Sustainability Report 2014
Business Integrity & Ethics
The DOF Group operates an international business across a diverse geographic, ethnic, cultural, political and financial landscape. The Group recognizes that it has obligations to a wide range of stakeholders, and the reputation of the Group and the trust and confidence of those with whom it deals are among its most vital resources. Our Business Integrity and Ethics policy outlines a set of core values and approaches that we expect our companies and employees to follow and the behaviors they must adopt to protect and build the Group’s reputation.
The Group’s definition of its social responsibility is to achieve good commercial profitability in a sustainable manner in line with fundamental ethical values, respect for humans, the environment and society.
DOF’s most important document is its Code of Business Conduct, which principal policies and guidelines are regularly reviewed and communicated both internally and to external parties. Central guidelines in the Code cover business integrity and ethics, equal rights and opportunities for employees / new recruits. The process to establish joint systems has continued in 2014 and the Group companies have now established joint manuals, standards and procedures for all employees.
The Group practices zero tolerance of bribery and corruption.
The Group has developed an electronic training module for ethical guidelines and commercial conduct that is available to and obligatory for all employees.
The DOF Group Values
See figure 7.1.
GRI-G4-SO5 | GRI-G4-SO7
The most important governing document in the DOF group is the Code of Business Conduct that has now been valid for several years. The principal policies and guidelines are regularly reviewed and communicated both in house and to external parties. Central guidelines in the code cover business integrity and ethics, equal rights and opportunities for employees / new recruits.
Besides the Code of Conduct, CoC, further improvements were made to internal communication of the Group’s ethical guidelines and business conduct with the implementation of an electronic training module made available to and obligatory for all employees. The Code of Conduct sets clear expectations on all employees, and is supplemented by a mandatory e-learn training module. The training is also publicly available at www.dofsubsea.com.
Additionally, executive and middle management receive regular training regarding anti-bribery and anti-corruption measures.
During 2014, the reporting mechanism for compliance incidents has been actively used on both local and Group level, and compliance incidents were handled and concluded in accordance with the requirements in the policy framework.
The DOF Group had one incident of employee breaking our compliance (CoC) regulations. That case was brought to attention through internal control systems, and dealt with according to internal procedures.
The case, concerning internal fraud, resulted in dismissal and was reported to the board of directors. In addition, the company pressed charges towards the individual involved, resulting in an arrest order being issued.
However, in 2014, no corruption cases have been noted. And neither was any legal action pending or completed regarding anti-competitive behavior, anti-trust or monopoly practices against the DOF Group.
Transparency – Traceability - Trust
It is the Board of Directors’ intention that the DOF Group shall be recognized by a high ethical standard. The Group’s anti-corruption and anti-bribery measures are regularly evaluated in order to ensure that sufficient measures are in place.
Risk assessment is also imperative to all DOF Group business activities.
Our Risk Management Manual helps us to identify threats and opportunities associated with the DOF business and operational activities and establish efficient means of barriers and controls in all phases of the business life cycle. The manual outlines the steps that the DOF Group have embraced within risk management at all levels of the organization. Our Risk Management principles and techniques align with the following:
- ISO 31000: Risk management -- Principles and guidelines;
- ISO 31010: Risk management -- Risk assessment techniques;
- ISO 17776: Guidelines on tools and techniques for hazard identification and risk assessment;
- DNV RP-H101: DNV Recommended Practice – RISK management in marine operations.
Bribery Risk Assessment
In regions with a high risk for Bribery and Corruption, we have used the know-how of DOF Subsea UK, subjected to the ruling of the Bribery Act 2010, to frame our approach to Bribery and ethics.
Bribery Risk Assessments are performed and recorded on a regular basis regarding operations of the Group, given the risk potential.
However, risks identified out with the formal Risk Assessment on an ad hoc basis will be added and analyzed as appropriate by Regional HSEQ Managers in all the locations where the Group operates.
In addition, assessment related to Business Integrity and Ethics is mandatory in all projects executed by the DOF Group. Control and mitigation required is based upon project risk and complexity.
In UK, we follow the ruling of the Anti-bribery act of 2010 and in other regions where we operate, a detailed process is followed according to guidelines for Business Acquisition in DOF, including Legal Contractual Risk Assessment, Commercial Risk Assessment, Technical Risk Assessment and Insurance Review.
Among the main significant risks identified related to corruption, they may vary according to the activity the company is engaged in. For example, during the tender selection key risks encompass: facilitation payments, excessive hospitality and excessive promotional expenditure, to provide a client with excessively luxurious accommodation or transportation, and offer of favorable prices in return for a personal gain.
Regarding donations and sponsorships, they are organized in a transparent way and are regularly being checked and audited by external bodies like PwC and equals.
A typical donation can be towards an athletic organization where we donate a fix sum for sponsoring a sport arrangement. We get our name on posters or clothes and in return we will receive an invoice from the athletic club. The invoice will refer to an agreement. Other sponsorships can be towards named athletics with a half yearly payment. This is regulated in a joint agreement signed by both parties.
In case of donations to support bereaved with education, in case of the death of DOF employees, a separate donation committee is organized by external lawyers. As a guest DOF will donate a given sum of money and this will be followed up by collection given by DOF employees.
In Brazil we donate money to established and reputable organizations that run schools and educational programs. These donations are based upon written agreements and payments are based upon invoices referring to the agreements. The agreements are part of the annual audit scope performed by external auditors.
In general all payment in DOF is regulated in our authorization matrix. The “four eye” principle is in build in this. The entire payment process is under a strict control and in case of donations and sponsorship these rules will apply.
Communication and training on anti-corruption policies and procedures
Introduction training is offered to all employees in the DOF Group, regardless of their role and position. Four e-learning modules are mandatory, including ‘Business Ethics and the Code of Conduct’, which covers many issues regarding anti-bribery and anti-corruption policies.
One of our aims is to provide to our executive and middle management team regular training regarding anti-bribery and anti-corruption measure, in order they disseminate the Group’s policies among the employees in the region where they are located.
In 2014, during a global meeting in DOF’s headquarter, senior managers were engaged in a ‘Dilemma training’ held by DNV GL, where the participants were faced with challenging cases regarding professional ethics and how to uphold integrity and ethical conduct on a daily basis. It was a good opportunity for the participants to practice ethical decision making based on DOF’s business integrity values and the Code of Conduct.
Experience gained through this training has then been brought back to the regions for transfer of experience and further training on a local level.
Since the launch in 2012, many of our employees have completed the Business Ethics & Code of Conduct e-learning module, with a passing score in the final test.
Business Integrity & Ethics is a mandatory part of the yearly appraisal between managers and employees. This is an important opportunity for monitoring awareness and consciousness of DOF’s values.