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Business Ethics

Subsea 7 is committed to carrying out its business ethically and complying with applicable laws. We aim to act fairly, honestly and with integrity at all times. 

"Integrity is one of our core values, and we apply the highest ethical standards to everything we do."


John Evans

Chief Executive Officer

Ethics Policy Statement

Our Ethics Policy Statement sets out our commitment to acting honestly, fairly and with integrity at all times, to comply with the law, and to treat people with respect. By so acting, we earn the trust of our clients, employees, business partners, suppliers and other stakeholders. 

Our Code of Conduct

We conduct our business in accordance with all applicable laws and regulations and in an ethically responsible manner. Our Code of Conduct applies to all our people. It sets out the key principles that we are all committed to upholding and which line management are responsible for communicating and implementing.

Our Compliance and Ethics Programme

Subsea 7 Group has a compliance and ethics programme designed to embed our Code of Conduct and help manage compliance (also referred to as “conduct”) risks, including prevent bribery and other unethical conduct by the company and those who work for us. The programme is informed and underpinned by our Values and our Board’s determination to conduct business ethically and in a way that is consistent with our Values: Safety, Integrity, Sustainability, Performance, Collaboration and Innovation.

Our programme is summarised in the this graphic:


While much of our focus has been on anti-bribery/anti-corruption (ABAC), as well as other legal compliance areas such as competition/anti-trust, sanctions and export controls, and tax evasion, the programme also has a broader, business ethics scope which is defined by Subsea 7’s Ethics Policy Statement and Code of Conduct. Increasingly, we are leveraging various aspects of our programme (such as risk assessments, due diligence, training and supply chain management procedures) to assess and manage modern slavery, human trafficking and other human rights risks.

More details about our Compliance and Ethics Programme, including our ABAC Programme, can be found here
 

Speak Up Policy

We have a clear Speak Up Policy, which offers various channels for raising concerns, including an externally administered and monitored confidential reporting line, Safecall, which is extensively promoted within Subsea 7 Group. All personnel are encouraged to utilise one of these reporting channels if they become aware of a possible breach of our Code of Conduct or have other concerns in respect of unethical conduct.

Code of Conduct for Suppliers

Our compliance and ethics programme also includes our Code of Conduct for Suppliers, which sets out the key principles of ethical conduct that our suppliers agree must be upheld when working with us. When an organisation asks you to comply with its Code of Conduct, it can seem like an imposition. Our Values underpin everything we do, including whom we choose to do business with and how we and our suppliers work together.