Our Ethics

To ensure we conduct our business activities with integrity and high ethical standards, the values expressed in the SOCO Code are integrated into the SOCO HSES MS through policies, procedures, implementation guidelines, project specific operational plans, programmes and training. Our primary policies for promoting ethical business conduct are the:

  • The SOCO Code
  • Guidelines for Implementation
  • Business Conduct Procedure

In each country where we operate, we ensure that there is a thorough understanding of the local regulatory framework in force and ensure that our activities are compliant with licence requirements as well as the commitments we make in our Environmental and Social Impact Assessment (‘ESIA’) studies that precede operational activity. The SOCO HSES MS facilitates best practice international standards which exceeds national requirements in some countries.

SOCO co-operates fully with governmental and regulatory bodies. We do not engage in party politics or make donations to political parties or candidates.

ANTI-BRIBERY AND CORRUPTION PROGRAMME

As reflected in the current SOCO Code (first published in 2004) the giving and receiving of bribes has always been prohibited throughout the organisation. Running in parallel with the Group’s general risk management process, the Audit & Risk Committee has established a detailed antibribery and corruption (‘ABC’) risk assessment and mitigation reporting procedure and monitors this risk throughout the year.

A dedicated ABC programme is active across the Group. The programme includes due diligence on new vendors, annual training for all personnel, requisite compliance declarations from all associated persons and comprehensive ‘whistleblowing’ arrangements.

SOCO’s Whistleblowing Policy reflects the protection afforded under UK employment law and aims to provide reassurance that employees will be protected from reprisals when raising concerns in the public interest regarding serious malpractice or wrongdoing within the organisation such as incorrect financial reporting, unlawful activity or activities that are not in line with the SOCO Code. In addition to the usual reporting channels, the Company offers a confidential Ethics Hotline, an independent telephone and web-based reporting service which is advertised to staff at all offices.

2017 outcomes

 SOCO’s ABC programme was active throughout 2017. During the year, we updated the Whistleblowing Policy and upgraded the accessibility of the Ethics Hotline. No reports were made under this policy in 2017.

Our contractor pre-selection questionnaire which includes a number of questions on business conduct has been routinely sent out to our potential contractors as part of our procurement process.

PREVENTION OF MODERN SLAVERY PROGRAMME

SOCO fully abides by the provisions of the 2015 Modern Slavery Act and has published on our website a statement on the steps taken to mitigate the risk of modern slavery occurring in any part of our business including our supply chain.

During 2017, following completion of the review of the SOCO HSES MS in the previous year, efforts to prevent modern slavery and human trafficking were focused on the implementation of pre-qualification due diligence for all new contractors and vendors. Additional human resource was recruited to administrate this process and workflow systems have been adjusted to flag non-compliance. The Prevention of Modern Slavery programme in 2018 will include process training, awareness raising within the organisation and contractor/vendor requalification due diligence.

TRANSPARENCY

Approach and 2017 outcomes

SOCO supports the principles of the Extractive Industries Transparency Initiative (‘EITI’) and is an EITI Reporting Company in Congo (Brazzaville). Our data is validated by external auditors prior to submission to EITI. We participated in EITI’s validation mechanism for Congo (Brazzaville) leading up to it becoming an EITI Compliant Country. During 2017 we completed reporting into EITI for the prior year.

We support the 2014 Reports on Payments to Government Regulations. In 2017, we published the details of tax and royalty payments made to governments around the world by SOCO and our subsidiaries on our website.

We disclose our greenhouse gas (‘GHG’) emissions data for all operations, including the jointly operated projects in Vietnam in accordance with the UK 2006 Companies Act. We continued our annual disclosure of emissions to the Carbon Disclosure Project (‘CDP’) in 2017.

 
 
 
 
 
 
 
 

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