Code of conduct and Anti-corruption policy As a growing global business, SBM Offshore is committed to conducting its business honestly, ethically, and lawfully. It recognises the importance of ethical compliance and has reinforced its compliance programme around the world throughout 2011.
During 2011, the Company continued its campaign to implement anti-corruption due diligence on all agents, freight forwarders, partners and major suppliers, completing 79 due diligence studies, with more currently underway. The Company ensures that its relationships with intermediaries are formalised by written agreement by using template agreements that clearly document its policies covering corruption, conflict of interest situation, and compliance with applicable laws and regulations.
Reinforcing SBM Offshore’s ethical standards The Company has updated its Code of Conduct to match the requirements of the UK Bribery Act. It has also published an AntiCorruption Policy & Compliance Guide, which provides SBM Offshore employees, partners, agents and subcontractor/suppliers with concrete guidelines on how to prevent corruption risks and deal with those that arise. All employees are required to adhere to the Company’s ethical standards. They must comply with all applicable laws, and accurately record, and track transactions. Any non-compliance with required Ethical Standards is subject to disciplinary sanction. Employees, including all key personnel, receive yearly training on the Company’s Business Ethics, including anti-corruption laws and practices. During 2011, the Company decided to supplement this training with an e-learning training dedicated to anti-corruption laws, notably the U.S. FCPA and UK Bribery Act. To date, 98% of all employees required to do so have completed the e-learning course.
The Company requires that its intermediaries maintain accurate books and records and grant it the right to audit them. All business relationships are approved in accordance with internal procedures and the agreements are reviewed by the Company’s Legal Department. The Company also shares both its Code of Conduct and Anti-Corruption Policy and Compliance guide with all partners, agents, suppliers and other intermediaries, requiring them to comply with all published requirements. Any intermediary who does not comply with anti-corruption or anti-bribery laws or the Company’s policies is deemed to be in breach of contract and will have their contract terminated.
Annual certification process The Company completes an annual certification of compliance exercise to monitor employees’ compliance with its Code of Conduct. The certification of compliance concerns all employees in positions of responsibility and in corporate and managerial roles. These certificates contain a personal confirmation that individuals understand the Company’s Ethical Standards, and that both they and their teams operate in accordance with them.
Bribery and corruption In 2011, the Company updated its ethical standards to comply with the requirements of the UK Bribery Act, as follows: “The SBM Offshore Code of Conduct specifically prohibits the payment (directly or indirectly) of anything of value to a public official or a commercial decision maker to secure an improper business advantage”.
SBM Offshore’s goals for 2012 In 2012, the Company is committed to continual enhancement of its compliance programmes. To that end, the Company has retained a specialist law firm to further enhance its existing anticorruption policies and procedures. It includes its processes related to the retention and oversight of consultants and other third parties and its system of internal controls, with the goal of ensuring that the Company’s compliance programme is consistent with established best practices in this area. The Company plans to give all its employees access to its ethics e-learning course and to continue its due diligence campaign. The management will encourage all employees to protect and enhance the Company’s high ethical reputation.
The Anti-Corruption Policy and Compliance Guide re-iterates this standard and provides detailed steps for employees to take if faced with corruption risks. The Company also ensures all transactions are properly authorised and accurately and completely recorded.
Business Relations The Company makes it an essential requirement to maintain good business relations with partners, agents, supplier and other intermediaries. A good relationship requires trust and an understanding of one’s business partners. Consequently, due diligence is carried out for all potential partners, agents, suppliers and other intermediaries.
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