2011 Annual Report - SBM Offshore
2011 Annual Report - SBM Offshore
2011 Annual Report - SBM Offshore
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3.9 Sustainable Initiatives<br />
3.9.1 Code of conduct and Anti- corruption policy<br />
As a growing global business, <strong>SBM</strong> <strong>Offshore</strong> is committed to conducting its business honestly, ethically, and<br />
lawfully. It recognises the importance of ethical compliance and has reinforced its compliance programme around<br />
the world throughout <strong>2011</strong>.<br />
Reinforcing <strong>SBM</strong> <strong>Offshore</strong>’s ethical standards<br />
The Company has updated its Code of Conduct to match the requirements of the UK Bribery Act. It has also<br />
published an Anti-Corruption Policy & Compliance Guide, which provides <strong>SBM</strong> <strong>Offshore</strong> employees, partners,<br />
agents and subcontractor/suppliers with concrete guidelines on how to prevent corruption risks and deal with<br />
those that arise. All employees are required to adhere to the Company’s ethical standards. They must comply<br />
with all applicable laws, and accurately record, and track transactions. Any non-compliance with required Ethical<br />
Standards is subject to disciplinary sanction. Employees, including all key personnel, receive yearly training on<br />
the Company’s Business Ethics, including anti-corruption laws and practices. During <strong>2011</strong>, the Company decided<br />
to supplement this training with an e-learning training dedicated to anti-corruption laws, notably the U.S. FCPA<br />
and UK Bribery Act. To date, 98% of all employees required to do so have completed the e-learning course.<br />
Bribery and corruption<br />
In <strong>2011</strong>, the Company updated its ethical standards to comply with the requirements of the UK Bribery Act, as<br />
follows: “The <strong>SBM</strong> <strong>Offshore</strong> Code of Conduct specifically prohibits the payment (directly or indirectly) of anything<br />
of value to a public official or a commercial decision maker to secure an improper business advantage”.<br />
The Anti-Corruption Policy and Compliance Guide re-iterates this standard and provides detailed steps for<br />
employees to take if faced with corruption risks. The Company also ensures all transactions are properly<br />
authorised and accurately and completely recorded.<br />
Business Relations<br />
The Company makes it an essential requirement to maintain good business relations with partners, agents,<br />
supplier and other intermediaries. A good relationship requires trust and an understanding of one’s business<br />
partners. Consequently, due diligence is carried out for all potential partners, agents, suppliers and other<br />
intermediaries.<br />
During <strong>2011</strong>, the Company continued its campaign to implement anti-corruption due diligence on all agents,<br />
freight forwarders, partners and major suppliers, completing 79 due diligence studies, with more currently<br />
underway.<br />
The Company ensures that its relationships with intermediaries are formalised by written agreement by using<br />
template agreements that clearly document its policies covering corruption, conflict of interest situation, and<br />
compliance with applicable laws and regulations.<br />
The Company requires that its intermediaries maintain accurate books and records and grant it the right to audit<br />
them. All business relationships are approved in accordance with internal procedures and the agreements are<br />
reviewed by the Company’s Legal Department. The Company also shares both its Code of Conduct and<br />
This is a customized selection from the <strong>SBM</strong> <strong>Offshore</strong> N.V. <strong>Annual</strong> <strong>Report</strong> <strong>2011</strong><br />
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