What goals does a compliance policy aim to achieve?
Sylvie Rapin: Our compliance programme allows us to secure our activity and reassure our stakeholders on the steps we’re taking to prevent non-compliance risks. It guarantees transparency and long-term success. Today, a group like TOTAL, which operates in over 130 countries, works internationally in accordance with an ethics code and a standardised global compliance policy.
Christian Laveau: A compliance programme is indispensable for operating in the oil and gas industry. Standardising BOURBON’s ethics and compliance policy allows us to have a common approach and rules with regards to compliance and anti-corruption. It also allows us to keep up with ever tightening regulatory frameworks.
S.R.: In the extractive industries, the global EITI (Extractive Industries Transparency Initiative) has been retained because so much money is at stake and the countries we operate in are changing and restructuring.
C.L.: Just like safety, the risk of non-compliance represents a major risk in our industry. The potential impact on finances and reputation is considerable. Not managing the risk of non-compliance concerning, for example, facilitation payments, the rules regarding embargoes, or business gifts can have serious consequences and leads to a loss of confidence among employees, stakeholders and all parties involved.
How can your policy be implemented in all the countries where you operate?
S.R.: It rests above all on engaging management at the highest level to analyse the risks and draft rules that are easy for everybody to understand. Our policy, which is spelled out in our code of conduct, is distributed to new employees and all interested parties. To make sure it is correctly applied, we rely on several stages of raising awareness, communication, and training, not forgetting monitoring and, if necessary, sanctions.
C.L.: BOURBON has a similar approach to TOTAL with our deployment of the ‘six pillars’ of our compliance programme. To complement this in terms of raising awareness and training, BOURBON has put in place clear sanctions linked to the non-respect of internal procedures. The emphasis is on winning the support of everybody in the organisation to respect these rules to ‘protect’ the company and its employees and boost competitiveness. Our motto, “Compliance, no compromise”, clearly states our goal.
S.R.: Employees must understand that this approach is fundamental to how the company works.
C.L.: I totally agree. We must continue to educate and raise awareness in order to work towards zero risk.
SYLVIE RAPINBRANCH COMPLIANCE OFFICER, TOTAL E&P
"Good compliance is a quiet success, like a good safety policy with zero incidents."
Which tools have been rolled out to raise employee awareness?
S.R.: In addition to 80 compliance officers in each entity, we have outreach tools like e-learning, which makes it easier to understand compliance principles on a daily basis. A dedicated e-mail address lets everybody express his or her concerns as quickly as possible, receive advice and report instances of non-compliance with the rules. A tool to register gifts, invitations, donations and conflicts of interest is available to each employee at their work station.
C.L.: BOURBON relies on a corporate team, a network of 26 compliance officers in the locations where it operates, a code of conduct and a compliance e-learning programme. This enables employees to reduce the risks they are exposed to and become more effective. Compliance success in the long term means never letting down your guard.