SANTOS LIMITED — Director's Dealing 2020

Dec 10, 2020

Mr Adrian Smythe Manager, Listings Compliance Australian Securities Exchange 20 Bridge Street Sydney NSW 2000

11 December 2020

Dear Mr Smythe

Appendix 3Y – Change of Director's Interest Notice

Enclosed is an Appendix 3Y Notice by Santos Limited for Kevin Gallagher announcing the award of deferred shares and Share Acquisition Rights (SARs) as part of the 2020 ShareMATCH employee share plan.

In 2020, the ShareMATCH share plan rules were amended such that Executives were eligible to participate in the plan for the first time. Mr Gallagher participated in the plan and on 4 September 2020, the beneficial interests in the deferred shares were allocated to Mr Gallagher, along with the SARs, in full compliance with the Company's Securities Trading Policy. An administrative error due to the change in process in 2020 has resulted in the lodgement of an Appendix 3Y being overlooked. Santos has recognised this error and immediately taken steps to notify the ASX. In addition, internal processes in connection with the allocation of ShareMATCH shares have been reviewed to ensure that an Appendix 3Y is lodged within the prescribed time period in relation to any future awards to Mr Gallagher under the ShareMATCH plan.

Yours sincerely,

Amanda Devonish Company Secretary

Rule 3.19A.2

Appendix 3Y

Change of Director's Interest Notice

Information or documents not available now must be given to ASX as soon as available. Information and documents given to ASX become ASX's property and may be made public.

Introduced 30/09/01 Amended 01/01/11

Name of entity	SANTOS LIMITED
ABN	80 007 550 923

We (the entity) give ASX the following information under listing rule 3.19A.2 and as agent for the director for the purposes of section 205G of the Corporations Act.

Name of Director	Kevin Thomas Gallagher
Date of last notice	15 April 2020

Part 1 - Change of director's relevant interests in securities

In the case of a trust, this includes interests in the trust made available by the responsible entity of the trust

Note: In the case of a company, interests which come within paragraph (i) of the definition of "notifiable interest of a director" should be disclosed in this part.

Direct or indirect interest	Direct and indirect
Nature of indirect interest(including registered holder)Note: Provide details of the circumstances giving riseto the relevant interest.	Shares held by Sesap Pty Ltd as Santos' employee share plantrustee
Date of change	4 September 2020
No. of securities held prior to change	1,098,863 fully paid ordinary shares (indirect interest)2,169,564 Share Acquisition Rights granted under SEEIP,previously known as SESPP220,149 fully paid ordinary shares held by Sesap Pty Ltd (2018deferred STI)142,048 fully paid ordinary shares held by Sesap Pty Ltd (2019deferred STI)
Class	Fully paid ordinary shares (1,796) and Share Acquisition Rights(1,796)
Number acquired	3,592
Number disposed	Nil
Value/ConsiderationNote: If consideration is non-cash, provide detailsand estimated valuation	Nil

+ See chapter 19 for defined terms.

No. of securities held after change

1,098,863 fully paid ordinary shares (indirect interest)2,169,564 Share Acquisition Rights granted under SEEIP,previously known as SESPP220,149 fully paid ordinary shares held by Sesap Pty Ltd (2018deferred STI)142,048 fully paid ordinary shares held by Sesap Pty Ltd (2019deferred STI)1,796 Share Acquisition Rights granted under ShareMATCH1,796 fully paid ordinary shares held by Sesap Pty Ltd (2020ShareMATCH)

Nature of changeExample: on-market trade, off-market trade,exercise of options, issue of securities underdividend reinvestment plan, participation in buyback

Allocation resulting from 2020 ShareMATCH program.

Part 2 – Change of director's interests in contracts

Note: In the case of a company, interests which come within paragraph (ii) of the definition of "notifiable interest of a director" should be disclosed in this part.

Detail of contract
Nature of interest
Name of registered holder(if issued securities)
Date of change
No. and class of securities to whichinterest related prior to changeNote: Details are only required for a contract inrelation to which the interest has changed
Interest acquired
Interest disposed
Value/ConsiderationNote: If consideration is non-cash, provide detailsand an estimated valuation
Interest after change

Part 3 – +Closed period

Were the interests in the securities or contracts detailed above	No
traded during a +closed period where prior written clearance
was required?
If so, was prior written clearance provided to allow the trade toproceed during this period?	Not applicable
If prior written clearance was provided, on what date was thisprovided?	Not applicable

+ See chapter 19 for defined terms.