Our people want to do business in a fair and transparent manner and are driven by integrity. As such, this is our principal value formalised in our Ethics & Compliance programme. This programme consists of a comprehensive set of policies, manuals and guidelines as well as assurance processes that defines how we can operate in the most responsible and compliant way possible. Regular training sessions aim to prevent staff from mere box ticking. Rules need to be updated regularly following feedback from our employees, our customers and other stakeholders.
Long-term value is created by doing business in an honest and transparent way, complying with the laws and regulations wherever we operate. We all contribute to safeguarding the company's integrity and reputation. This safeguarding process is overseen by the Ethics & Compliance function, consisting of a centralised Ethics & Compliance team at our head office and Compliance Officers at all SHV Energy business units.
"Long-term value is created by doing business in an honest and transparent way, complying with the laws and regulations wherever we operate. We all contribute to safeguarding the company's integrity and reputation."
Our Ethics and Compliance philosophy relies on setting the right example. Since leaders are visible and influential in what they do, other employees will follow. It creates the right climate and it is the cornerstone upon which our integrity culture is built.
A solid Ethics & Compliance framework is important. Policies, manuals, guidelines and procedures, containing as little "legalese" wording as possible, are available to support the right behaviour across our company. When possible and relevant, we issue clear and concise guidance to provide employees with the appropriate amount of information needed to perform a task. Combined with training and sufficient monitoring, the programme simultaneously covers legal and behavioural compliance. Our people are encouraged to voice any concerns about workplace practices. Ideally, they are able to speak with the person involved, their manager, HR or the Compliance Officer. If that is not seen as a suitable solution, we have our "Speak Up" helpline, a confidential whistle-blowing line where people can raise their concerns via internet or telephone.
In 2018, we implemented a solid process for third party due diligence through which we obtain the right information to assess the integrity of a third party. We also implemented the SHV Privacy Codes, in accordance with the General Data Protection Regulation (GDPR) which is overseen by a Data Protection Officer. These Codes allow us to legally perform the cross-border exchange of personal data from employees and third parties within the company. As part of our operations we process personal data, and we are fully committed to protecting the personal data of all our stakeholders.
Policies and manuals
An updated Anti-Bribery & Corruption policy and manual have been introduced, supported by a new e-learning module to make everyone aware of the importance of doing business in an honest way.
We also pay a lot of attention to competition law, promoting and ensuring fair competition and forbidding illegal practices like price-fixing and market-sharing. Furthermore, we pay attention to trade sanctions and export controls. We see that international sanctions are becoming more and more important in international politics, often with major, immediate consequences for our business.
Apart from the framework and risk assessments, we boost awareness among staff by referring to the why of things. By providing e-learning modules, face-to-face training and portion-sized information, we create overall awareness. It is our aim to provide the right amount of information to the right target group. We cannot avoid risks altogether, but we can visualize them and do our best to mitigate them. Sharing experiences and best- and worst-case scenarios can help to see the causality of actions and the real long-term benefits of doing the right thing.