ESG investors

Environmental Management System

Tullow operates an ISO 14001 certified Environmental Management System in its London Headquarters and by doing so demonstrates via external assurance that the systems and processes which we apply to our business in the management and determination of environmental risk are robust.

Protected areas

We identify and assess risk throughout the project lifecycle and have publicly committed to stringent evaluation prior to determining whether to conduct operations in areas of natural or cultural sensitivity. Specifically:

• Tullow will not operate within designated UNESCO World Heritage areas in line with the public commitment made in 2015
• Tullow will risk assess the potential impact of our operations in areas adjacent to UNESCO World Heritage areas as part of the decision-making process prior to any activity
• Tullow will seek Board of Director approval for proposed activities in IUCN Category I-IV protected areas, Ramsar Wetlands and Natura 2000
• Tullow will publish annually a list of these protected areas within which there are Tullow operations

Biodiversity impacts

Tullow accepts its responsibility to comply with applicable biodiversity protection laws and regulations in areas where we operate.  We therefore endeavour not to adversely impact biodiversity and natural habitats through our presence and operations. Specifically, we have committed to:

• Ensuring that areas of high-level environmental risk related to biodiversity and natural habitats continue to remain an integral part of project reviews, and project ‘go/no go’ decision-making processes
• Assessing the impacts of our activities on biodiversity and natural habitats and implementing mitigation initiatives, taking into account the overall scope and scale of our operations
• Maintaining transparency in our decision-making and approach to biodiversity issues in relation to our operations
• Align our Development planning work to IFC PS6
• Engage with expertise and industry initiatives that further our understanding of biodiversity assessment and mitigation

In Kenya, for example, Tullow has committed to undertaking assessments of potential impacts on biodiversity features and ecosystem services to meet national permitting requirements, Tullow requirements and Good International Industry Practice (GIIP) as described in IFC Performance Standard 6. The Biodiversity Management Framework for our Kenya operations is published here.

Climate change

Tullow acknowledges the global threat posed by climate change and recognises the need to reduce greenhouse gas (GHG) emissions. We accept our responsibility to comply with emerging climate change legislation and regulation, and to reduce our GHG emissions as far as is reasonably practical through appropriate initiatives.

As an Africa-focused company, we appreciate that emerging oil and gas producing nations are confronted with complex trade-offs to negotiate, as they seek to maximise the value of their natural, human and financial resources, whilst building the foundation for a lower-carbon future. Tullow is also aware of the increasing demands for transparency by stakeholders on demonstrating how climate considerations are accounted for within business decisions.

Tullow is committed to aligning with the actions that our host Governments take to manage the impacts of climate change, and we will continue to support them in this area.

Demand for energy is forecast to grow, and we expect fossil fuels to continue to play a role in the global energy mix over the coming decades. We will continue to support our host Governments as they seek to use oil revenues to promote sustainable and inclusive economic development, and we will align with the actions that they take to manage climate change. Specifically, Tullow will: -

• Aim to minimise the GHG emissions potential of our activities and implement appropriate reduction initiatives, considering the overall stability of our operations
•  Adopt a business strategy that is responsive to applicable legal and regulatory developments designed to address climate change
• Maintain transparency in our performance reporting and openness in our engagement about climate change

Carbon pricing

Given the established fossil fuel asset base and the ever-increasing demand for secure, low cost energy, we expect oil and gas to continue to play a vital role in meeting the world’s energy requirements for decades to come.  Tullow’s assets in West and East Africa are low-cost sources of fossil fuels, which remain economic, even at lower oil prices, and carbon pricing assessments are designed to help Tullow consider ways to future proof our developments.

We recognise that evolving legislation aimed at reducing GHG emissions may, over time, have an impact on demand/prices, and we are actively seeking to anticipate and respond to this change, for example by applying notional carbon pricing to test the viability of major capital projects for Full Field Developments (as outlined above).

The process for calculating the Net Present Cost of GHG emissions over the lifetime of new projects is set out in our IMS Investment Appraisal Standard, making it an integral part of Tullow’s financial appraisal process for new developments.

We are committed to adopting a business strategy that is responsive to applicable legal and regulatory developments designed to address climate change, and Tullow’s Non-Technical Risk Standard requires that for all new developments, greenhouse gas emissions are estimated over the lifetime of the project.  The Net Present Cost (NPC) of these emissions must be calculated by using a shadow carbon price.  We use a shadow carbon price of $40/te of CO² equivalent emissions to calculate the NPC, a value which is in line with industry standards.

