Operating with the highest ethical standards
We are committed to operating with the highest standards of ethical business practice.
Our values reflect the best of our heritage and the attributes that support our continued future success. They are: driven, agile, respectful and open. These values are surpassed only by our uncompromising commitment to safety and ethical business practice.
We identify ethical conduct, bound by rigorous compliance and governance, and the right behaviours, as one of the ESG (Environmental, Social, and Governance) issues that matter most to our stakeholders.
Our future built on a robust compliance regime
We have a well-developed, comprehensive compliance and governance regime at Petrofac.
This is supported by a dedicated compliance and investigations team, new systems and technologies, mandatory training, and a company culture based on ethical business conduct and transparency.
Our compliance regime is championed, supported, and overseen at local, divisional and Board level, and supplemented by regular independent verification.
It is built on three lines of defence:
- Leadership and people
- Processes and controls
Each of these lines of defence informs improvements to others.
Leadership and people
Board and senior leadership
The starting point of our ethics and compliance programme is our Board and senior leadership.
Our Board includes members with relevant remediation and corporate corruption experience, while the Compliance and Ethics Committee is overseeing and continuously challenging our Compliance function. The Committee, chaired by George Pierson, member of the Board since 2016 and a former lawyer, organises quarterly meetings attended by key corporate leaders – Group General Counsel, Chief Compliance Officer, Head of Investigations, Head of Internal Audit and others. It advises our leadership and it had an active role in revising our Code of Conduct to deliver a clear, understandable, and direct tone on compliance to all employees.
Our new senior leadership team has worked hard to enhance the corporate compliance programme and to institutionalise this within the company’s culture.
Supporting the cultural shift
Our people in key roles across the business are empowered and qualified with more direct lines of communication to senior management.
We have an effective training and communication plan, a robust risk assessment mechanism, a confidential and efficient investigations process, and a monitoring and evaluation system that ensures continuous improvement and calibration. Leadership engagement is at the centre of our programme, and our leaders are driving its implementation.
We insist on a single standard of Petrofac behaviours, which are an integral part of our business and underpin our ways of working. We are committed to enable and embody ethical behaviours, and we continue to invest in our people and processes to ensure that we live up to the commitment.
Processes and controls
The second line of defence is a set of processes and controls which strengthen our compliance programme and ensure we have adequately designed and effective tools, systems, and controls to prevent wrongdoing from happening, and to detect and respond to it appropriately if it occurs.
We have established a Third Party Risk Committee, chaired by our Chief Financial Officer, and made up of our CFO, our two COOs, and the Group General Counsel. This Committee has oversight of our third-party risk profile, ensures Petrofac only engages with approved third parties, reviews high risk engagements and evaluates the risk and proposed mitigation. In its work, it reports to the Board’s Compliance and Ethics Committee.
Our third line of defence, a strong assurance framework, is built on three key initiatives:
- Renewed Investigations function
- Strong Internal Audit function
- External monitoring and review
Each of these provides essential feedback and influences the design of our compliance and Ethics programme in a continuous improvement cycle.
Our investigations team is made of highly qualified, trained specialist investigators. To support their work, we established a new platform for anonymous issues reporting, and an agreed set of KPIs to ensure timely resolution of investigations.
We assembled an Investigations Triage Committee, which reports to the Board and assess all allegations of wrongdoing and has an active role in investigations and monitors their progress and results.
Independent Internal Audit
This independent function reports to the Board’s Audit Committee through the Finance function. It is actively testing our policies, tracks mitigation and remediation, and organises cross-departmental calls to ensure timely reporting of any potential issues.
We have entered a long-term engagement with an external monitor whose integrity, credibility, and experience with multinational corporate compliance programmes will be a key part of our assurance process. They will evaluate and benchmark our compliance programme to make sure it meets and exceeds regulatory expectations, make recommendations for improvement, and monitor implementation and effectiveness.
We encourage everyone to Speak Up
We encourage everyone involved with Petrofac, to Speak Up if they have concerns about unethical behaviour or activity. Speak Up is our independently managed and confidential reporting helpline.