Anti-Corruption/ Business Conduct and Ethics Policy

Transcription

1 Anti-Corruption/ Business Conduct and Ethics Strict compliance with the provisions of the Company s Code of Business Ethics and Conduct and the Anti-Corruption and it s annexures is mandatory for all directors, staff, contractors and agents. It is therefore essential that all personnel familiarize themselves with their requirements. Anti-Corruption : It is the policy of Seven Energy International that all of its officers, directors, employees, contractors, consultants and agents representing Seven Energy International and all of its subsidiaries and affiliates (collectively, the Company ) shall comply fully with all applicable provisions of the United States Foreign Corrupt Practices Act of 1977, as amended ( FCPA ), the U.K. Bribery Act of 2010 ( UKBA ) and all other equivalent anti-corruption and/or anti-bribery legislation applicable to the Company (whether by virtue of its jurisdiction of incorporation or the conduct of its business operations). Business Conduct and Ethics : It is the policy of Seven Energy International to conduct its business in accordance with applicable laws, rules and regulations, with honesty and integrity, in a manner which demonstrates respect for local cultural and ethnic customs, and with a strong commitment to the highest standards of ethics. We demand high standards of integrity and sound ethical judgment from our personnel at all times. Each officer, director, or employee of the Company shall annually certify that he or she: (i) has read the Code of Business conduct and ethics, (ii) has not violated any requirements thereof during the preceding year, and (iii) is not aware of any material violation of the Code s requirements by any other person. Comply with the provisions of the United States Foreign Corrupt Practices Act of 1977, as amended ( FCPA ), the U.K. Bribery Act of 2010 ( UKBA ) and all other equivalent anticorruption and/or anti-bribery legislation applicable to the Company (whether by virtue of its jurisdiction of incorporation or the conduct of its business operations). Communicate the requirements through different channels to all personnel. Ensure documentation of all policies and procedures in a manner that makes them readily accessible to and easily understandable by all stakeholders Provide training and guidance to all staff and other stakeholders to ensure they meet the Company s goal of conducting business in an ethical manner. Entrench a culture that is characterized by our employees tradition of doing the right thing and abiding by the rule of law.

2 Quality Management Quality Management Seven Energy International (the Company ) aims to improve Quality Assurance and Control by implementing a Quality Management System that meets the criteria outlined in the International Standard for Quality Management Systems (ISO 9001:2008). In addition to following international best practice, Seven Energy commits to meeting all Statutory and Regulatory requirements wherever the company operates. Seven Energy International determines company activities by stating specific objectives on an annual basis (Management by Objectives). The degree to which each objective has been met will be evaluated against the QMS. Subsequently, the QMS forms the overall framework for all operations within Seven Energy. Strict compliance with the Quality Management System is mandatory for all personnel employed by Seven Energy International. It is therefore essential that all personnel familiarize themselves with the policies contained within the QMS and operate according to those policies. Comply with legislation and associated codes of practice and improve on performance standards by adopting a risk-management approach to design, construction and production operations. Communicate through awareness training the objectives and requirements of the QMS to all personnel. Ensure documentation of all policies and procedures in a manner that makes them readily accessible to all personnel and company/community stakeholders. Provide training, supervision and support to all staff to ensure they meet company goals. Implement a framework for internal audits and management reviews for continuous improvement of the QMS. Set objectives and targets for monitoring and measuring the effectiveness of the QMS.

3 Corporate Social Responsibility Corporate Social Responsibility Integral to Seven Energy International s (the Company ) Business Plan is the objective to be the preferred partner for the communities in which we operate. Our investment in community programs demonstrates our commitment to improving opportunities and living conditions in host communities. We are committed to making a positive social contribution and minimizing environmental impacts. Undertake consultation with the host communities to assist in identifying and evaluating environmental and social impacts along with risks and opportunities. Adopt and comply with a risk mitigation hierarchy to anticipate and avoid risks and impacts to workers, affected communities and the environment. Where avoidance is not possible risks and impacts will be minimized. If residual impacts remain for workers, communities and the environment compensatory procedures will be implemented. Promote and provide the means for effective engagement of host communities about issues that affect them and to ensure that relevant project information is disclosed and shared in a timely and transparent manner. Ensure that grievances from host communities and other stakeholders are responded to, managed and resolved to the satisfaction of all parties. Promote improvements in the environmental and social performance of contractors and service providers through the use of appropriate management systems, processes and procedures. Identify local and indigenous communities and the manner in which their traditional cultural heritage may be impacted by company projects and address potential community and stakeholder concerns. Develop partnerships with communities, non-government organizations and local government to foster sustainable development and enhance economic benefits in host communities.

4 Asset Protection Asset Protection Seven Energy International (the Company ) is committed to providing a safe and secure working environment for all personnel. The Asset Protection is designed to protect a wide variety of company assets including tangible assets such as property and personnel. Intangible assets such as corporate information and company reputation are also included within this policy. Seven Energy International seeks to remove or reduce these risks to a level as low as reasonably practicable (ALARP). Identify and regularly assess security threats to business operations and assess and manage risks. Develop and maintain effective asset protection processes to mitigate or minimize identified risks by using proactive and cost effective measures. Protect all company assets including personnel, property, corporate reputation, business information systems and key business processes from harm. Conduct asset protection operations in accordance with national legal requirements, international standards and company policies. Record, investigate and evaluate all reported security incidents and irregularities to prevent any recurrence and improve the effectiveness of the Asset Protection.

5 Health, Safety and Environmental Health, Safety and Environmental The health and safety of all employees and company/community stakeholders and minimizing environmental impacts is of primary importance to Seven Energy International (the Company ). Company operations are at all times directed by a Health, Safety and Environmental that reflects best industry practice. Continual improvement in HSE performance is critical to the overall success of the company. To ensure continual improvement in HSE performance, upper management regularly evaluates personnel awareness and compliance with HSE policies. Lessons learned are communicated to all employees and modifications to HSE practices are made if necessary. HSE performance is a core value in our business and all Seven Energy International employees are accountable for its delivery. Identify HSE hazards arising from all business operations and mitigate the associated risks to a level as low as reasonably practicable (ALARP). Comply with all applicable national and international legislation and associated codes of practice and improve on the performance standards within applicable codes by adopting a risk management approach to the design, construction and operation of facilities. Minimize impact on the environment through pollution prevention, reduction of emissions and the reduction, re-use and recycling of waste materials, where applicable. Ensure that all employees and contractors are aware of their responsibility to comply with HSE policies and to communicate HSE issues and performance to all stakeholders to ensure continual improvement. Provide direction, training and appropriate supervision to enable all employees and contractors to meet their responsibility to work safely and with consideration for the health and safety of others and the environment. Require contractors and partners to demonstrate they are operating in full compliance with the HSE policy mandated by Seven Energy International. Make available leadership, management and other appropriate resources to implement the HSE policy and publicly report on HSE performance.