www.enrc.com Phone: +44 (0) 20 7389 1440

Communicating Corporate EthicsENRC Compliance

Michelle Witton – Compliance Lawyer

London, 11 June 2014

Reputation and Brand

Reputation and Brand

• New field / function – still very much evolving

• Behaviour (Win hearts & Minds) + Regulation

- Top down v bottom up approaches

• Internal messaging to build and sustain positive, compliant culture

• Real opportunities for creativity and working with Communications

to deliver impactful communications.

What is Compliance?

• Code of Business Conduct / Corporate ethics

• Anti-corruption (ABC) Policy + Gifts and Entertainment Policy

• Competition / Anti-trust Policy

• Ministerial Relations Policy

• Counterparty Due Diligence

• Trade sanctions

• Compliance Risk

• Compliance Training

• Monitoring + Auditing

Compliance - Areas

Bribery and corruption

TI Corruption Perceptions Index

UK

7.7

Trinidad & Tobago

3.6

Egypt

2.8

Indonesia

2.6

Libya

2.6

Angola

1.9

Azerbaijan

1.9

Iraq

1.312/06/2014 6

10 = Best possible Less than 5 = high risk

TI CPI 2013 – Least corrupt

UK

7.7

Trinidad & Tobago

3.6

Egypt

2.8

Indonesia

2.6

Libya

2.6

Angola

1.9

Azerbaijan

1.9

Iraq

1.37

10 = Best possible Less than 5 = High risk

Denmark 90Finland 90New Zealand 90

Sweden 88Singapore 86

TI CPI 2013 – Most corrupt

UK

7.7

Trinidad & Tobago

3.6

Egypt

2.8

Indonesia

2.6

Libya

2.6

Angola

1.9

Azerbaijan

1.9

Iraq

1.38

10 = Best possible Less than 5 = High risk

SOMALIA 8KOREA (North) 8AFGHANISTAN 8

SUDAN 13MYANMAR 15

IRAQ 18

FIFA – Doesn’t play fair….

FIFA Revised Code - My Game Is Fair Play

Siemens

Siemens – case findings

• $1.4bn total bribes paid

• 4,000+ improper payments

• Asia, Africa, Europe, Middle East,

Americas

• Usually paid by outside consultants hired

to help ‘win’ contracts

• Siemens paid fee to consultant, consultant

delivered cash to decision-maker(s)

• Dawn raids

• Simultaneous investigations across 20

countries

• 1,750 investigation interviews

• 500 employees disciplined

• From 5th to 50th preferred company ranking

• Loss of senior personnel

• Total penalty: $1.6b

• Additional costs: approx. $2b hidden costs

• Compliance monitor imposed for 4 years

Siemens – loss to business

Compliance and Communications –

Working together to achieve compliance

- Creating a strong brand for compliance

- Culturally relevant and resonant

- Enhance credibility

- Assisting employees to know

and apply the Code of Conduct

as the minimum standard

wherever we operate.

How are we achieving this?

• Clear visual identity for the Code &

Compliance.

• Easier to read, understand and recall.

• Communicate the Code to our people

in the most suitable way, depending

on location, role and position.

• Our people to tell the story of why it

matters.

Code of Conduct packs

• Code of Conduct packs produced in English,

Russian, Brasilian-Portuguese and French

• A language-specific DVD

• The ENRC Code of Conduct.

• Code “Z Card” with the key principles and contacts

for whistleblowing hotlines and helplines.

• Self-certification Certificate of compliance with the

Code, to sign and return to Compliance.

• Manual

• Website

• Intranet

• Chairmans office

Where can we find the

ENRC Code of Conduct?

Intranet

ENRC Global Whistleblowing Hotline NumbersEmployees who have any concerns or suspicions regarding a breach of the ENRC Code should raise these matters with their

line manager, local Human Resources contact, a higher level of management within their business unit or the General Counsel.

Whether it is bribery, corruption, discrimination, harassment, violence, legal, policy or regulatory violations, environmental issues

or any other matter, Employees should speak to someone about it.

If, for any reason, any Employee feels unable to talk to these people, they may bring their concerns to the attention of the ENRC

“Trust, but Verify!” external whistleblowing hotline. The whistleblowing hotline is a confidential, 24/7 service managed by an

independent company. It can be contacted by telephone or by email. The contact details are outlined below.

UK

Т: 0808 234 9574

Switzerland

Т: 0800 83 6056

South Africa

Т: 0800 891 2843

Mozambique

Т: 841199 (Vodacom)

DRC

Т: +243(0)82 302 7626

Brazil, Fale Conosco

T: 0800 891 2843

China

T: 10 800 110 1045

Dubai

T: 8000 021;

Code: 866 605 3095

Zambia

Т: 8000 021;

Code: 866 605 3095

Kazakhstan

Т: 8 – 800 121 4321

Pin: 866 605 3095

Russia

Т: 8 – 10 800 110 1011

Pin: 866 605 3095

W: http://hotline.enrc.com

E: compliance@enrc.com

ENRC does not tolerate any

harassment or victimisation

(including informal pressures or

any way of disadvantaging any

individual) and will take

appropriate action to protect

anyone who raises a concern in

good faith. If anyone tries to

discourage an individual from

coming forward to express a

concern, it will be treated as a

violation of the Code of Conduct

and of this policy, and as a

disciplinary offence.

Corporate Values Case Study - BP

Corporate Values – BP – Pre 2010

• Progressive

• Responsible

• Innovative

• Performance

Driven

Deep Water Horizon - 20th April, 2010

Corporate Values – BP – Revised 2012

“ We are BP ” – Safety

– Respect

– Excellence

– Courage

– One Team

Corporate Values – BP - 2012

One Team

• Whatever the strength of the

individual, we will accomplish

more together.

• We put the team ahead of our personal success and commit to building its capability.

• We trust each other to deliver on our respective obligations

Making values visual - Anglo American Guiding Values

Ethical decision-making

Ethical decision-making

Ethical decision-making

Ethical decision-making

Where do we work?

Where do we work?

Where do we work?

• Accessible, branded Code of Conduct

• Payslip reminders, Training Desk Certificates

• Intranet, internal publications

• Radio, Internal tv network stories, Promotional video

• Workshop and online training using scenarios

• Decision trees, Wallet cards

• Stickers, Mouse mats, Notepads

• Tablet app for Code of Conduct

• Annual Ethics award

Compliance and Communications – Project Ideas

33

Questions?