BG Group wants to know about any breach or potential breach of our Business Principles, Policies and Standards, unlawful conduct, financial malpractice or dangers to the public, the environment, or to anyone working for BG Group, that may be occurring despite our rigorous compliance procedures.

BG Group personnel therefore have a duty to Speak Up promptly if they have a reasonable belief that there has been a breach or potential breach of our Business Principles, Policies and Standards or any other misconduct. If an issue is raised internally first, and acted upon, it is likely to reduce any damage that may otherwise occur. Reporting of issues will detect and possibly deter any further wrongdoing.

Possible breaches of BG Group’s Business Principles and Policies include:

  • Ethics and compliance issues, such as financial mis-reporting, insider trading, bribes or conflicts of interest;
  • Employee relations and human resources issues, such as harassment or discrimination;
  • Loss prevention and asset protection issues, such as criminal activity (for example fraud, threats and violence, alcohol/drug abuse or internal theft), the security and protection of assets and facilities or actions involving harm to the environment; and
  • Health and safety, such as taking unnecessary risks, not following mandatory Standards or false reporting.

BG Group will not tolerate harassment or retaliation of any kind against anyone who seeks advice or raises a genuine concern about a breach or potential breach. Any personnel who subject a colleague to such treatment will face serious consequences such as disciplinary action or contract termination. They may also expose themselves and BG Group to legal liability.1

Applicability

Every employee, director or officer of every wholly owned BG Group company and in every joint venture company under BG Group control must follow this Policy. Contract personnel working for BG Group companies must also follow this Policy. Contractors and consultants are required to act consistently with this Policy when working for BG Group companies as our agent, on our behalf or in our name, on any business activity including when delivering outsourced services.

Any other individual or organisation such as a joint venture partner, supplier or family member are encouraged to report concerns regarding the conduct of BG Group or anyone acting on our behalf. Such openness can help information reach us which may otherwise go unnoticed, for example bribery or exploitation of gifts and hospitality.

Raising concerns – where to go for help

Line management is the right first place for concerns to be raised as managers will generally be closest to the situation and best able to help. If an individual feels uncomfortable doing this, depending on the nature of the concern, they are encouraged to report their concerns to one of the independent and confidential internal channels such as:

  • Head of Ethical Conduct;
  • General Counsel;
  • Group Company Secretary;
  • Local Compliance Officer;
  • Legal;
  • Group Audit; and
  • HR.

However, if individuals ever feel unsure about where to go for help or are uncomfortable raising the matter using one of these internal routes, they have the additional option of reporting concerns to an independent third party using the Speak Up telephone and online facility (Speak Up facility).

The Speak Up facility is operated by Global Compliance: an independent company and market leader in ethics and compliance services.

The Speak Up facility is available round the clock, every day of the year, in all countries where BG Group has a presence and in all relevant languages. On contacting the Speak Up facility, issues will be handled confidentially and, if requested, anonymously.

Everyone raising a Speak Up report must keep confidential the fact that an investigation is being conducted, since failure to do so may prejudice the course of the investigation.

Raising concerns –BG Group response

BG Group will promptly respond, under the direction of the General Counsel, to all genuine concerns raised and:

  • use reasonable endeavours to keep the identity of the individual raising a concern and the information received confidential, while recognising that BG Group may, in certain circumstances, be required to disclose information and identities of individuals, for example in legal proceedings or government investigations or in order to implement any recommendations made by the Speak Up and Fraud Investigation Committee or to take other appropriate action to address the findings of an investigation into a concern; 
  • when appropriate, provide feedback to the individual who raised the concern;
  • track the progress of each case, implement recommendations and ensure that appropriate actions are taken, including disciplinary action when required; and
  • where appropriate, report actual or suspected breaches of law to the relevant law enforcement agencies.

In some circumstances (depending on the nature of the concern raised), BG Group may decide that investigation of the complaint and attempts to resolve it should take place via another relevant procedure (for example a local grievance procedure), particularly where a concern relates to an employee's individual circumstances. BG Group reserves the right not to investigate allegations (in particular anonymous allegations) which appear to be made without a reasonable belief that there has been a breach or potential breach. In those circumstances BG Group may, where appropriate, inform the party against whom the allegation was made and take appropriate action against the person who has made the non-genuine report.

1 Section 47B of the Employment Rights Act 1996 provides statutory legal protection for a worker not to be subjected to any detriment because they have reported a genuine concern.  Any personnel who subjects a reporter to detrimental action is potentially personally legally liable.