Supply Chain Management
Tullow recognises that the success of the oil and gas industry should bring long-term social and economic benefits to the communities and countries where we operate. One way to meet this aspiration is through robust and fit for purpose local content procurement practices which enable local companies to participate in our supply chain.
- Tullow looks to give first consideration of the procurement of goods and services, where commercially and technically possible, to local suppliers from the host countries in which we operate
- Our procurement strategy requires our international suppliers to set out their commitment to developing local companies within their own supply chain
- Local content spend with both INTRIC (International Suppliers Registered in Country) and local suppliers is measured and reported internally on a monthly basis, which drives behaviours consistent with optimising local content
Our ability to optimise local content will vary at different stages of the development lifecycle and in accordance with applicable obligations and the availability of local suppliers that meet acceptable health, safety, technical and compliance standards.
Screening of suppliers on environmental criteria
Where applicable, Tullow uses pre-qualification criteria related to environmental issues when screening suppliers with which we may do business. Further evaluation of a supplier’s environmental criteria will be completed, when applicable, during the technical evaluation of suppliers.
Monitoring of supplier compliance with our standards
On a quarterly basis, suppliers are screened against a compliance database that covers sanctions, trade restrictions, notifications of financial crime and adverse media coverage in relation to bribery and corruption, and human rights violations, amongst others.
Production Sharing Agreement Transparency
Tullow believes that the success of the oil and gas industry should bring long-term social and economic benefits to the communities and countries where we operate. We consider transparency and disclosure to be an important first step in enabling governments, citizens and international opinion formers to participate in debate and the exchange of ideas on how wealth from oil resources should be managed sustainably and equitably.
As part of this commitment, we support the public disclosure of Production Sharing Agreements, which can help people to understand our activities, build trust and manage the expectations of communities. This also aligns with Tullow’s goal of creating shared prosperity through its business activities, and with our role as a corporate supporter of the Extractive Industries Transparency Initiative (EITI). Specifically:-
- Tullow supports disclosure of its Production Sharing Agreements, but we will only do this with the express support and agreement of our Government partners
- We are committed to ensuring that all of our Government and Joint Venture partners are aware of our support for public disclosure of our PSAs, and the benefits that we believe this can bring to the success of our projects
- We provide insights into how our industry operates and the prosperity it can bring
Engagement with policymakers and regulators
Tullow engages with all relevant national and local Government departments and agencies, at every stage of the project lifecycle. On environmental and social impacts, most engagement consists of formal ESIA-focussed discussions and normal ongoing dialogue with regulators to discuss matters of environmental and social compliance performance. Conversations around subjects such as land use, security provisions, fresh water use, noise, waste management and other issues are conducted.
Our focus is on building and maintaining an enabling environment for our business while ensuring that our activities can contribute effectively to the economies of the countries in which we operate. This includes actively engaging in dialogue with government on issues of importance to our business and to our stakeholders, including communities.
Tullow engages in policy debate on topics that are of legitimate commercial interest to the company, including applicable laws and regulation. We do not however conduct advocacy campaigns, participate in political process, or make political contributions or donations.
Tullow conducts our business in compliance with applicable laws and our Code of Ethical Conduct. In addition, we are subject to the UK Bribery Act and have an anti-corruption programme in place.
Our focus is on building and maintaining an enabling environment for our business, while ensuring our activities can contribute effectively to the economies of the countries in which we operate. We look for opportunities to exchange information freely and fairly with Government, and to actively engage in dialogue with Government on issues of importance to our business and stakeholders. In addition to compliance with the Code of Ethical Conduct, our policy is to:
- Conduct our Government engagement activities with integrity
- Comply with applicable national and international laws and regulations on political engagement and lobbying, including registration and reporting requirements
- Ensure that the contracts of all third-party intermediaries appointed to make representations to Governments on behalf of Tullow require them to do the same
- Only appoint third parties to represent Tullow’s views under a formal written contract and once full due diligence checks have been conducted and documented
Diversity & Inclusion
Tullow believes that a diverse and inclusive workforce is critical to maintaining a successful and sustainable business. Furthermore, Tullow strives to create a workplace that treats employees fairly, equally and with respect. Our rich diversity, skills, abilities and the creativity that people from differing backgrounds and experiences bring to the company are highly valued.
