Full colour version of the BP magazine

“Our reputation, and, therefore, our future as a business,
depends on each of us, everywhere, everyday, taking
personal responsibility for the conduct of BP’s business.”
Tony Hayward
can be harder to spot. The cause and effect
with safety is very clear; there is a science
behind it. But when faced with an ethical
dilemma, the solution can sometimes cause
a completely new dilemma somewhere else
along the chain. “I cannot tell you the
number of times an OpenTalk [BP’s
confidential compliance and ethics helpline]
investigation has found that two or three
people made a judgement that has created a
non-compliant situation. Not because they
were doing anything covert, but because
they were trying to do their best, but made a
bad judgement,” says Kuryk.
To encourage employees to better
understand the dilemmas and adapt
accordingly, C&E has created a number of
tools. The two most prominent are its
global OpenTalk helpline (which receives
more than 1,000 calls per year) and its code
of conduct, benchmarked as best-in-class.
The code covers five key business areas:
protection of health, safety, security and
environment; employee treatment;
interaction with business partners;
interaction with governments and
communities; and appropriate handling of
company assets and financial integrity. “It’s
a universal standard,” says Kuryk. “If you do
everything the way the code tells you to do
it, you’ll be in good shape from an ethical
perspective.”
Simple process
Of course, an 84-page document cannot
cover every nuance of every instance in
every part of the world. So, says Langton,
the process is simple: “If there is no local
guidance in the region you work in, then
follow the code. If the local guidance is
more exacting than the code, then follow
the local guidance.”
Ultimately, managing compliance and
ethics is about managing risk, and
McCormick believes the company has
come on leaps and bounds in the way it
does this. “Lots of companies are good at
identifying risk,” he says. “The big question
then is how you take action.”
In the past, BP carried out an annual
exercise in which the top 7,000 individuals
in the company had to consider
compliance and ethics risk and confirm
they were managing it appropriately. In
2007, the team assessed the situation and
came to the conclusion that it was an
unwieldy process that only really asked
people to list issues, with little direction on
how to actually manage them. “It was an
enormous task, and the business benefit
was not commensurate with the effort,”
says Kuryk.
It was clear that if the team wanted to
ensure a high standard of compliance, then
the process needed to be simplified and the
conversation changed. All BP’s businesses
and functions know they need to manage
their risks. “It is their decision, their risk,”
says Langton. The role of the C&E team is
to promote compliance, provide oversight
and help respond to ethical quandaries.
It is a collaborative effort. Rather than a
central team disseminating a list of risks
and leaving the businesses to figure it out,
the process is a two-way conversation, in
which the C&E team helps a business or
function respond to known risks. And if
the C&E team should spot another issue as
they listen to a business, then all the better.
There are, of course, risks that can have
an impact on any part of BP’s activities –
such as bribery, breaches of competition
law, environmental protection and
personal conduct – but underneath these
‘top line’ themes, there’s a second layer of
more specific issues depending on which
part of the business you’re focusing.
“The risks have very different instances
in very different parts of BP, and actually can
be different in different parts of an
individual segment,” says McCormick. “So,
one risk could be a blanket issue right across
our Exploration & Production businesses,
but only relevant in one sub-segment of our
Refining & Marketing operations. Our job is
to make sure the programme works
everywhere, while having enough flexibility
to cater to all our customers.
“There is a real art to understanding
what is happening in the multitude of
different businesses in the 65 jurisdictions
where BP operates. It’s very complex and
it’s multi-dimensional. It’s what makes it
fun – to make compliance and ethics
relevant from a business standpoint.”
The ultimate goal is that this joined-up
approach should run like a seam right
through BP’s DNA and, to ensure that BP’s
board of directors plays a critical role.
While many company boards review their
compliance programme once a year, BP
reviews its risk profile every single
business quarter.
Fluid situation
The attention it is given is a reflection of the
fact that BP is dealing with a dynamic, fluid
situation. “The fact that Tim’s team talks
straight to the top of the line regularly
means they understand what the businesses
are experiencing as it happens,” says Kuryk.
“It is about being relevant on a day-inday-out
basis,” adds Langton, “and it has to
be simple otherwise people won’t do it.”
Simplicity allows all BP employees to
take the kind of individual responsibility
for the group that Hayward describes in the
code of conduct. In turn, it helps tell a
strong story to the outside world – driving
reputation. Indeed, other companies have
approached BP to share its experiences.
And, if potential partners value BP’s ethical
commitment as a reason to want to work
with it, then doing the right thing brings
about mutual advantage – in other words,
good business in the ethical sense provides
a multinational company with its license
to continue operating. ■
“There is a real art to understanding what is
happening in the multitude of different businesses in
the 65 jurisdictions where BP operates. It’s very
complex and it’s multi-dimensional. It’s what makes
it fun – to make compliance and ethics relevant from
a business standpoint.”
Tom McCormick
BP MAGAZINE Issue 1 2009 27