2012 Sustainability selection - SBM Offshore

framework of its supplier qualification process.
3.7.5 Communications and Training
Employees of SBM Offshore are continually informed about the importance of ethical behaviour and compliance.
Senior management regularly issue statements promoting compliance at events, as well as in internal print and
online media.
In addition, the Group provides a comprehensive programme of compliance training. In 2012, 3,077 employees
received web-based training on the prevention of corruption, and 1,027 employees received in-depth classroom
training provided in 23 sessions on corruption prevention.
3.7.6 Point of Contact
Employees of SBM Offshore are encouraged to contact the Compliance Department to seek clarification or to
report any concerns regarding compliance. In addition, employees can raise concerns anonymously by calling the
SBM Offshore Integrity Line. The Integrity Line is a hotline operated by an external provider and available in all
relevant languages for employees wishing to bring to the attention of management any perceived breaches of
SBM's Code of Conduct and other procedures. Since its inception, 2 incidents were reported which were
investigated.
3.7.7 Risk Assessment
In 2013, the Compliance Department will perform a systematic risk analysis, including of Execution Centres and
other entities within the Group. Key aspects to be analysed and evaluated will include perceived geographic
exposures to compliance risks, the control environment, and business processes typically exhibiting higher
corruption risks as well as the robustness of any mitigating controls and processes which are in place.
3.7.8 Internal Controls
SBM Offshore is committed to ensuring that its anti-bribery related polices and guidelines are properly applied
and monitored throughout the Group. The Group will therefore supplement its current internal control framework
by additional anti-bribery specific controls. The proper execution of these controls will be tested by the Group’s
Internal Audit Function.
3.7.9 Regulatory Compliance
The Regulatory Compliance Function has created a process to ensure that the offshore facilities of all Group
Projects comply with all applicable conditions of project regulatory approval, host government regulations,
statutes, and permitting requirements. Once established, all applicable regulatory requirements are shared with
relevant functions such as engineering, construction, supply chain and HSE. Regulatory Compliance also
coordinates the activities of the functions involved to safeguard that projects conform to all regulatory
requirements throughout their lifecycle.
In some cases external providers are used to acquire the necessary understanding of the requirements under
some regulations and to provide specialist advice where needed.
The Regulatory Compliance Function also has responsibility for coordinating the Classification process.