Energy consumption, Scope 1 emissions, and methane emissions

Over 95% of Tullow’s energy consumption and Scope 1 emissions come from our two offshore operated assets in Ghana (Jubilee and TEN), the two main areas of emissions1 being gas flaring and energy consumption.   

Tullow has over the years disclosed data on our energy consumption and Scope 1 emissions in our Annual Report & Accounts and other required external reports including the Carbon Disclosure Project and International Oil & Gas Producers association. Last year, we responded to specific requests from the International Energy Agency through IPIECA and disclosed our methane emissions data and basis of reporting.  Of our total carbon emissions, 98% are driven by flaring, 2% of which are in relation to fugitive emissions. We continually assess our operations to seek opportunities to reduce the flaring levels via process or procedural controls and continue to seek opportunities for further reductions in Jubilee and TEN FPSO’s.

Tullow is committed to minimising the GHG emissions potential of our activities and implement appropriate reduction initiatives, considering the overall stability of our operations.  Our Non-Technical Risk Standard sets out mandatory requirements for managing emissions on existing facilities, which includes monitoring and reporting of energy use, quantified inventories of GHG emission sources, operationally and financially viable energy optimisation2. 

Industry-specific pollutants (NOX, SOX, VOCS, PM)

At our operational sites, we record and trend our air emissions performance with regards to the above-mentioned industry pollutants. We conduct periodic third party or internal stack emissions monitoring and air quality monitoring and compare the results of this to emissions guidelines including those of World Health Organisation, the US Environmental Protection Agency and the International Finance Corporation.  In Ghana, we took additional steps of conducting air quality monitoring in the coastal communities adjacent to the location of our offshore assets. This study concluded that our offshore activities had no effect on ambient air quality in the onshore coastal communities.

Water risk management

Tullow recognises that water is a critical and limited natural resource, essential to life, health and sustainable social and economic development.  Water is also a key component of Tullow’s operations and as such we accept our role in the responsible and efficient use of this scarce resource.

Tullow commits to identify, monitor and mitigate impacts on water supplies associated with our operations. Locations deemed as high risk will have detailed water management plans in place in line with the requirements of our Safe and Sustainable Operations Policy. We commit to engaging with all stakeholders to improve our understanding of the most effective ways to manage this important issue.

Water risks, and how we manage them, differ depending on the geographical locations of our projects. In our Kenya development, water utilisation is a primary focus of the development concept and as such requires both a robust technical solution but more importantly one that is inclusive the needs of the community within which we operate including the potential for shared infrastructure.

Crisis and Emergency Management

Requirements for Crisis and Emergency Management (CEM) are set out in the Integrated Management System (IMS). CEM arrangements are long established and embedded in business operations, ensuring that Tullow is suitably prepared, resourced and equipped to respond effectively to emergency and crisis situations and mitigate the impact on people, the environment, assets and reputation.  This reflects the policy commitment set out by our CEO in his Safe and Sustainable Operations Policy Statement.

Agreed plans, procedures and resources are in place that cover all operational activities, ensuring that they are ready to respond to any major emergency.  These plans are based on credible emergency scenarios, identified during the Environmental and Social Impact Assessment process or the Business activity risk assessment, and follow the mandatory requirements of the Group Emergency Preparedness Standard.  They also align with Best Industry Practice e.g.  IPIECA Oil Spill Response - Joint Industry Project.  The International Finance Corporation’s investment agreement requires both our Ghana and Kenya projects to achieve compliance with the IFC Environmental and Social Performance Standards and audit Tullow against these guidelines.

A programme of training and regular exercises and testing are in place to ensure response plans are properly understood and will work in the event of an emergency.  Emergency response plans, equipment and resources are reviewed annually. As part of the management of change process any change to the nature of operational activity or change in regulatory or Company requirements will result in the evaluation of associated risks or availability of response resources or equipment is evaluated and identification of any key lessons during training exercises or response to real events.

The Group communicates information about our operations and ambitions to ensure stakeholders understand the Group’s business and can ask questions and make decisions in an informed way.  Group policy requires that grievance management mechanisms, including location-specific grievance management procedures are established.
  

