Sustainability Report 2014
Compliance to Law & Industry Standards
Operating in multiple countries around the world challenges the DOF group to stay abreast of governmental regulations in both national and local levels.
DOF personnel and subcontractors are required to comply with applicable legislation, regulations and standards as well as client’s requirements in every work function or activity. The legislation, standards, codes of practice and guidelines register provides a list of applicable requirements.
Each region where DOF Subsea operates has developed registers of applicable legislation, standards, codes of practice and guidelines. These registers are the foundation for compliance measurement. Identified non-compliances are to be addressed by corrective measures. When DOF operates in areas where legal requirements are weak, all operations are to follow our policies and operational standards.
DOF endeavors to comply with recognized industry standards and guidelines published by various organizations connected to the oil & gas industry, such as International Maritime Organization (IMO), International Marine Contractor Association (IMCA), International Association of Oil & Gas Producers (IOGP), International Organization for Standardization (ISO), and class societies (DNV GL, Lloyd’s etc.).
In the marine segment, a robust system is also in place to allow that vessels and offshore personnel are in compliance with laws and regulations in the locals of operation.
DOF have built up a Safety Management System (SMS) based on compliance on the IMO regulations. The SMS is audited and approved by DNVGL and a Document of Compliance certificate is issued. An annual audit is conducted on the company to verify that the company complies with the requirements of the International Management Code for the Safe Operation of ships and for Pollution prevention.
The DOF internal audit program is annually updated to ensure updates on new regulations are implemented and adhered to in the company.
All the Vessels owned by DOF are also audited annual by DNVGL under the same IMO Legislation vessel by vessel. The vessels are also audited under the internal audit program
DOF Management utilizes DNVGL Navigator, which provides regular updating of all IMO legislation and flag state requirements on vessel. Any changes in legislation as well any vessel recertification are communicated on a daily basis to our managers.
In 2013 DOF Management successfully implemented the Marine Labor Convention (MLC) on all NIS / NOR, BAH, Cyprus and IOM flagged vessels. In addition, vessel managers ensure that all DOF vessels comply with the SOLAS regulations for Life Saving Appliances (LSA) & Fire Fighting Equipment on board and that masters and officers are given the required training to operate in safety.
Compliance towards local regulations
DOF Quality System – BMS (Business Management System) is based upon OHSAS 18001, ISO 9001 and ISO 14001. The system is accredited by DNV. All three management systems standards impose the organization to monitor and measure processes against legal and other requirements - OHSAS 18001, ISO 9001 and ISO 14001.
All legislative requirements are listed in the Legislation and Other Requirements Compliance Register according to pre-identified areas for the compliance analysis (i.e. Labor & Working Environment, Health & Safety, Vessel, Offshore Activities, Environmental issues, Emergency Preparedness) in a Form – Legislation and Other Requirements Compliance DSA-HS-TP-005.
The requirements are identified for each Business Unit by HSEQ department. When ensuring and verifying the compliance requirements, internal governmental documentation from BMS is assessed towards the applicable chapters / sections and paragraphs in the legislation, compliance evidence is recorded in the register. Company is subscribed to regular updates from legal databases, and register is being updated accordingly. Compliance with the requirements is verified during internal reviews, inspections, third party reviews, internal and external audits.
Memberships of Associations
In order to facilitate interaction and collaboration with different sectors of the offshore industry, DOF is an active member of many industry associations in the locations where it maintains operations. And some of DOF’s managers even participate in projects or committees of those associations.
DOF Subsea APAC
- APPEA (Australian Petroleum Production & Exploration Association)
- IMCA (International Marine Contractors Association)
- Subsea Underwater Technology (SUT)
- Subsea Energy Australia
- Industrial Foundation for Accident Prevention (IFAP)
- Offshore Project Safe - Steering Committee member (Region EVP)
DOF Subsea UK
- British Safety Council
- Subsea UK
- Oil and Gas UK
- Abespetro (O&G Association)
- Abeam (Shipowners / Vessel Operators Associations)
- Syndarma (Shipowners Union)
- Abran (NSA - Norwegian Shipowners Association)
- NBCC (Norwegian-Brazil Chamber of Commerce)
- AEPM (Association for the Specialization of the Seafarer)
- Norwegian Shipowners Association
- Bergen Shipowners Association
DOF North America
- American Society of Safety Engineers - ASSE
- International Organization for Safety and Health - IOSH
- International Association of Drilling Contractors - IADC
GRI-G4-SO8 | GRI-G4-EN29
In 2014, there was no significant fine and non-monetary sanctions related to accounting fraud, workplace discrimination, or corruption under the jurisdictions where the DOF Group operates. In addition, the DOF Group has not identified any non-compliance with environmental laws or regulations, in the reporting year of 2014.