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.
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.
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.