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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. Every person connected with Tullow has individual responsibility for maintaining an ethical workplace. Managers and leaders throughout the Group are additionally responsible for fostering a proper environment and encouraging ethical practices.
The Board has approved the new Tullow Code of Business Conduct ('the Code). This has been issued to all staff and will be provided as a matter of course to all of our industry partners via the Group's Supply Chain processes. This update to the Code is to provide further guidance on a range of topics and to ensure compliance with the new UK Bribery Act.
New anti-bribery legislation, called the UK Bribery Act, came into force in July 2011. This requires UK companies, or any foreign companies doing business in the UK, to ensure that all reasonable steps are taken to prevent acts of bribery. This Act, which applies to our business activities worldwide, is considered more onerous than the well known US Foreign Corrupt Practices Act (FCPA), which has resulted in many high profile prosecutions in recent years.
The Bribery Act criminalises bribery in both the commercial and public sectors. It is not limited to bribery that could be committed by a company's own staff but also covers individuals or companies working on a company's behalf. Successful prosecution under the Bribery Act can lead to unlimited fines for companies and individuals and jail sentences of up to 10 years. The only defence against an act of bribery being committed by a member of staff or an individual or company working on our behalf is to have in place 'Adequate Procedures' to prevent bribery. The UK Government, as a requirement of the UK Bribery Act, published their Adequate Procedures guidance on 30 March, 2011 and this is being used to shape and update the Tullow compliance programme.