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.
Our commitment to managing ethics and compliance risks with third parties
We perform risk-based due diligence on our business partners, including suppliers, JV partners, social investment beneficiaries and other third parties. Our due diligence approach requires an assessment of the risk exposure of an actual or prospective third party that we work with (e.g. low, medium or high risk), determining if the third party is required to complete a due diligence questionnaire and the information we are required to query.
Where a risk exposure has been assessed and the completion of a due diligence questionnaire is required, we seek disclosures from third parties with respect to bribery and corruption, fraud, tax evasion, sanctions and economic restrictions, and human rights and labour conditions.
Furthermore, in line with our support for the Extractives Industries Transparency Initiative (EITI), we are committed to beneficial ownership transparency: our due diligence questionnaires are designed to seek disclosures from third parties on their ultimate beneficial owners.
Our due diligence processes support us in assessing, mitigating, and managing our ethics and compliance risks with our business partners.
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.
Speaking Up
Tullow is committed to providing a supportive and listening culture, where anyone who works for (or on behalf of) us feels empowered and comfortable in raising concerns. We encourage all of our employees, and anyone else whom may be affected by our business operations, to ‘Speak Up’ with any concerns related to any form of misconduct which may breach our Code.
If you have any concerns related to our business practices, you may raise these concerns via our ‘ComplianceLine’ reporting tool. ComplianceLine is an independent company, which provides a ‘speaking up’ service to many different organisations, including Tullow. The ComplianceLine service offers an independent, safe and confidential mechanism enabling concerns to be raised in good faith, whilst enabling you to remain anonymous, if you wish.
You may report any genuine concern, which is being raised in good faith, even if the concern is later determined to be factually incorrect or unfounded. In particular, any concern relating to something which is unsafe, unethical and/or may breach our Code. Examples of concerns that may be reported through ComplianceLine include (but are not limited to) actual or suspected incidents involving:
- Action or intention to commit a criminal offence;
- Disregard for the environment, health, safety, security or human rights;
- Financial irregularity or suspicion of bribery, fraud, tax evasion or theft;
- Bullying or harassment of an individual;
- Any action to hide or cover up wrongdoing.
The service is available 24 hours a day, 7 days a week. They may be contacted via telephone or via their website (using the link on the right of this page).
All reported concerns are taken seriously and will be thoroughly investigated to extent possible.
