We have strong corporate governance practices and disclose our payments transparently.

We are committed to comply with laws and regulations and wherever we do business, maintain ethical conduct, uphold human rights and maintain strong community relationships.

Tullow has always operated to the highest standards of corporate governance and, as a publicly traded company, the need for transparency and accountability is extremely important.

We have zero tolerance for bribery, corruption and other financial crime and we explicitly prohibit behaviours that do not align with our Values or are not consistent with fair, respectful and decent business practice. A key tool for the Board of Directors and our Executive Management to meet these requirements is our Code of Ethical Conduct. The Code is periodically reviewed and updated as our business environment evolves, and the last update was in 2018. All our staff receive annual training in the provisions of the Code and in 2019, 100 percent of Tullow employees, including our Executive Management and members of our Board of Directors, completed this training and certification.

Additionally, we require our suppliers to uphold the Code of Ethical Conduct and our contractual agreements include ethics and compliance clauses covering these requirements. Prior to engaging with suppliers, we conduct risk-based, third-party due diligence on matters relating to ethical conduct including specifically, anti-bribery and corruption, sanctions and trade restrictions and human and labour rights.

We encourage our colleagues, or others, to report suspected breaches of the Code through our Speaking Up process. This is available through internal channels or via our external provider, Safecall. In 2019, there were 87 cases, all of which were investigated, and appropriate action taken. Nine people left the organisation due to confirmed breaches of the Code.

Tullow believes that public disclosure about our business and actions serves a broader agenda of openness to dialogue and builds accountability, credibility and trust. Transparency regarding payments to governments is an important way to promote honesty in our industry, mitigate corruption and support inclusive development. In 2019, we further improved the clarity of our payment disclosures by using a common basis for reporting across different countries.

Tullow has been a corporate supporter of the Extractive Industries Transparency Initiative (EITI) since 2011, and we play an active role in the development of new programmes and initiatives.

We support national EITI membership in the regions in which we operate and are keen to take an active role in supporting the national application process, which can take two years or more to complete. In 2019, we contributed to Suriname’s EITI application, by assisting in the development of the terms of reference for multi-stakeholder consultations and advising on different aspects of the process. We are also supporting the government of Uganda in its application for EITI membership.

In 2019, we attended and supported EITI’s eighth global conference and underlined our support for contract transparency which will be required by EITI from 2021. Tullow continues to publish Production Sharing Agreements (PSAs), with the agreement of our government partners.

In addition to our engagement with EITI, in 2019, we continued our collaborations with other groups to improve transparency and accountability in our industry. For example we have worked with the Centre for Global Development, contributing to the development of a set of generic commercial transparency principles in government contracts.

Our 2019 disclosure: total socio-economic contribution the past five years, our socio-economic contribution has reached more than $4.6 billion, of which close to $2 billion was tax revenues paid to our host governments. This sustained contribution continues to support social development and inclusive economic growth in regions where such revenues are badly needed.

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Specifically, our total payments made to the Ghanaian Government in the 2015-2019 period amounted to $1.2 billion, including $270 million in 2019.

Tullow has been a formal part of the Voluntary Principles on Security and Human Rights (VPs) since 2013. The principles play a vital role in bringing governments, companies and NGOs together to maintain the safety and security of our operations while ensuring respect for human rights and fundamental freedoms. The principles guide the way we work with national naval, military and police forces and other relevant bodies.

In Ghana, we have led the implementation of the VPs. Specifically, we work with the Ghanaian navy to protect our offshore facilities, and we used the VPs approach to engage with local fishermen to develop a safe sea access framework. This has provided a way for them to operate safely in the areas around our offshore facilities while reducing incursions into the safety zones.

In Kenya, we work with the Kenyan Police Service to manage the security of our sites and have engaged with local communities to assure their support and collaboration, while addressing their concerns and expectations. With private security companies, we have applied the VPs and included the requirements of the International Code of Conduct Association in our contracts with service providers. In particular, in 2019, we are working with a local private security company in an innovative model that uses support from an international security company to help to develop local capacity to meet international standards. In 2019, we participated in a round table discussion at Geneva Peace Week. The discussion centred on the risks and opportunities of private security in building peace and security.

In 2019, TISC Report, an independent monitor of Modern Slavery Act disclosures in the UK, confirmed that Tullow’s disclosure ranked in the top 9.3 per cent of companies for meeting the minimum disclosure criteria.

Strong community relationships are central to our success wherever we operate and we update host communities and engage with them on a regular basis. We maintain formal grievance mechanisms which ensure all issues raised are addressed in detail until they are resolved.

In particular, our development plans always include comprehensive Environment and Social Impact Assessments (ESIAs) incorporating detailed Stakeholder Engagement Plans (SEPs). These cover consultation with a range of local and national stakeholders including: government representatives, non-governmental organisations, civil society organisations, faith-based organisations, local communities, academia and media stakeholders.

In 2019, we published our proposed SEP for the ESIA for the foundation stage of the South Lokichar development for upstream oil production from a number of wells in this region of Kenya. This development is significant for the region as it will substantially increase the number of wells we operate as we transition from the exploration stage to production. The SEP sets out both the regulatory frameworks governing stakeholder engagement and the process of consultation that provides affected stakeholders with opportunities to express their views on project risks, impacts and mitigation measures. Following feedback on the proposed SEP, we expect to start the engagement and consultation process in 2020.