Our anti-bribery and corruption programme is based on the six principles of the UK Ministry of Justice’s ‘adequate procedures’ guidance. In 2014, we continued to deliver a number of compliance activities for each principle, including:
- Proportionate procedures – reviewing existing standards, procedures and guidelines; and launch of group standards covering per diems and expenditure related to public officials;
- Top-level commitment – discussing and generating the compliance strategy with the Compliance Committee; establishing a Ghana Compliance Committee to oversee work locally; and engaging with, and obtaining endorsement from, the Audit Committee and the Board;
- Risk assessment - monitoring the implementation of mitigation actions identified from formal corruption risk workshops
- Due diligence - designing and implementing a formal due diligence strategy covering contracting and procurement; asset acquisition and divestment; social investment, donations and sponsorships; recruitment; oil marketing; and new country entry;
- Communication (including training) - delivering workshops on the Code of Business Conduct to staff and suppliers; encouraging staff to report concerns via the ‘speaking up’ internal and external channels; and
- Monitoring and review – obtaining compliance certification from all staff; monitoring the gifts and hospitality and conflicts of interest registers; and conducting investigations of actual or suspected breaches of our Code of Business Conduct.
We also publish information on our commitment to zero tolerance of bribery and corruption on our website and in our public reports. In 2014, we were assessed by Transparency International as having scored 100% in ‘reporting on anti-corruption programmes’.
In 2014, we commissioned an independent review of our anti-bribery and corruption programme from GoodCorporation, an external provider of anti-corruption assessments. We registered an 85% improvement in the areas that had been identified as requiring action in the last review by GoodCorporation in November 2012.