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.
We are committed to applying the Code in the way we work and promoting our Code amongst staff, suppliers and other external stakeholders. We have also developed compliance standards, procedures and guidelines commensurate with our risk exposure; these are referenced and described in the Code.
On an annual basis, we obtain a certification from staff on their compliance with the Code and its accompanying standards and procedures and non-compliances are investigated. Both internal and external channels are available for raising concerns and speaking up, details of which are published in our Code, including our policy of not retaliating against someone who has raised a concern in good faith.
UK Bribery Act
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 guidance on 30 March 2011 and the Tullow anti-bribery and corruption programme is based on the six principles of the Adequate Procedures guidance.