2.1.1Ethics & Compliance
management approach
In all communities in which SBM Offshore operates, SBM Offshore is committed to conducting its business honestly, ethically, and lawfully, which is vital to maintain the trust and confidence of stakeholders in SBM Offshore’s long-term value creation. SBM Offshore does not tolerate bribery, corruption, fraud, or violations of trade sanctions, anti-money laundering or anti-competition laws, or any other illegal or unethical conduct in any form by anyone working for, or on behalf of, SBM Offshore.
All employees, and those working for or on behalf of SBM Offshore, must embrace and act in accordance with the core values of SBM Offshore (see section 1.3.1), the Code of Conduct and SBM Offshore’s internal policies and procedures.
SBM Offshore fosters a culture of trust and fairness, where dilemmas are openly addressed. SBM Offshore’s aim is to enable its employees and business partners to make the right decisions, with commitment to integrity at all levels. SBM Offshore is an active member of International Chambers of Commerce Nederland and Transparency International NL.
For further details on SBM Offshore’s management approach, its purpose and its assessment, refer to sections 1.4.1, 3.6 and 3.6.2.
How SBM Offshore measures performance
SBM Offshore uses a single and integrated platform to manage compliance tasks. This platform is continuously improved and uses data to predict and avoid compliance risks. It allows SBM Offshore to standardize and automate processes where possible, aiming for a high level of quality, effectiveness, and efficiency.
The compliance platform includes the following tools:
- Compliance e-Learning, with training hours and completion ratio data available by employee target group.
- Automated continuous monitoring of third parties (due diligence process).
- Registration and approval of charitable contributions and sponsorships.
- Gifts, hospitality and entertainment registration and approval.
- Annual compliance statements of designated staff.
As part of performance management processes, SBM Offshore sets, monitors and reports on compliance KPIs. Integrated quarterly group risk and compliance reports are discussed with the Management Board and the Audit and Finance Committee of the Supervisory Board.
2021 PERFORMANCE
Notable developments and achievements in 2021
- CGU officially released SBM Offshore from reporting duties in Brazil, ending the monitoring period.
- Revamped Speak Up Policy and Speak Up Line.
- Team organized in accordance with business needs and priorities.
- Annual (virtual) training for all staff (including offshore).
- Tailored training for high-risk functions embedded in business programs.
- Expanded reach through nomination of offshore compliance ambassadors.
- Target group for annual compliance statement expanded to cover all onshore staff.
Metrics
The number of employees eligible to file the Annual Compliance Statement was in 2021 substantially higher than in 2020 (4,357 employees in 2021 versus 1,083 in 2020). The number of Compliance training courses completed in 2021 is substantially higher than in 2020 (11,011 training courses in 2021 versus 7,380 in 2020).
|
Annual Compliance Statements |
Designated Staff1 |
|---|---|
|
Number of employees per year-end |
4,357 |
|
Onshore Completion ratio |
96% |
|
Offshore Leadership Completion ratio |
76% |
- 1 Designated Staff reflects all onshore staff and offshore leadership
|
Compulsory Compliance Tasks Completion1 |
All Staff |
|---|---|
|
Number of employees per year-end |
4,188 |
|
Onshore Completion ratio |
96% |
|
Offshore Leadership Completion ratio |
79% |
|
Offshore non-Leadership Completion ratio2 |
40% |
- 1 Including Code of Conduct, theme based e-Learning courses and annual compliance statements
- 2 New audience, completion ratio impacted by reachability, subject to continuous improvement
|
Overall number of Compliance Trainings conducted in 2021 worldwide |
Trainings |
Training hours |
|---|---|---|
|
Face to face trainings1 |
1,839 |
1,998 |
|
e-Learnings2 |
9,172 |
6,804 |
|
Total |
11,011 |
8,802 |
- 1 An employee can have attended multiple face to face trainings
- 2 An employee can have completed multiple Compliance e-Learning courses
|
Face to face training categories |
Trainings |
Training hours |
|---|---|---|
|
Annual Code of Conduct training |
33 |
58 |
|
Targeted Compliance topic training1 |
1,713 |
1,851 |
|
Training of third parties2 |
93 |
89 |
|
Total |
1,839 |
1,998 |
- 1 Training on relevant Compliance topics for risk based target audiences
- 2 Mainly strategic vendors, contracted yards and manpower agencies
|
Speak Up Line reports |
Total |
|
|---|---|---|
|
Reports received under SBM Offshore’s Speak Up Policy |
88 |
No confirmed instances of corruption occurred during 2021.
Future
In 2022, SBM Offshore aims to continuously strengthen compliance management and control by focusing on the importance of the right behavior and through continuous alignment with business needs and priorities. SBM Offshore will continue to embed Compliance by:
- Promoting a speak up culture and responsible business conduct.
- Further developing digital tools.
- Increasing monitoring and reporting capabilities by progressing to data-driven compliance.
- Applying a risk-based approach to third-party screening.