Business ethics and anti-corruption

Operations assessed for risks related to corruption

(number/%)

  2014 2015
Cairn total 8/100 4/100

Note: Significant risks identified include:

  1. Risk of corruption acts in the supply chain.
  2. Risk of local contractors not being adequately trained on anti-bribery and corruption.
  3. Risk of not adapting corporate anti-bribery and corruption management system to the local culture.
  4. Risk of operating in jurisdictions perceived as high risk for bribery.
  5. Risk of poor communication and monitoring of anti-bribery and corruption policies and procedures.

Note: For the purposes of this indicator we define an operation as a country in which we had operational activity (including field and office activity) in the reporting year. It should be noted that we may have more than one set of assets in a given country.

Note: All of the operations included have been assessed for risks related to corruption although the assessments may not have taken place in the reporting year itself.

 

Total communicated to on anti-corruption policies and procedures

(number/%)

  2014 2015
Board members 7/100 9/100
Total employees 178/100 151/100
Total management grade employees 56/100 48/100
Total non-management grade employees 122/100 103/100
Business partners   12/75
Business partners – significant suppliers   11/85†
Business partners – joint venture partners   1/33‡

Note: Data on business partners communicated to on anti-corruption policies and procedures is only available for 2015.

Note: Significant suppliers are defined as any that require approval from Cairn’s Contracts Committee.

Note: †Only two of all the significant suppliers did not have Cairn's anti-bribery and corruption policies communicated to them. They were data/software providers.

Note: ‡Cairn communicated its anti-bribery and corruption policies to the joint venture partner that was involved in operations. The others were non-operated partners who were given access to Cairn's anti-bribery and corruption policies.

Note: The following notes explain the processes Cairn goes through to ensure that anti-corruption risks are assessed and to ensure its anti-corruption policies and procedures are communicated to its business partners.

In line with the requirements outlined in the UK Bribery Act, Cairn applies a risk-based approach to assessing corruption risk prior to establishing new operations and contracting with new joint venture partners and suppliers. Cairn considers a number of factors when determining the level of anti-bribery and corruption due diligence to be completed, such as the Corruption Perceptions Index score for the relevant country and the level of contact the business partner is expected to have with public officials. These factors are objectively scored, and the appropriate level of due diligence is determined accordingly. This process is mandatory for all Cairn Group companies, business units and locations.

In addition, all Cairn contractors are required to comply with Cairn's Group Business Ethics Policy and its Business Principles. Consequently, these policy documents are incorporated into contracts entered into by the Cairn Group with suppliers, consultants and agents.

As Operator (or prospective Operator) under a licence, we provide the relevant Government with details of our anti-bribery policies and procedures in the following circumstances:

  • In the course of submitting an application under a licence bid round.
  • Where requested by the party from whom we are acquiring an interest in a licence.
  • In the course of requesting consent from the relevant government to an acquisition of interests (if required).
  • Where otherwise requested by the relevant government.

Up-to-date versions of Cairn's anti-bribery and corruption policy documents are displayed on the Cairn Energy website at all times.

 

Employees communicated to on anti-corruption policies and procedures, and country breakdown

(number/%)

  2014 2015
Greenland 1/100 NA
Morocco 2/100 2/100
Norway 17/100 21/100
Senegal NA 1/100
Spain 3/100 NA
United Kingdom 155/100 127/100

 

Total employees trained in Cairn’s anti-corruption policies and procedures

(%)

(number/%)

  2011 2012 2013 2014 2015
Board members       0/0 7/78
Total employees 118/79 42/23 56/27 105/59 23/15
Total management grade employees 35/73 9/16 24/34 30/54 13/27
Total non-management grade employees 83/81 33/27 32/24 75/61 10/10

Note: Figures on board members trained in Cairn’s anti-corruption policies and procedures are only available from 2014 onwards.

Note: The Board received anti-bribery and corruption training at the Board meeting in March 2015. Two new Board members joined the Company after the training was provided.

Note: All Cairn employees have been trained in Cairn’s anti-corruption policies and procedures, but these are the figures for employees who received training in the reporting year. The majority of employees received training at the end of 2014 and the rest were trained in 2015.

 

Employees trained in Cairn’s anti-corruption policies and procedures, and country breakdown

(number/%)

  2014 2015
Greenland 0/0 NA
Morocco 0/0 0/0
Norway 6/35 0/0
Senegal NA 0/0
Spain 0/0 NA
United Kingdom 99/64 23/18

Note: All Cairn employees have been trained in Cairn’s anti-corruption policies and procedures, but these are the figures for employees who received training in the reporting year. The majority of employees received training at the end of 2014 and the rest were trained in 2015. A training workshop was delivered to all personnel in the Senegal office in September 2015, however these were all contractors so are not included in these figures.

Note: An employee is defined as a person employed by and on the payroll of Cairn. Persons employed under short-service contracts are included as Cairn employees provided they are paid directly by Cairn. Personnel who are contracted for more than 3 months to an organisational position and who are categorised as ‘other workers’ in the database are not included in the employee numbers for these indicators.

Note: Data on board members cannot be broken down by country as Cairn has only one board of directors which is located in the UK. Data on business partners cannot be broken down by country as they only include business partners in Senegal, our only operational asset in 2015.

 

Total business ethics

  2011 2012 2013 2014 2015
Incidents of non-compliance with Cairn's Code of Business Ethics (number) 0 0 0 0 0
Employee dismissals resulting from non-compliance with Code of Business Ethics (number) 0 0 0 0 0
Contracts cancelled in part due to concerns about contractors' ability/willingness to operate in line with business principles (number) 0 0 0 0 0
Money paid to political parties and institutions (£ pounds sterling) 0 0 0 0 0

 

Investment proposals that covered results of CR due diligence

(%)

  2013 2014 2015
Investment proposals 100 100 100

Note: Investment Proposals (IPs): In 2015 Cairn required that any new investment with a net expenditure in excess of $1 million should be assessed against specified investment criteria, which include an assessment of the potential CR risks involved with the opportunity. For those investment opportunities that are taken forward to the Board for approval, an Investment Proposal (IP) is required which summarises the outcome of the review (including the CR assessment), the recommended terms of the offer and how the opportunity would be managed in the event of success. These IPs are signed off by all Functional Department Heads, the Chief Operating Officer (COO) on behalf of the Management Team (MT) and the Chief Executive Officer (CEO) on behalf of the Executive Team (ET).

 

Anti-competitive behaviour

(number)

  2014 2015
Legal actions for anti-competitive behaviour, anti-trust, and monopoly practices 0 0

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