Ethics and integrity

We are committed to maintaining the highest ethical standards in the personal and professional conduct of our employees, suppliers, contractors and consultants. We aim to ensure that our day-to-day business activities are conducted in a fair, honest and ethical manner and each person connected with Tullow has individual responsibility for maintaining an ethical workplace. Managers and leaders throughout the Group have an additional role of fostering the proper environment and encouraging ethical practices.

The Tullow Code of Business Conduct (‘the Code’) sets out general business principles, the Group’s Ethics & Integrity policy, Whistleblowing policy and Human Rights policy.

As a principles-based code, people are guided to use their best judgement to make the right decisions for the wide variety of situations they face, and are encouraged to ask for further assistance if they are unsure of the right thing to do. As well as being a personal guide to behaviour, the Code forms an important element in the contract specification and purchasing terms used by the Group’s Supply Chain Management department. The Code was approved by the Board and rolled out during 2009 in conjunction with an awareness campaign.

It has always been our intention that the Code remains a living, working document with internal controls and procedures in line with the dynamic environment in which we operate. Amendments expected in our 2010 revision include testing the Code’s robustness in line with the UK Bribery Act and separating out our Human Rights policy to raise its profile. The next edition of the Code will also include examples of business ethics dilemmas which we hope will help to make the consistent application of the Code easier. An important next step is to undertake an internal audit review of the Code in practice in 2010, with an external audit planned in 2011.

We need to ensure that awareness of the Code reaches 100% of all audiences, and during 2010 we have defined a training and communications programme to achieve this, including line management initiatives to explain and promote the Code, and a series of open workshops following recent successful ones held in Accra and Takoradi, Ghana.