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Company Response

Total's response

As part of the public consultation opened by the SEC regarding the proposed rule on Disclosure of Payment by Resource extraction issuers, Total has already submitted its comments to the SEC. Total considers that the re-introduction of Rule 13q1 under the Dodd Frank Act should enhance transparency for the benefit of the whole industry and its stakeholders and, to this end, restore a level playing field among major publicly listed oil and gas companies. As a result, the Group strongly supports that the SEC align the Proposed Rule with the European Directive 2013/34/EU, more stringent mainly on two key points : (i) the threshold above which payment to foreign governments must be presented in the report and (ii) the definition of the term “project”.  Our detailed position is available on the SEC website : https://www.sec.gov/comments/s7-24-19/s72419-6791650-208331.pdf 

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