Company statement on bribery issues
Company statement concerning our approach to bribery issues
Heritage Oil Plc and its subsidiaries (collectively, the "Company") is opposed to bribery and corruption in whatever form. This policy includes the prohibition of facilitation payments in accordance with the UK Bribery Act 2010. Its scope extends to all of its agents, employees and contractors. The Company has adopted a zero tolerance approach to bribery and corruption and is committed to carrying out its business activities fairly, honestly and openly. The Company believes that its licence to operate and its success as a business depends upon this approach as it enables the Company's stakeholders to have the required level of confidence in their dealings with it and to maintain its reputation.
The Company has established an Anti-Bribery and Corruption Code (the "Code"), which applies to all of its agents, employees and contractors and is an enhancement of existing policies. The Code prohibits all forms of bribery and outlines potential disciplinary actions if this Code is breached. The Company has also established a Board level Anti-Bribery & Corruption Committee, to deal with the Code. It has the maintenance of management systems combating bribery and corruption, amongst its duties. The Terms of Reference for this Committee are in the Corporate Governance section of this website.
The Company's bribery prevention procedures include:
- rigorous financial management systems which aim to prevent instances of bribery and corruption;
- an established whistle-blowing system to assist employees and contractors in reporting any related concerns they may have in a confidential manner;
- training and human resource systems to ensure that all of its employees and contractors are aware of and understand the boundaries between for example, corporate entertaining and bribery, and the Code. These procedures also aim to support its senior management team, in each of the territories that the Company operates, to provide leadership and guidance in this important area;
- internal communications systems, which are regularly reviewed, to disseminate and inform agents, employees and contractors about the Code, the sanctions it contains concerning instances of bribery and its whistle-blowing procedures;
- regular consultation, discussion and knowledge sharing with its peer group companies, investors, non-governmental organisations and the regulatory authorities in the territories in which it operates; and
- regular review of the Company's related policies, systems, processes and performance by its senior management, the CSR Committee, Audit Committee and the Anti-Bribery & Corruption Committee and its external advisers. This activity includes an assessment of the risks involved in each part of the world where the Company conducts its activities.
The Company welcomes feedback and dialogue with interested stakeholders concerning this statement and its policies, systems and performance concerning bribery. Please see the Contacts section of this website for the relevant contact details.
Chief Financial Officer on behalf of Heritage Oil Plc
1 July 2011