At CNOOC International, we foster ethical, responsible and a safety-first mindset in order to build trust with all of our stakeholders. We set high expectations of our employees and provide resources to help guide responsible decisions. Working this way helps us attract and retain talented employees, enables us to access capital and countries that might otherwise be difficult, and strengthens the work we do as stakeholders.
Corruption, whether in the private or public sector, is illegal and a significant barrier to sustainable economic and social development. CNOOC International is committed to doing business free from all forms of corruption.
This commitment is endorsed by our executive management team who emphasize that compliance with our standards of integrity is supported at the highest level of our organization. These standards apply to all of us – every employee, director and officer is required to comply with our standards and is personally responsible for refusing to pay bribes or make improper payments.
CNOOC International’s culture and processes support our commitment to integrity. Our Prevention of Improper Payments Standard requires that all employees comply with applicable laws everywhere we operate. This Standard is periodically reviewed for best practices, vetted by external counsel and reviewed by our Compliance Committee.
The Compliance Committee is comprised of members of our executive management team and provides oversight on potential high risk payments. Approvals required under the Prevention of Improper Payments Standard are dealt with by this Committee, which also receives a report on high risk payments. As an additional control, our internal audit department assesses corruption risk on a periodic basis and conducts investigations if necessary.
Risk-based Prevention of Improper Payments training has been developed that provides employees in high risk positions with guidance on avoiding improper payments.
A number of resources have been developed to support CNOOC International’s commitment to integrity. These resources are managed by the Integrity and Compliance group in Calgary, Canada.
The purpose of the Integrity and Compliance group is to champion our culture of integrity, facilitate learning and compliance, and create business value. Our work falls into three areas: creating an integrity culture, compliance oversight and reporting. The Integrity and Compliance group is supported by subject matter experts in CNOOC International’s legal, security, information technology, audit and human resources departments. External advisors are engaged when necessary.
A network of Integrity Leaders has been established to promote the organization’s culture of integrity, facilitate integrity education and awareness, as well as act as a divisional resource for employees and internal stakeholders faced with an ethical dilemma or seeking guidance. Integrity Leaders regularly liaise between the Integrity and Compliance group in Calgary, Canada and employees working in our global locations.
Educating employees about the importance of integrity and compliance at CNOOC International is a key component of the organization’s Integrity Program. All new employees and contractors are introduced to our integrity culture through mandatory training. The training provides specific information with respect to CNOOC International’s expectations related to ethical business practices.
Annually, directors, officers and designated employees and contractors acknowledge their compliance with our Standards and Policies. Through this process, designated employees and contractors are given the opportunity to report actual or suspected integrity issues that have not already been raised with the organization. All concerns or reported violations are reviewed, investigated and resolved.