Sustainability

SUSTAINABILITY

Comstock operates predominantly in the Haynesville shale in North Louisiana and East Texas, which is one of the premier natural gas plays in the United States. We are focused on developing our significant natural gas resource base to provide our customers a long-term and affordable energy source through the implementation of sustainable and safe business practices while achieving long-term financial returns for our stockholders. At Comstock, we are committed to conducting our business in a responsible manner that protects the environment along with the health, safety and security of our employees, contractors and the communities where we operate. Key elements of our business practices which demonstrate our commitment include:

Air Emissions Reduction

Comstock has achieved independent certification for our operated production under the MiQ Standard. The MiQ Standard is an independent framework for assessing methane emissions from the production of natural gas, along with the policies and practices of the producers making it.

Comstock is a member of The Environmental Partnership working collectively with other American companies to produce our nations essential natural gas and oil resources in an environmentally responsible manner.

Comstock utilizes dual-fuel and bi-fuel technology in drilling and completions operations. As a result, we are able to use cleaner burning natural gas to help power our development activities.

We have implemented a rigorous leak detection and repair (LDAR) program covering 100% of our operated assets. The LDAR program is comprised of both aircraft deployed technology as well as handheld optical gas imaging technology.

Minimize Surface Land Disruption

Comstock employs multi-well pad locations and extends the lateral lengths of its wells to minimize our land surface footprint and reduce rig move traffic. The reduced traffic makes our roads safer, requires less fuel for transports and less noise/activity in the communities in which we operate. Prior to developing a well site, we work closely with third-party experts who perform extensive reviews for wetlands, threatened/endangered species and historical cultural resources.

EH&S Management System

Comstock maintains an Employee Health and Safety management system with the goal of achieving operational excellence and an injury-free workplace. The EH&S management system consists of policies, procedures, and programs to drive a proactive safety culture. Our EH&S Management System has provisions to train employees, set targets and objectives for accountabilities, and audit/inspect to measure our results to identify improvement opportunities.

We work with a third-party contractor management service provider to ensure our contractors are held to the highest performance standards.

Under our Stop Work Authority any employee or contractor has the authority and obligation to stop work due to unsafe conditions.

Corporate Governance

Comstock strives to conduct our business in a responsible and ethical manner that is aligned with the interests of all of our stakeholders, including shareholders, debt investors, employees and the communities in which we operate. Recent changes to our 2020 Annual Incentive program added returns-driven and cost-efficiency measures to better align the interest of management with shareholders. Comstock’s Corporate Governance Guidelines and Code of Business Conduct and Ethics drive our commitment to high ethical standards across the organization.