Subject: File No. S7-42-10
From: Francois Valerian, Ph.D.
Affiliation: Head of Private Sector, Transparency International

March 1, 2011

In 2008 and 2011 we produced two reports on the transparency of revenue reporting of oil and gas companies. We believe the results are of interest to the discussion.

We would draw your attention to the poor levels of country level financial reporting of the majority of multi-national oil and gas companies analysed in the report. (page 3).

The questions relating to country-level reporting are on page 60 (questions 37-46). The individual company scores are found on pages 87-109.

On pages 37-39 there are charts which show that companies operating in difficult environments have very different levels of disclosure. Some companies (Statoil, for example) report on their operations country-by-country wherever they operate in the world. This proves it is not a competitive matter but a matter of having management sufficiently involved and willing to disclose the information.

Francois Valerian

(Attached File #1: 2011 Report)
(Attached File #2: 2008 Report)