Occupational health and safety

We are committed to ensuring our colleagues and host communities are kept safe and well, and to raising awareness of potential dangers related to our operations and locations where we operate. We ensure colleagues have access to affordable healthcare and aim to achieve top quartile industry performance on our occupational safety measures. We also protect our colleagues and assets with robust emergency plans.
  

Contractor EHS management

At Tullow, we recognise that contractors play a critical role in our EHS performance.  A significant proportion of all hours worked on our activities is by contractors and hence managing contractor performance is key to reducing our EHS incidents. 

Tullow has therefore developed processes to ensure that EHS risks are identified and managed throughout the contract lifecycle.  Developing close working relationships with our contractors to build a common EHS culture forms part of these processes. Specifically:

• Tullow identifies key risks associated with contractor activities and manages the contract scope and specifications to mitigate those risks.
• Tullow assesses the EHS records and capability of potential contractors as part of the contractor selection process.
• Tullow actively manages contractor performance with focus on EHS performance throughout the contract duration
• Through combined contractor forums establish networks to share lessons and collectively discuss EHS performance and improvement opportunities

Process safety management

Tullow ensures that all hazards that can lead to major accidents are identified and takes all measures necessary to prevent major accidents and to limit their consequences for human health and the environment. Tullow reduces the risks of major accidents to As Low As Reasonably Practicable (ALARP). We make appropriate preparations to respond to emergencies including any consequences beyond the site boundary. We also maintain transparency both internally and externally in our performance reporting on asset integrity management.
 

Human rights

As laid out in our Human Rights Policy, approved by the Board and signed by our Chief Executive Officer, Tullow is committed to respecting internationally recognized human rights and seeks to implement the U.N. Guiding Principles on Business and Human Rights and the Voluntary Principles on Security and Human Rights. Everyone who works for, or on behalf of, Tullow is responsible for ensuring that this policy is implemented. To achieve these goals, we commit:

• To identify and address human rights risks upon entering a new country or region, and on an ongoing basis, and conduct human rights due diligence before significant investments
• To avoid causing or contributing to adverse human rights impacts, and to remediate any adverse impacts that we cause or to which we contribute and take all feasible steps so that our operations are not directly linked through our business relationships to adverse impacts on human rights
• To engage meaningfully with and obtain broad, community support from impacted communities throughout the project life cycle, including, where appropriate, using traditional community governance mechanisms and obtaining the perspectives of vulnerable groups, including women
• In a form appropriate to the circumstances, to obtain the informed agreement of project-affected communities early in the project cycle, and prior to major project developments or changes that would significantly affect them
• To avoid or, where that is not possible, minimise involuntary physical or economic resettlement and provide compensation for loss of assets, and improve or restore the livelihoods and standards of living of people resettled
• To ensure that affected communities have access to a transparent and fair non-judicial project-level grievance mechanism which operates in a timely and predictable manner; and
• To respect fundamental labour rights and international labour standards, as set out in the Universal Declaration of Human Rights and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work

We apply this policy in all our operations and take steps to encourage our non-operated business partners to apply this Policy, or an equivalent policy. We expect our contractors to respect human rights and adhere to this Policy and encourage our suppliers to do so as well.

Modern slavery

Tullow is committed to respecting internationally recognised human rights, including fundamental labour rights and international labour standards as set out in the Universal Declaration of Human Rights, and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work.  We recognise that the nature and context of our business and supply chain exposes Tullow to the potential risk of instances of modern slavery and human trafficking, including underage, forced or bonded labour.  Specifically, we: -

• Work to regularly assess the extent of this risk to our business
• Take steps to ensure that underage, forced or bonded labour have no place in Tullow’s business or supply chain

Our annual Modern Slavery statement provides an ongoing assessment of identified risks and our efforts to address these.

Voluntary Principals on Security & Human Rights

Tullow is committed to respecting internationally recognised human rights and seeks to maintain the safety and security of our operations within the framework of the UN Guiding Principles on Business and Human Rights.

We recognise the importance and benefits of the Voluntary Principles on Security and Human Rights as the leading international standard for identifying, mitigating and managing the human rights challenges faced by extractive companies in their global operations. We seek to meet our responsibilities in security and human rights by implementing the practical guidance provided by the Voluntary Principles, to which we are a signatory, through:

• Early identification of potential security and human rights related risks and issues
• Promoting respect for human rights
• Ongoing implementation of those principles
• Regular monitoring to identify and address gaps in the effectiveness of our approach

Success in managing these risks in the long term, relies on collaboration with host nations, and engagement with local communities.