Our Diversity & Inclusion Plan has the objectives of: achieving a diverse employee population with a nationality mix representative of our assets’ geographic footprint and, improving gender diversity (especially at senior levels). Specifically, Tullow will:
- Operate with zero tolerance towards discrimination and comply with employment laws in all the jurisdictions where we work
- Work with host Governments to fulfil localisation and training obligations set out in our licences and in regulations
- Utilise an Executive Team Sub-Group to advance our long-term diversity and inclusion goals;
- Monitor and report diversity data on a quarterly basis internally, paying particular attention to changes affecting our African nationals and female employees
- Take account of the recommendations set out in the UK Hampton-Alexander Review to progress gender balance in senior leadership positions and on the Board
- Ensure that recruitment searches are conducted across a diverse talent pool, and all Executive searches facilitated by external search firms comply with the Executive Search Firms Voluntary Code of Conduct
Gender Pay Gap reporting
Tullow supports the UK Government’s action to report gender pay, because greater transparency encourages a level playing field and development of women in the workplace and will highlight any practice of pay and bonus discrimination. Gender Pay Gap Reporting is a requirement of the UK Government from April 2017 for companies with 250+ employees in Great Britain. Specifically, Tullow will:
- Report our annual gender pay gaps in accordance with the requirements stipulated by the UK Government
- Explain the reasons for any gaps and the measures we are taking to address disparities
- Address gender pay gaps during our annual salary review cycle
- Through our Diversity & Inclusion Plan continue to ensure equal gender representation in pay and senior leadership roles
The Board supports the aspirations for female participation on boards set out in the Davies Report and in the Hampton-Alexander Review, but we believe that to achieve this within the timeframe contemplated would restrict future Board appointments to women only, which may not be in the best interest of the Company. The Board also supports the targeted improvements to ethnic diversity on boards set out in the recent Parker Review.
Tullow has not formally adopted any quotas on female or ethnic representation on the Board, but we are committed to ensuring that all searches for board level roles are conducted from a diverse talent pool. In that regard, Tullow ensures:
- All board search mandates are facilitated by reputable external search firms who have signed up to the Executive Search Firms Voluntary Code of Conduct
- That any long list prepared for a board level role consists of at least 33% female candidates and has appropriate levels of ethnic diversity to reflect our business and where we operate
- That we continue to actively promote and develop a diverse pool of talent in our senior management pipeline so that our internal-promotion candidates for board level roles meet our diversity aspirations
Bribery & Corruption
Our Code of Ethical Conduct is at the core of our Ethics & Compliance programme which is designed to ensure that we conduct our business ethically and legally. We have zero tolerance for bribery, corruption and other financial crime and this is fully supported by Tullow management and the Board. We update the Code as part of our three-year review cycle for Board-level policy documents. We require those who deliver services to us, or who act on our behalf, to act in a manner consistent with our Code in addition to the specific business ethics and compliance clauses we have in place in our agreements as well as other clauses that cover anti-slavery and compliance with sanctions and trade restrictions. These contractual clauses are designed to ensure that third parties connected to Tullow will not cause us to breach our own Code. Prior to contract award, we also conduct risk-based third party due diligence to assess risks related to ownership structure, anti-bribery and corruption, sanctions and trade restrictions and human rights and labour conditions. We also run an annual eLearning on the Code for all staff.
Whistle blower policies
We are committed to ensuring that the integrity of our Code of Ethical Conduct is not compromised, whether by staff or by those who work on our behalf. To this end, we have a Speaking Up process in place, comprised of internal channels to speak up to a manager or the Tullow Ethics & Compliance team, or via our external independent and confidential reporting process provided by Safecall. We prominently publish the Speaking Up details in our Code which is publicly available.
We disclose annually the number of speaking up cases, and what proportion were submitted via Safecall. We investigate all reported possible or actual breaches of our Code, and take appropriate action, including terminating contracts of staff and suppliers. We disclose annually the breakdown of such cases by category.