Sustainability & Ethical Practices.
At Nobel Upstream we are committed to maintaining the highest ethical standards in the personal and professional conduct of our employees, suppliers, contractors and consultants.
We seek to conduct our day-to-day business activities in a fair, honest and ethical manner. Every person connected with our company has individual responsibility for maintaining an ethical workplace. Managers and leaders throughout Nobel Upstream are also responsible for fostering a proper environment and encouraging ethical practices. Below, our codes of conduct, ethical policies and the standards to which we hold ourselves as company are available.
Our Anti-Bribery and Anti-Corruption Policy is supplemented by a framework of supporting policies, procedures and guidance. These include staff training, vetting and communicating our ethical standards to business partners, procedures in areas such as gifts & entertainment, donations and sponsorships, whistleblowing, monitoring and related matters.
Nobel Upstream also plans to host business partner forums to provide an overview of anti-bribery legislation, including the UK Bribery Act 2010.
The UK Bribery Act 2010 requires UK companies, or any foreign companies doing business in the UK, to ensure that all reasonable steps are taken to prevent acts of bribery. The Act, which applies to our business activities worldwide, is considered more onerous than the US Foreign Corrupt Practices Act (FCPA), which has resulted in many high-profile prosecutions in recent years. You can find an overview of some key features of the UK Bribery Act here.
The Bribery Act criminalises bribery in both the commercial and public sectors. It is not limited to bribery that could be committed by a company's own staff but also covers individuals or companies working on a company's behalf. Successful prosecution under the Bribery Act can lead to unlimited fines for companies and individuals and jail sentences of up to 10 years. The only defence against an act of bribery being committed by a member of staff or an individual or company working on our behalf is to have in place ‘Adequate Procedures' to prevent bribery. The UK Government, as a requirement of the UK Bribery Act, published their Adequate Procedures Guidance on 30 March 2011.
Our Code of Conduct applies to everyone within Nobel Upstream. It is expected that all permanent and contract staff will attend training sessions to ensure awareness of the Code and the requirements and procedures set out by it. All members of the Executive Leadership Team and the Board are expected to participate in training sessions that we provide to ensure a clear understanding the Code. Additionally, our Code of Conduct has been translated into Russian and Azerbaijani to make it more accessible in various jurisdictions where we operate.
We comply with all applicable local and international acts within the countries where we do business. Where differences exist between the standard of the law or regulations and the requirements of the Code, the higher standard will be applied. Nobel Upstream Legal actively works with leading legal and compliance practitioners to ensure that the most up to date guidance and tools are being used to shape and maintain the company's Ethics & Compliance programme.
At Nobel Upstream, we work with respect for the environment in which we operate and we identify, assess and manage our environmental risks.
Nobel Upstream firmly believes that sound environmental performance is key to ensuring sustainable business. By following this Policy, we will ensure that environmental risk management forms an integral part of our day-to-day working practices and alignment with our commitment to minimizing any adverse effects to the environment resulting from our business activities. To achieve this, we commit to:
In adhering to this Policy, we expect everyone to think about their role in managing environmental risks that exist in our business and, in particular, within their own area of responsibility and influence.
This policy shall be reviewed and updated periodically to ensure continual improvement and to take account of organisational priorities and changes, environmental legislation and industry best practice.
As a non-operator with risk management at the core of its business, Nobel Upstream is committed to the safety and operational integrity of all its projects. We have developed the guidelines below to ensure that we act in accordance with this commitment in achieving our business objectives.
We believe that it is possible to operate in a high-hazard business at an acceptably low risk of harm. We are committed to the prevention of major hazard accidents and also to the continuous improvement of personal safety and security.
We will seek, as described below, to ensure the health, safety and security of our own staff and of the people who operate the hydrocarbon production facilities in which we have a material ownership interest.
To demonstrate our commitment to this belief and to achieve our objective, Nobel Upstream will take the following actions across all leadership levels in our organisation:
Hold itself and its staff accountable and responsible for seeking to positively influence safety and operational integrity performance in any business where Nobel Upstream is a shareholder.
Monitor and seek to influence the safety performance of partners and operators through active participation in formal and informal onsite reviews of operations and through active dialogue and challenge.
Where necessary, establish and implement local policies for safety and operational integrity to ensure that all activities prevail at acceptably low levels of risk and comply with local laws and regulations.
Establish proven emergency response plans to promote prompt restoration of good order and restitution for all foreseeable events involving Nobel Upstream staff.
Ensure that all work related accidents and incidents involving Nobel Upstream staff, and/or staff within majority-owned businesses, are properly reported and recorded and, subsequently, investigated and lessons-learned identified.
Take action to prevent, reduce or control occupational health risks to an acceptable level and reduce the potential for ill health in the workplace.
We think that it is important to speak up, under appropriate circumstances, and encourage Nobel Upstream personnel to do so. We do not tolerate retaliation against good faith whistleblowers and take all claims of retaliation seriously.
We hope that in most cases Nobel Upstream personnel will be able to raise any concerns with their line manager or the CEO.
If any Nobel Upstream personnel feel that this has not addressed their concerns, or if they prefer not to raise their concerns with the management team for any reason, they can contact our 24/7/365 Whistleblowing Hotline.
Summaries of cases will be presented to the Audit Committee on a quarterly basis.
Nobel Upstream's external auditors are Ernst & Young LLP.
Ernst & Young LLP
1 More London Place
SE1 2 AF
Visit Website www.ey.com
A resolution to appoint Ernst & Young LLP as the company's auditors was passed by the Board of directors on 14 October 2014.