| |
|
| |
Frank Chapman,
CEO BG Group |
| |
|
 |
 |
| |
|
Translations of the BG Group Speak Up policy are available in the following languages: (PDF format - links open in a new window)
Install the latest version of the free Acrobat reader | |
| |
 |
BG Group is a global business operating in diverse cultures and business environments. Our reputation for high standards in all that we do is crucial to our business success. We must have confidence that this reputation is earned and maintained by continued commitment to the highest standards of corporate responsibility, governance, compliance and accountability as set out in our Business Principles.
The Group’s Business Principles set out the core values and behaviours that define the way we work. BG Group employees have a duty to Speak Up promptly if they have any reason to suspect that there has been a breach or potential breach of our Business Principles or any other misconduct. You may raise your concern in confidence and if you want anonymously. When raising a concern, it is important that you provide as much information as possible so as to enable a proper investigation to be carried out. By coming forward and raising concerns you are fulfilling one of your responsibilities as an employee. You are also doing the right thing and helping to make BG a stronger and more effective company.
Usually, speaking to your line manager will be all that is required to achieve a satisfactory outcome – this should be the first step for any concerns as your manager will generally be closest to the situation and best able to help. Please think about this route first. However, we recognise that there may be instances when employees feel unable to raise concerns with their line manager. This BG Group Policy – Speak Up – provides an alternative reporting channel for those situations. It is independent, external and confidential. I recognise that it may sometimes not be easy to make the decision to raise a concern but you have my assurance that, when concerns are raised in good faith, confidentiality will be protected and retaliatory action will not be tolerated.
We all share the values expressed in the Group’s Business Principles. Together with the values goes the responsibility for upholding them. I hope I can rely on you to help us strengthen and build our company by speaking up when it is necessary.
Frank Chapman
CEO BG Group
Purpose, Scope and Guiding Principles
BG Group wants to know about any breach or potential breach of our Business Principles, 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 employees therefore have a duty to Speak Up promptly if they have any reason to suspect that there has been a breach or potential breach of our Business Principles 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.
This Policy explains how employees and any other individual or organisation should report their concerns, the types of issues that are covered by the Policy, guidance on how individuals can seek assistance when they have a concern and what they can expect if they raise a concern.
BG Group will not tolerate retaliation against any employee who in good faith seeks advice, raises a concern or reports misconduct.
Responsibility for investigating concerns raised under this Policy rests with the General Counsel, who reports to the Governance and Risk Committee for this purpose. The Governance and Risk Committee, a sub-committee of the GEC, has responsibility for keeping the Policy under review and amending it as necessary.
All concerns raised under this Policy will be monitored to ensure that the Company takes appropriate action to redress any issues. Any concerns regarding accounting, internal accounting controls or auditing matters will be reported to the Audit Committee.
Scope
The Speak Up Policy applies worldwide to all workers in BG Group companies.
In this context, “worker” means all employees of BG Group and any employees working for entities and third parties such as contractors and agency workers.
The duty to report concerns applies to all employees of BG Group. To fulfil this duty, employees must provide as much information as possible to ensure that a proper investigation can be carried out and must respond to requests for further information as the investigation progresses.
Depending on the terms of their contracts, employees working for entities and third parties such as contractors and agency workers may also have a duty to report concerns under this Policy. Where there is no such contractual obligation, third party workers are encouraged to use this Policy and bring their concerns about BG Group or anyone acting on our behalf to our attention.
Any other individual or organisation such as a joint venture partner, supplier or family member can also use this Policy 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 a worker feels uncomfortable doing this, depending on the nature of the concern, they are encouraged to get help or advice from an appropriate BG Group function, such as:
However, if workers 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 facility.
The Speak Up telephone line and web reporting facility is operated by Global Compliance an independent company and market leader in ethics and compliance services. Contact details for the Speak Up line may be found under question 2 below.
The Speak Up line is available around the clock, every day of the year, in all countries where BG Group has a presence and in all the relevant languages. No call tracing or recording devices are used.
Speak Up gives all workers and any third parties a simple and secure facility to raise any concerns. If requested, reports to Speak Up can be made anonymously.
QUESTIONS AND ANSWERS
- Why have this Policy?
The Speak Up Policy is here to help you raise your concerns about malpractice at an early stage and in the right way. We would rather that you raised the matter at the earliest opportunity than wait for the situation to deteriorate.
We recognise that you may be worried about raising such issues or may want to keep the concern to yourself. We assure you that, by using this procedure, your concern will be dealt with effectively, discreetly and, if you wish, anonymously.
- I have decided that I want to report my concern using the Speak Up facility – how do I make contact?
The Speak Up facility is operated by an independent company. The telephone line operates 24 hours a day/seven days a week and also has translation services available at all times. When you make contact, please make it clear which language you want to use.
you can telephone. There are telephone numbers for all countries in which BG Group has a presence. Where possible, telephone numbers have been set up on a toll-free basis. To find your local number please go to the current list of numbers. This list also confirms whether we have been able to set up your local number on a toll free basis.
you can report on-line using the Speak Up web-based system provided by the same independent company at www.bg-speakup.com .