Free, Prior & Informed Consent  

Tullow looks to engage with and obtain the informed agreement of project-affected communities early in the project cycle and, subsequently, prior to major project developments or changes that would significantly affect them.  We recognise however that in certain circumstances we will be required to achieve the Free, Prior and Informed Consent of potentially impacted communities. Specifically, Tullow will engage in a manner following the principle of FPIC when:

• The regulatory framework of the host country recognises specific Indigenous Peoples and these Indigenous Peoples have been identified as part of the project-affected population; or
• Indigenous Peoples, as described under IFC Performance Standard 7, are identified as affected persons in a project ESIA; and
• Our operations would affect the traditional lands, natural resources, livelihoods or cultural heritage of Indigenous Peoples as described above; and/or
• We are required to do so under the laws of a host country or through our commercial relationship with project lenders or project partners.

Tullow understands FPIC as both a process involving recognition of, and engagement with, Indigenous Peoples, together with an outcome, i.e., an agreement.

Physical & economic displacement

Tullow’s operations, onshore and offshore, have the potential to impact on local stakeholders’ ownership, access and use of land and other natural resources. These impacts may be associated with physical and / or economic displacement, such as adverse impacts on livelihoods, and Tullow is committed to working with relevant authorities and impacted communities to avoid or, where that is not possible, minimise involuntary physical or economic resettlement.  We also commit to providing compensation for loss of assets, and to improving or restoring the livelihoods and standards of living of people resettled. To achieve this, Tullow will:

• Avoid or, where that is not possible, minimise involuntary physical or economic resettlement
• Provide compensation for loss of assets and improve or restore the livelihoods and standards of living of people resettled

Voluntary social economic investment

Tullow recognises that as a part of our commitment to being Africa’s leading independent oil company, we have a role to play in promoting sustainable social and economic benefits in the countries where we operate. To help achieve this we invest on a voluntary basis in the following three areas:

• Capacity building through education and skills development, specifically in Science, Technology, Engineering and Mathematics (STEM) to prepare people for jobs in the economy
• Strengthening the local economy through activities that support the growth of local businesses
• Investing in shared infrastructure and logistics by adapting and leveraging existing Tullow infrastructure plans and projects for our business to benefit host communities

We prioritise these three areas to align with national and local priorities, deliver benefits in a meaningful and measurable way and generate value for our business. Tullow will always have a role to play in creating Shared Prosperity and leaving a legacy of sustainable social and economic benefits in the countries where we operate. Tullow believes the best projects will be those that are linked to Tullow’s business drivers, create measurable socio-economic benefit and are aligned to national and local priorities.

Community involvement & stakeholder engagement

Tullow’s community engagement strategy to manage risks and opportunities associated with community rights and interests, including risk of project delays. Tullow’s Non-Technical Risk Standard requires the development and implementation of a Community Engagement Plan that is scaled to project risks, potential impacts and the stage of a project.  The plan must describe how potentially affected communities will:

• Be engaged in the conduct of Environmental & Social Impact Assessments, Human Rights Impact Assessments and other assessments of impact and risk
• Be provided with access to timely, relevant, understandable and accessible (i.e. culturally appropriate, including local language) information
• Be able to provide input into project design, scope, impacts and mitigation measures, prior to the start of project activities and on an ongoing basis throughout the life cycle of the project
• Be communicated with on progress in implementing any impact mitigation measures. A commitment register is to be established to track, report and record progress.

The Standard also requires the establishment of a Grievance Mechanism that is compatible with the level of risks and impacts associated with a Project’s activities, to facilitate the resolution of any grievances arising in relation to the company’s activities, prior to conducting operations. The Stakeholder Engagement Framework for Tullow’s operations in Kenya can be found here. 

For more information on our community engagement activities in Ghana, please see the IFC Independent Monitors Review Report here.

Labour practices

Tullow has made a commitment in its Human Rights policy to respect fundamental labour rights and international labour standards as set out in the ILO’s Declaration on Fundamental Principles and Rights at work.

Employee collective bargaining agreements

Tullow does not have collective bargaining agreements; however, we do communicate via various means - Town Halls, executive-led Tullow in Focus sessions etc. Different offices have different staff engagement groups, for example our Ghana office has an Employee Engagement Forum. Team and group updates are held regularly, and updates given via the Intranet and Yammer.

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. 

Government lobbying

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

Board diversity

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.

Performance data for 2020