The Baker Panel Report - ABSA

BP CODE OF CONDUCTThe Code of Conduct provides a starting point for the conduct expected of BP employees. 12 All employees must follow the Code of Conduct, andsupervisors must also promote, monitor, and enforce compliance with it. 13 The Code of Conduct contains a two-page section addressing thehealth- and safety-related conduct of all BP employees and anyone else working at BP facilities. 14 It provides that “[n]o activity is so importantthat it cannot be done safely” 15 and emphasizes that “[s]imply obeying safety rules is not enough. BP’s commitment to safety means each of usneeds to be alert to safety risks as we go about our jobs.” 16 The Code of Conduct does not make reference to specific BP standards, practices, orexpectations; instead, it contains a list of basic rules that all employees must follow. 17 These basic rules include practices that might bedescribed as axiomatic, such as “stop any work that becomes unsafe” and “make sure you know what to do if an emergency occurs at yourplace of work.” 18GETTING HSE RIGHTGetting HSE right (gHSEr) describes the BP HSE Management System Framework and represents how BP intends to meet its HSE performancecommitment. It sets forth the Group’s expectations for the health, safety, and environmental practices of its business units. 19 These HSEexpectations “encompass the complete spectrum of health, safety[,] and environmental risk management including personal security,technical/operational integrity of facilities and equipment, and product stewardship.” 20 gHSEr represents “the boundaries within which all BPmanagers must operate” and is mandatory for every business unit. 21According to BP, an HSE management system containing the gHSEr elements should ensure continuous improvement of the business unit’s HSEpractices through a “Plan-Perform-Measure-and-Improve Cycle.” 22 Each business unit is then responsible for designing an HSE managementsystem that meets all of the relevant BP Group-wide expectations set out in gHSEr. 23BP’s HSE expectations are presented in gHSEr’s 13 Elements of Accountability, which provide expectations in the following areas: Leadership and accountability. Managers must develop, document, and implement HSE management systems in accordancewith HSE expectations. Risk assessment and management. Managers must assess, document, and reference risks in their decisions. People, training, and behaviors. HSE responsibilities should be assigned by managers to individuals, and managers mustdocument those responsibilities and create performance targets. Working with contractors and others. Contractors must be supervised, and this includes reviewing their HSE policies. Facilities design and construction. There must be documentation of project management systems and formal approval fordesign, procurement, and construction standards. Also, pre-start-up reviews must be carried out for all new or modified equipment. Operations and maintenance. Post-start-up reviews must be completed and procedures must be developed and followed forequipment operations, maintenance, and retirement. Management of change. Changes must be formally assessed and approved, and they must not exceed their original scope orduration. Information and documentation. Information must be made available but also secure. Customers and products. BP must maintain information about product hazards and adverse product effects and have a recallsystem in place. Community and stakeholder awareness. BP must communicate HSE information to the community. Crisis and emergency management. Plans must be developed, continuously updated, and tested through drills. Incident analysis and prevention. All incidents must be fully reported, investigated, and findings must be shared as appropriate.BP should have teams with some members from outside the business unit for major incidents.BP’s HSSE Management Framework and Process Safety Related Standards C 49