Alternatively, you can report your concern to the General Counsel of BG Group by sending a letter to Graham Vinter, General Counsel BG Group, 100 Thames Valley Park Drive, Reading, Berkshire, RG6 1PT United Kingdom, emailing him at graham.vinter@bg-group.com, sending him a confidential fax to the following number 0118 929 3791 or telephoning his direct dial number 0118 929 2590.
- What happens when I call Speak Up – can I call anonymously?
Your call goes through to the independent company Global Compliance. Those staffing the Speak Up line are highly trained in collecting the right, relevant information and in ensuring anonymity if required.
The operator will listen and make a detailed summary of your call. At the end of the call, you will be given a unique tracking number so that you can follow up on the report anonymously.
The person taking your call will then forward your question or concern to the BG Group Business Principles Investigations Committee (BPIC) which comprises the General Counsel, Executive Vice President Policy & Corporate Affairs, Chief Counsel Corporate Responsibility and the General Manager Human Resources Operations. The BPIC will review the report and decide on the form of investigation to be taken. This will involve either an internal investigation or, if appropriate, a police investigation. The General Counsel makes regular reports to the Governance & Risk Committee on concerns received and related investigations and remedial actions. He will refer any complaint regarding financial matters to the Head of Group Audit, who may then refer the matter to the Audit Committee.
If any of the above BG Group individuals could be implicated, the person taking your call will forward your concern to the Company Secretary.
If you report a concern outside UK business hours and Global Compliance assess your concern as representing an imminent threat to BG Group, Global Compliance will contact the out of hours BG Group Duty Manager. The Duty Manager will ensure that appropriate immediate action is taken and will transfer the case to the Investigations Steering Committee on the next business day following receipt of the report. In all cases, Global Compliance will check that the Duty Manager is not implicated before forwarding the concern.
- What happens when I make an on-line report?
The Speak Up reporting website is hosted by the independent company Global Compliance.
You will be asked if you want to remain anonymous. If you indicate that you do wish to remain anonymous, all fields requesting identifying information are removed. IP addresses are not captured from web-based communications, ensuring anonymity is maintained. You will be given a unique tracking number, allowing you to receive a response or provide more information.
Once the report is placed on the Speak Up secure server, it is made available to you and to the selected BG report recipients referred to above in question 3. To ensure confidentiality, reports are never faxed or emailed and are only available by accessing the Speak Up secure server. The system ensures that reports are never shared with an implicated party, even if that person typically has access to the reports.
- I don’t want to make an on-line report using my work pc – can I make a report using my home pc?
Yes, you can use any computer with access to the internet to make an on-line report.
- I am not a BG Group employee; can I still contact Speak Up?
Yes; BG encourages all workers, including third party contractors and agency workers, (and their families) to raise concerns. Any other individual or organisation can also use this Policy to report concerns regarding the conduct of BG Group or anyone acting on our behalf.
- Do I have to give my name?
No. You may raise a concern anonymously and in confidence under this Policy.
However, if you do not tell us who you are, it will be much more difficult for us to look into the matter, to protect your position or to give you feedback.
If the situation arises where we are not able to resolve your concern without knowing your identity, we will ask Global Compliance to discuss with you whether and how we can proceed. If you have identified yourself, we will treat your concern confidentially but there may be circumstances where BG Group is required to disclose your identity – for example in a legal proceeding or government investigation.
If you have raised a concern anonymously, and, after investigation, BG Group suspects that you maliciously raised a matter which you knew to be untrue, BG may take steps to try to identify you and take disciplinary action up to and including dismissal.
- If I report a concern and give my name, could I get into trouble?
If you raise a genuine concern under this Policy, you will not be at risk of losing your job or suffering any form of reprisal as a result. We take claims of retaliation seriously. Allegations of retaliation will be investigated and appropriate action taken. Anyone responsible for reprisals against individuals who report in good faith suspected misconduct or other risks to the business will be subject to disciplinary action up to and including dismissal.
As long as you are acting in good faith, it does not matter if you are mistaken. However, if you maliciously raise a matter that you know to be untrue, this could result in disciplinary action up to and including dismissal.
- What if I am implicated?
BG Group will protect you from retaliation in respect of the disclosure, but we cannot give you immunity.
- What feedback can I expect?
While the purpose of this Policy is to enable us to investigate possible malpractice and take appropriate steps to deal with it, we will give you as much feedback as we properly can. However, we may not be able to tell you the precise action we take where this would infringe a duty of confidence owed by us to someone else. Follow up by the company may not therefore be apparent to you due to the need for confidentiality of all parties involved.
- If I suspect fraud, what should I do?
If you have a concern about fraud, you are encouraged to raise this with your line manager or Fraud Officer (see the Fraud Risk Management Standard which is available on the Group portal under BG Advance, BG Advance Home, BG Standards & Guidelines). However, if you would prefer you can use the Speak Up facility (see questions 2, 3 and 4 above) and the matter will be referred to the BG Group Business Principles Investigations Committee.
Policy Owner – Legal Department
Effective Date: April 2008
|