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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.
Tullow's Code of Business Conduct ('the Code) is supported by a Group-wide 'Code awareness' programme. To date, over 2000 permanent and contract staff have attended, representing over 88% of our workforce. All members of the Executive and Board have participated in the half-day awareness session and our Code of Business Conduct has been translated for our French-speaking countries, such as Mauritania and Gabon. In addition, we have held industry partner forums in Bangladesh, Kenya and Ghana, to provide an overview of anti-bribery legislation, including the UK Bribery Act (2010).
The UK Bribery Act (2010) 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.