Context for the review

In response to allegations made in various quarters, and following its own internal assessment of the allegations of bribery, in the summer of 2014 the Company appointed an independent law firm, Clifford Chance, to review the allegations centred around SOCO’s activities in Block V, located in the Albertine Rift area of the Democratic Republic of Congo, and to report to the Board.

From the outset, the Company instructed Clifford Chance to keep the relevant UK authorities appraised of the scope, progress and outcomes of its review.

Clifford Chance was given full access by the Company to documents (in excess of 100,000 were searched) and permission to interview all members of staff.

Clifford Chance engaged directly with Global Witness in hopes of gaining insight into or evidence of specific allegations levelled by the NGO; however, the parties were unable to agree on conditions under which that information would be shared. Thus, during this process, Global Witness provided no information that was not in the public arena.

Findings of the review process

Clifford Chance assessed the allegations around SOCO’s activities in Block V and scoped their review accordingly and concluded that the allegations of bribery were substantially inaccurate. Further, the review found no evidence to support allegations that the Company or its employees sought to promote, sponsor or support any intimidatory action against any individuals or groups in the DRC.

Clifford Chance found non-material instances where those with whom the Company worked made payments in breach of Group policy. These are subject to remedial advice.

Clifford Chance confirmed that the Company did provide funding to various Governmental authorities (e.g. military escorts and park rangers) for the performance of legal and legitimate activities required for the performance of SOCO’s and the DRC government’s obligations under the Production Sharing Agreement. They found no evidence that any payments were made to secure any unentitled advantage or to curry special treatment.

Improving policies and processes

The Company disclosed in its 2014 Annual Report and Accounts the action it has taken both before and in parallel with the legal review in order to strengthen its procedures for transparency and accountability amongst staff and contractors.

The Company’s policy is that employees and contractors conduct themselves in an appropriate manner avoiding conflicts of interest and allegations of bribery or compromise and steps have been taken to reinforce this position across the organisation through an ongoing programme of anti-bribery and corruption training and testing.

Going forward SOCO has engaged Clifford Chance to further advise on improvements in employee/contractor policies and processes. Given the more hostile environments in which the Company operates, we want to make sure that there is no risk of improper conduct by those associated with the Company and that the Company is fully protected against exactly the sort of allegations it recently faced from campaigning organisations, NGOs and lobbying groups.

Exiting Block V

SOCO reiterates its commitment to leave Block V as has already been publicly announced. The timeline for this is tied to our contractual obligations in DRC.



Bell Pottinger
Luke Chauveau
Tel: +4478970054560


SOCO is aware of attempts to impersonate the company on social media. SOCO does not have a Facebook page.