
provided by authorities in host countries.
Compliance risk
DNO has a policy of zero tolerance for corruption,
bribery and
other illegal or inappropriate business conduct.
Violations of
compliance laws and contractual obligations can
result in fines
and a deterioration in the Group’s ability to effectively execute
its business plans. DNO adheres to a strict
and comprehensive
conflict of interest policy, trade sanctions and other policies
focused on the Group’s Code of Conduct to ensure regulatory
and company expectations are met. The Company encourages
its personnel to raise concerns about unethical or
illegal
behavior and breaches of DNO’s Code of Conduct or other
Company policies. The Company also has a confidential