Ethical business practices
Bribery and corruption exist in all parts of the world in varying degrees. Our Code of Business Ethics helps protect our reputation as a responsible and ethical business and seeks to eliminate the risk of bribery and corruption.
Complying with the UN Global Compact
Principle 10 of the UN Global Compact requires businesses to work against corruption in all its forms, including extortion and bribery. To meet our commitment to this principle we:
- have introduced anti-corruption policies and programmes throughout the organisation and our business operations;
- report externally on our work against corruption; and
- have joined forces with governments and industry peers through our membership of the Extractive Industries Transparency Initiative (EITI) to promote open and accountable management of natural resources (see Transparency).
Code of Business Ethics
Cairn’s Code of Business Ethics sets out the standards of conduct we expect all our employees to meet. It is the cornerstone of our anti-bribery and corruption procedures, and forms a key part of staff induction training. All employees are required to sign up to our Code of Ethics and comply with the behaviours set out in the code.
Cairn expects its employees, partners and suppliers to behave honestly, fairly and with integrity. In line with our business principles, we have adopted a zero tolerance approach to bribery and corruption.
Anti-bribery and corruption
Our anti-bribery and corruption management system (ABCMS) has been developed to manage such risks through all stages of the exploration and production life cycle. Country- and Company-level anti-bribery and corruption risk screening forms an important part of the decision-making process when entering new countries or negotiating with potential partners and major suppliers. We also subscribe to a number of due diligence tools, which enable us to complete comprehensive risk assessments of business partners, suppliers and other third parties.
As part of our ongoing commitment to establishing a culture of zero tolerance to bribery and corruption, we continued to deliver a series of training workshops across the Group in 2015. This included a bespoke ABC workshop delivered to all our Senegal employees. To supplement and enhance our approach to managing bribery risks in Senegal, we also worked with local specialists to provide additional support in conducting risk assessments and developing training material and procedures. In addition, an anti-bribery and corruption e-learning training module has been developed, which was rolled out to all staff and selected consultants in Q1 2016.
Employees trained in Cairn’s anti-corruption policies and procedures (%)
Through our whistle-blowing procedure, employees are encouraged to report any incident they believe may compromise our Code of Business Ethics. They can do this in a number of ways, including using a confidential phone line, or speaking directly to their regional director. Where appropriate, the procedures can also facilitate an independent investigation of any matters raised. The Group whistle-blowing procedure was reviewed and approved by the Board in December 2015.
Cairn is now registered with the whistle-blowing charity Public Concern at Work, which offers staff an alternative way of reporting an issue if they are not comfortable using internal procedures.
There were no reported incidents raised through the whistle-blowing procedure in 2015.
Our social investment projects are developed through a process of community engagement, consultation and participation and using a transparent decision-making process that aims to ensure that any payments made are aligned with our Business Principles and comply with our ABCMS (see Transparency).
Monitoring and checking procedures
Cairn has a well-developed framework in place to ensure compliance with national laws and conventions. Regulatory approval for our activities is often granted subject to specified conditions and in accordance with local requirements and the terms laid down in our Corporate Responsibility Management System (CRMS). We maintain compliance registers to monitor activities and ensure compliance with these conditions.
At an operational level, regional directors are accountable for all activities within a given region, supported by health, safety and environment (HSE) personnel who advise on CR regulations, permits, and developing and implementing asset CR plans. Employees are encouraged to be vigilant about reporting any actual or potential risks and non-compliances.
At a corporate level, assurance in 2015 was provided by the Risk and Compliance department. This is often supported by peer reviews, benchmarking against standards, government audits, internal audits and appraisals from potential lenders.