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Business Ethics

Ensuring ethical business conduct and compliance by those working in and for the Company.

Our ambitions

Why it is important

Integrity is one of Subsea 7’s six Values: we are committed to complying with applicable laws and applying the highest ethical standards in everything we do, treating our clients, people, partners and suppliers fairly and with respect.

Our sector can present significant corruption risks, as can many of the countries in which we operate. We recognise our duty to manage the human rights impacts of our business on people and communities where we operate – and corruption is one of those potential impacts. We have a zero tolerance approach to corruption, and we want to play our part in combatting it. 

Our Compliance and Ethics Programme

The Subsea 7 Compliance and Ethics Programme is designed and implemented in accordance with international best practice, including the International Anti-Bribery Management System Standard ISO 37001:2016. Much of our focus in recent years has been on anti-bribery/anti-corruption (ABAC), as well as competition/anti-trust, sanctions and export controls.

What is covers

Our programme has a broader scope which is defined by our Ethics Policy Statement and our Code of Conduct (both approved by the Board of Subsea 7 S.A.).

In recent years, increased regulatory and stakeholder demands and expectations have continually raised the bar and brought other compliance and ethics risks to prominence, including tax evasion, human trafficking and modern slavery, and other human rights risks. In relation to these few topics, there is a clear overlap with business ethics.

As with safety, we take a management system approach to embedding a culture of ethics and integrity and managing legal and reputational risks. The Subsea 7 compliance and Ethics Programme has been developed to prevent bribery, corruption, and other legal and business ethics breaches by the Company and all who work for us – including suppliers and other third parties. 

Ethics Committee

We have an Ethics Committee comprising all members of the Executive Management Team, which oversees the implementation and continual improvement of the programme and approves the strategy and priorities. In conjunction with the Board, it also oversees our Speak Up Policy, procedures and channels, and any significant compliance and ethics incidents and investigations.

Management system approach

We take a management system approach to embedding a culture of ethics and integrity and managing legal and reputational risks. The Subsea 7 Compliance and Ethics Programme has been developed to prevent bribery, corruption, and other legal and business ethics breaches by the Company and all who work for us – including suppliers and other third parties.

In order to monitor and continually improve our programme, we conduct internal audits of compliance with relevant financial controls, supply chain management procedures, our due diligence and gifts and hospitality policies and procedures, and other aspects of our programme. We have also engaged an external expert firm (GoodCorporation™) to perform independent assessments of our programme, both at a Group level and in selected countries.

Ethics and Integrity

A key element of our approach to compliance is to emphasise ethics and integrity. We want people to care about the impacts of corruption and the consequences of different types of compliance breach (which is why we refer to it as compliance and ethics); and we want to inform people about what integrity means to Subsea 7; empower them to bring their personal integrity to work; and educate them on how to use personal and Company integrity to make the right decisions in their work.

Our targets

  • 100% Medium and high-risk suppliers assessed for anti-corruption risk by 2025 (90% by 2022)
  • 100% Proportion of the business covered by an independent anti-corruption compliance programme assessment by 2025 (85% by 2022)
     

Our commitments

Principle 10 of the UN Global Compact identifies the importance of businesses working against corruption in all of its forms. Through a range of initiatives, policies and processes we have continued to strengthen our approach to maintaining ethical business conduct

Subsea 7 supports the UN Sustainable Development Goals