SPO takes a zero-tolerance approach to bribery and corruption and we are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption.
This commitment is underlined in our Corporate Code of Conduct (CoC) and Anti-Bribery & Corruption Policy. We also take observing best industry practices very seriously and require both our employees and contractors to display the highest ethical standards.
SPO's requirement is for probity, transparency and accountable conduct in all business dealings and the CoC is a condition of everyone's employment. We have in place compulsory training modules for all shore-based employees, through our online training platform, Percipio. Training covers our CoC and Global Anti-Bribery and Corruption issues (though based on UK law). We also have a module on Anti-trust issues for relevant employees. The modules require employees to pass the test on completion demonstrating their understanding of the regulations and our requirements.
All SPO employees, besides obtaining appropriate approvals from Relevant Persons, must also declare all gifts and hospitality given to them with value in excess of USD 150. Declarations are submitted to the HR team who check for compliance with the CoC. It is the responsibility of all SPO employees to prevent, detect and report bribery and other forms of corruption. Any issues or concerns can be reported using the Confidential Whistleblowing Hotline and are duly investigated by senior management. (see Fines and Grievances section)
Our own Internal Audit ("IA") department and the Swire group Internal Audit Department ("GIAD") formally audit all business units on a rolling, risk-based basis. The internal audits are conducted and reported to the Audit Supervisory Committee.
The scope of the Internal Audit encompasses the examination and evaluation of the adequacy and effectiveness of the organisation's governance, risk management process, system of internal control structure and quality of performance in carrying out assigned responsibilities to achieve the organisations stated goals and objectives. We report annually to our parent company in Hong Kong SAR on Anti-Bribery and Corruption compliance matters.
Zero Tolerance for Facilitation Payment
We also take observing best industry practices in areas such as marine anti-corruption very seriously, especially given the historical prevalence in some areas for seeking "facilitation payments" to perform activities or provide services that are, and should be, a normal part of doing business. SPO has been working with and submitting reports to the Maritime Anti-Corruption Network ("MACN") for a number of years to help remove this scourge from the marine sector.
SPO's employees should never encourage nor initiate facilitation payments. We report all instances to the MACN, especially those related to physical harm, detention, or undue harassment.
Photo top: Pepi Stojanovski on Unsplash
Photo above: Sahand Hoseini on Unsplash