The Oil Search Code of Conduct represents our commitment to upholding ethical business practices that meet or exceed applicable legal requirements. We believe a consistent and principled approach to conduct builds trust and generates stakeholder support.
The Code of Conduct applies to all Directors, employees, contractors, consultants, agents, advisors and representatives engaged by us and our related companies.
Everyone who carries out Company business is expected to understand and practise the Code. We provide compulsory training to new employees and consultants during induction and conduct ongoing awareness and refresher training sessions annually, or when there are significant updates to the Code.
If an employee fails to comply with the Code, this may result in disciplinary action, including termination of employment. We expect employees to report any breaches and, if any applicable laws have been broken, we will report this to the relevant authorities. Every year, we publish the number of Code of Conduct breaches that result in a disciplinary action warranting a written warning or termination of employment, to demonstrate our commitment to managing this serious issue.
Senior management and members of the Board are obliged to certify their compliance with the Code each year. The Oil Search Integrity Committee - which consists of all members of the Executive Leadership Team, Head of Assurance and Compliance, General Manager Stakeholder Engagement and Social Responsibility and the Compliance Manager - reports to the Board and its Committees on material breaches of the Code and corrective action taken.
Oil Search has a zero tolerance approach to bribery and corruption and we expect that employees, contractors and any third parties acting on our behalf perform their duties ethically, honestly, responsibly and diligently, and in full compliance with the law, our Code of Conduct and the Corruption Prevention Policy.
Our procedure on corruption prevention outlines our expectations in relation to:
- Whistle-blower protection.
- Recognising and avoiding corrupt behaviour and activity.
- Rules for offering, accepting and recording gifts and entertainment.
- Managing conflicts of interest.
- Prohibiting political contributions.
- Conducting due diligence of joint venture partners and agents.
Our Assurance and Compliance team periodically conducts Company-wide fraud risk assessments to ensure our controls remain strong enough to minimise the likelihood and significance of fraud. All our supplier contracts include corruption prevention clauses and we check compliance during supplier performance reviews.
Training on our corruption prevention requirements is mandatory for all employees and select consultants during induction and we run compulsory refresher training every two years. We communicate updates to the Corruption Prevention Policy through the Company intranet and staff emails.
We conduct ongoing monitoring of sanctions as part of our due diligence processes. Our Corruption Prevention Policy elicits the need to conduct background checks using these processes.
Our Board Audit and Financial Risk Committee is informed of the completion rates of mandatory corruption prevention training and is notified of all fraud and corruption incidents.
Any instance of corruption, fraud or bribery can be reported via the Oil Search Whistle-blower Hotline or other contact points, as outlined in the ‘Speaking out’ section.
We expect employees, contractors, joint venture partners, customers and other stakeholders to report suspected violations of our procedures or corrupt practices. This includes conduct that:
- Involves bribes or inducements,
- Is dishonest, fraudulent or corrupt,
- Is illegal,
- Is negligent, directly or indirectly resulting in a substantial waste of Company funds,
- Is detrimental to our interests,
- Involves unsafe work practices or is a danger to public health, safety or the environment.
Any suspected breaches can be reported to an employee’s line manager or to one of the following:
- General Counsel,
- A Compliance team member,
- Human Resources.
Suspected breaches can also be reported in confidence and anonymously through the Oil Search Whistle-blower Hotline. The Hotline is managed by an independent third party and languages other than English are available.
Details are available at: www.oilsearchhotline.deloitte.com.au
The identity of the person making the disclosure is protected as far as the law permits. Where practicable, we will consult with them before informing government agencies.
We prohibit any form of retaliation against someone who raises a concern or reports a suspected breach of our Code of Conduct, Policies or the law. We regard retaliation as grounds for discipline, including dismissal.