SHV Energy’s purpose: Advancing Energy Together
We place a great deal of trust in our people in the field. They are committed to doing business in a fair manner, and are driven by the Corporate Values that serve as the foundations of our culture. Our most important values are integrity and loyalty. Integrity means being honest, genuine and totally open in communications about all matters that concern the company. Loyalty means putting our best efforts into our work for the company and its development.
Our Ethics & Compliance programme focuses on how we transfer these values into behaviour through our People, Policies and Processes. The business is accountable for Ethics & Compliance, and we employ Compliance professionals to advise us about legislation, as well as to help us create a comprehensive set of policies and assurance processes that define how we can operate in the most responsible and compliant way.
The right tone at the top
Setting the right tone at the top is the first ingredient for a solid Ethics & Compliance programme. That is why our Group CEO and all business unit managers are committed to leading by example. This creates the right climate, and it is the cornerstone upon which our integrity culture is built. It is also essential to fortifying our organisation’s reputation and our relationship with all stakeholders.
Constantly enhanced Ethics & Compliance
SHV Energy consistently addresses a variety of Ethics & Compliance topics, and they are also regularly discussed at a management level during Ethics & Compliance Committee meetings. From a business context point of view, we are of course fully aware of the risk of issues such as Competition Law, Anti-Bribery & Corruption, Export Control and Sanctions, Privacy, Third Party Due Diligence and Fraud.
Each of our business units has at least one Compliance Officer to coordinate our Ethics & Compliance activities. Initially, this role was an add-on, but an increasing number of business units are now switching to a full-time Compliance Officer. The Group Ethics & Compliance team regularly interacts with these Compliance Officers to exchange information, share best practices and implement the policies, procedures and guidelines we use to constantly improve our Ethics & Compliance processes.
A focus on awareness and prevention
An important pillar of our integrity programme is based on prevention – we consider raising awareness of integrity risks to be a vital preventive measure. Our primary focus is on training and communication for all employees to ensure that our values are understood and to prevent non-compliant behaviour. Some of this training is done through e-learning, and we start as soon as possible. New employees must complete online training in relevant Ethics & Compliance subjects within two weeks of joining our company. After that, they are requested to do e-learning training bi-annually. We organise face-to-face training for employees who do not have an email account. In addition, we discuss integrity and related integrity risks and we train our management teams on Ethics & Compliance. Enhanced face-to-face training is also provided to many teams across our organisation, and is often part of the agenda during leadership programmes.
A confidential whistle-blowing process
In 2017, we re-enforced our Speak Up whistleblowing process. Employees can report integrity concerns in a variety of ways, including a web-based hotline run by a third party, which is available 24 hours a day, seven days a week, in all relevant languages. All reports are treated confidentially – employees can choose to remain anonymous, and we make a firm promise that we will protect all whistle-blowers from retaliation.
Clear policies, manuals and guidelines
SHV Energy has clear policies, manuals and guidelines in place to support integrity and correct behaviour across our company. In order to make these policies accessible to all employees, we intend to build a simple yet solid policy house to store these documents. Where relevant, and based on policies from SHV Holdings, we are enhancing our own policies, manuals and guidelines in various areas – especially in the fields of Trade Sanctions & Export Controls and Third Party Due Diligence. We draft and test these documents in close cooperation with relevant people in the business, and we intend to further implement them during 2018.
Other initiatives in 2017
Anti-Bribery & Corruption activities
Based on the identified actions resulting from the internal audit on bribery risks performed in 2016, we have worked with the various stakeholders to increase risk awareness levels across our business units in order to mitigate them. We strengthened our way of working with third parties, especially agents. Together with Internal Audit, we enhanced some of our internal processes in order to further minimise risks of fraud. We intend to develop and implement a revised Anti-Bribery & Corruption policy and roll-out a new Anti-Bribery & Corruption e-learning in 2018.
Ensuring GDPR and privacy compliance
In order to be compliant with the General Data Protection Regulation (GDPR), effective as of 25 May 2018, SHV decided to adopt Binding Corporate Rules: the SHV Privacy Codes. These codes will allow us to legally perform the cross-border exchange of personal data from employees and third parties within the company. SHV Energy will implement these SHV Privacy Codes globally. In 2017, we prepared for GDPR by developing a full implementation plan addressing all relevant aspects and processes. We have dedicated staff both at the SHV Energy level and the business unit level, and firm cooperation between our central team and business unit Privacy Leads led to a solid start in implementation in 2017.
Our 2018 initiatives
In 2018, we will continue to dedicate our attention and resources to the solid implementation of GDPR and the SHV Privacy Codes. We will also implement an enhanced process for Trade Sanctions & Export Control and a solid process for Third Party Due Diligence. Furthermore, we intend to launch a revised Anti-Bribery & Corruption policy and implement a new Anti-Bribery & Corruption e-learning module. At the same time, more of our business units will hire a dedicated, full-time Compliance professional. Involving these new colleagues will strengthen cooperation and communication within our Ethics & Compliance community.