Reputation in Oil, Gas and Mining 2014: Communicating on corporate ethics

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Michelle Witton, compliance officer, ENRC
The relationship between communications and compliance is crucial to communicating key messages to both internal and external stakeholders regarding the company’s code of conduct and corporate values. Michelle Witton, compliance lawyer at the Eurasian Natural Resources Corporation explores the importance of the relationship between communications and compliance. In this session she shares her first-hand experience working on Anglo American’s anti-corruption programme.

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Reputation in Oil, Gas and Mining 2014: Communicating on corporate ethics

  1. 1. www.enrc.com Phone: +44 (0) 20 7389 1440 Communicating Corporate Ethics ENRC Compliance Michelle Witton – Compliance Lawyer London, 11 June 2014
  2. 2. Reputation and Brand
  3. 3. Reputation and Brand
  4. 4. • New field / function – still very much evolving • Behaviour (Win hearts & Minds) + Regulation - Top down v bottom up approaches • Internal messaging to build and sustain positive, compliant culture • Real opportunities for creativity and working with Communications to deliver impactful communications. What is Compliance?
  5. 5. • Code of Business Conduct / Corporate ethics • Anti-corruption (ABC) Policy + Gifts and Entertainment Policy • Competition / Anti-trust Policy • Ministerial Relations Policy • Counterparty Due Diligence • Trade sanctions • Compliance Risk • Compliance Training • Monitoring + Auditing Compliance - Areas
  6. 6. Bribery and corruption
  7. 7. TI Corruption Perceptions Index UK 7.7 Trinidad & Tobago 3.6 Egypt 2.8 Indonesia 2.6 Libya 2.6 Angola 1.9 Azerbaijan 1.9 Iraq 1.3 10 = Best possible Less than 5 = high risk
  8. 8. TI CPI 2013 – Least corrupt UK 7.7 Trinidad & Tobago 3.6 Egypt 2.8 Indonesia 2.6 Libya 2.6 Angola 1.9 Azerbaijan 1.9 Iraq 1.3 10 = Best possible Less than 5 = High risk Denmark 90 Finland 90 New Zealand 90 Sweden 88 Singapore 86
  9. 9. TI CPI 2013 – Most corrupt UK 7.7 Trinidad & Tobago 3.6 Egypt 2.8 Indonesia 2.6 Libya 2.6 Angola 1.9 Azerbaijan 1.9 Iraq 1.3 10 = Best possible Less than 5 = High risk SOMALIA 8 KOREA (North) 8 AFGHANISTAN 8 SUDAN 13 MYANMAR 15 IRAQ 18
  10. 10. FIFA – Doesn’t play fair….
  11. 11. FIFA Revised Code - My Game Is Fair Play
  12. 12. Siemens
  13. 13. Siemens – case findings • $1.4bn total bribes paid • 4,000+ improper payments • Asia, Africa, Europe, Middle East, Americas • Usually paid by outside consultants hired to help ‘win’ contracts • Siemens paid fee to consultant, consultant delivered cash to decision-maker(s)
  14. 14. • Dawn raids • Simultaneous investigations across 20 countries • 1,750 investigation interviews • 500 employees disciplined • From 5th to 50th preferred company ranking • Loss of senior personnel • Total penalty: $1.6b • Additional costs: approx. $2b hidden costs • Compliance monitor imposed for 4 years Siemens – loss to business
  15. 15. Compliance and Communications – Working together to achieve compliance - Creating a strong brand for compliance - Culturally relevant and resonant - Enhance credibility - Assisting employees to know and apply the Code of Conduct as the minimum standard wherever we operate.
  16. 16. How are we achieving this? • Clear visual identity for the Code & Compliance. • Easier to read, understand and recall. • Communicate the Code to our people in the most suitable way, depending on location, role and position. • Our people to tell the story of why it matters.
  17. 17. Code of Conduct packs • Code of Conduct packs produced in English, Russian, Brasilian-Portuguese and French • A language-specific DVD • The ENRC Code of Conduct. • Code “Z Card” with the key principles and contacts for whistleblowing hotlines and helplines. • Self-certification Certificate of compliance with the Code, to sign and return to Compliance.
  18. 18. • Manual • Website • Intranet • Chairmans office Where can we find the ENRC Code of Conduct? Intranet
  19. 19. ENRC Global Whistleblowing Hotline Numbers Employees who have any concerns or suspicions regarding a breach of the ENRC Code should raise these matters with their line manager, local Human Resources contact, a higher level of management within their business unit or the General Counsel. Whether it is bribery, corruption, discrimination, harassment, violence, legal, policy or regulatory violations, environmental issues or any other matter, Employees should speak to someone about it. If, for any reason, any Employee feels unable to talk to these people, they may bring their concerns to the attention of the ENRC “Trust, but Verify!” external whistleblowing hotline. The whistleblowing hotline is a confidential, 24/7 service managed by an independent company. It can be contacted by telephone or by email. The contact details are outlined below. UK Т: 0808 234 9574 Switzerland Т: 0800 83 6056 South Africa Т: 0800 891 2843 Mozambique Т: 841199 (Vodacom) DRC Т: +243(0)82 302 7626 Brazil, Fale Conosco T: 0800 891 2843 China T: 10 800 110 1045 Dubai T: 8000 021; Code: 866 605 3095 Zambia Т: 8000 021; Code: 866 605 3095 Kazakhstan Т: 8 – 800 121 4321 Pin: 866 605 3095 Russia Т: 8 – 10 800 110 1011 Pin: 866 605 3095 W: http://hotline.enrc.com E: compliance@enrc.com ENRC does not tolerate any harassment or victimisation (including informal pressures or any way of disadvantaging any individual) and will take appropriate action to protect anyone who raises a concern in good faith. If anyone tries to discourage an individual from coming forward to express a concern, it will be treated as a violation of the Code of Conduct and of this policy, and as a disciplinary offence.
  20. 20. Corporate Values Case Study - BP
  21. 21. Corporate Values – BP – Pre 2010 • Progressive • Responsible • Innovative • Performance Driven
  22. 22. Deep Water Horizon - 20th April, 2010
  23. 23. Corporate Values – BP – Revised 2012 “ We are BP ” – Safety – Respect – Excellence – Courage – One Team
  24. 24. Corporate Values – BP - 2012 One Team • Whatever the strength of the individual, we will accomplish more together. • We put the team ahead of our personal success and commit to building its capability. • We trust each other to deliver on our respective obligations
  25. 25. Making values visual - Anglo American Guiding Values
  26. 26. Ethical decision-making
  27. 27. Ethical decision-making
  28. 28. Ethical decision-making
  29. 29. Ethical decision-making
  30. 30. Where do we work?
  31. 31. Where do we work?
  32. 32. Where do we work?
  33. 33. • Accessible, branded Code of Conduct • Payslip reminders, Training Desk Certificates • Intranet, internal publications • Radio, Internal tv network stories, Promotional video • Workshop and online training using scenarios • Decision trees, Wallet cards • Stickers, Mouse mats, Notepads • Tablet app for Code of Conduct • Annual Ethics award Compliance and Communications – Project Ideas
  34. 34. 33 Questions?

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