Two Cairn employees looking out to sea

Ethics, anti-bribery and corruption, and transparency

Our ability to do business relies on developing trust with our stakeholders, including investors, governments, business partners, suppliers and the broader society. This means we work in an ethical and transparent way and take a zero-tolerance approach to bribery and corruption. 

Code of Business Ethics

We have a group Code of Business Ethics (the Code) whose purpose is to establish the standards of business ethics and conduct expected of everyone who carries out work for us or on behalf of us, including contractors. The Code is regularly updated, most recently in November 2016, along with our Business Principles, which identify the behaviours we expect from our personnel. Application of the Code throughout the business is ensured by the highest level of management, the Board. The Board’s audit committee is responsible for appointing an internal auditor to regularly conduct internal audits of Cairn’s compliance with the Code. All levels of management at Cairn, including executive and non-executive directors, regional directors, general managers and heads of departments, are responsible for ensuring consistent application of the Code. All personnel must abide by the Code and promote its use in all business activities. All employees are required to sign up to the Code as part of their employment conditions.

The Code includes our commitment to:

  • legal and regulatory compliance;
  • a zero tolerance approach to bribery and corruption;
  • respecting human rights;
  • not making contributions to political parties, organisations or individuals engaged in politics or political lobbying, as a way of obtaining advantage in business;
  • providing a workplace free from discrimination and harassment; and
  • financial integrity and reporting.

Whistleblowing procedure

Employees are encouraged to report any incident they believe may compromise our Code of Business Ethics. They can do this in a number of ways, including using a confidential phone line or speaking directly to their regional director. Where appropriate, the procedures can also facilitate an independent investigation of any matters raised. The Group’s whistleblowing procedure was reviewed and approved by the Board in December 2015.

Cairn is now registered with the whistleblowing charity Public Concern at Work, which offers staff an alternative way of reporting an issue if they are not comfortable using internal procedures.

There were no reported incidents raised through the whistleblowing procedure in 2016.

KPIs

  • Incidents of non-compliance with the Code of Business Ethics
  • Employee dismissals for non-compliance with the Code of Business Ethics

Anti-bribery and corruption

Our anti-bribery and corruption management system (ABCMS) has been developed to manage such risks through all stages of the exploration and production lifecycle. Country- and Company-level anti-bribery and corruption (ABC) risk screening forms an important part of the decision-making process when entering new countries or negotiating with potential partners and major suppliers. We also subscribe to a number of due diligence tools, which enable us to complete comprehensive risk assessments of business partners, suppliers and other third parties.

As part of our ongoing commitment to establishing a culture of zero tolerance to bribery and corruption, in 2016 we required all personnel, including contractors, to complete a bespoke e-learning module to ensure their continued understanding and application of our ABC policies and procedures.

Employees trained in Cairn’s anti-corruption policies and procedures (%)

2012: 23, 2013: 27, 2014: 59, 2015: 15, 2016:91

Monitoring and responding to ethical issues

Throughout the year we track emerging ethical issues of importance to our business and the industry by monitoring emerging legislation, guidance and agreements; press commentary and stakeholder enquiries, and through focused stakeholder engagement. See our position with regards to Western Sahara.

In 2016, we reviewed our potential contribution towards the UN Sustainable Development Goals (see Sharing benefits in Senegal), our readiness to report against the Modern Slavery Act 2015 (see Human rights) and the implications of the COP21 Climate Change agreement (see Climate change review).

Transparency

Cairn is committed to being open and transparent in all aspects of its business and this includes in its communications with stakeholders and in its reporting.

Communicating with shareholders

Shareholders are important stakeholders, and they are key to our funding position, consequently we invest significant resource in effective shareholder communications. We respond promptly to correspondence from shareholders and our website includes a dedicated Investor relations section.

To ensure the Board maintains an up-to-date understanding of the views of major shareholders, there is a focused and structured programme of regular shareholder dialogue. The Board is kept informed of any issues raised by shareholders through Board papers where shareholder concern is a standing agenda item, through feedback at pre-Board meetings and following significant announcements. In addition, we maintain an investor relations database, which details all meetings between Cairn and its investors.

Read more on Transparency regarding reporting, Remuneration and Government relations.

Objectives 2017

  • Continue to improve our Code of Business Ethics and Business Principles
  • Enhance the gifts and hospitality register
  • Anti-bribery and corruption (ABC) training targeted at high-risk areas

Strategic objectives

  • Maintain licence to operate
 

Principal risks

  • Negative stakeholder reaction to our operations
  • Fraud, bribery and corruption

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