2.1.1Ethics and Compliance
management approach
In all the communities in which it operates, SBM Offshore is committed to conducting its business honestly, ethically and lawfully. Integrity is vital to maintaining 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.
SBM Offshore’s aim is to enable its employees and business partners to make the right decisions, with commitment to integrity at all levels. Therefore, 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 compliance policies and procedures. The Code of Conduct, which builds on SBM Offshore’s Core Values, is a guide for behavior and reflects the commitment of SBMers to lead the business responsibly, beyond compliance with rules.
For further details on SBM Offshore’s management approach, its purpose and its assessment, refer to sections 1.4.1, 3.5.2 and 5.2.5.
SBM Offshore uses a single and integrated platform to manage compliance tasks. All staff, including the Management Board and Executive Committee, are required to complete their assigned compliance tasks. The 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. Quarterly compliance reports − including follow-up to action for improvement − are discussed with the Management Board and the Audit Committee of the Supervisory Board.
2023 PERFORMANCE
In 2023, SBM Offshore continued to promote a speak-up culture and adherence to the Code of Conduct through:
- Code of Conduct e-Learning for all staff (including Management Board), including speak up and non-retaliation.
- Tailored speak up and investigation training for HR leaders.
- Psychological safety part of the Executive Leadership Program.
- Tailored training for functions with higher exposure to compliance risks, such as Supply Chain Management.
Other notable developments and achievements in 2023
- Improvement of global geographical presence of the compliance team.
- Organization and focus on business needs and priorities.
- Expanded reach offshore through the Compliance Ambassadors Program.
- No confirmed instances of corruption occurred during 2023.
More on how SBM Offshore manages ethics and compliance can be found on its website and for further information about its performance, refer to section 5.2.5.
Metrics
The number of employees eligible to file the Annual Compliance Statement in 2023 was lower than in 2022 (4,625 employees in 2023 versus 4,936 in 2022). The number of compliance training courses completed in 2023 decreased comparing with 2022, due to less face-to-face trainings was done (7,613 training courses in 2023 versus 11,960 in 2022).
Annual Compliance Statements | Designated Staff1 |
|---|---|
Number of employees per year-end | 4,625 |
Onshore Completion ratio | 89% |
Offshore Completion ratio | 87% |
- 1 Designated Staff reflects all onshore staff and offshore leadership.
Compulsory Compliance Task Completion1 | All Staff |
|---|---|
Number of employees per year-end | 6,911 |
Onshore Completion ratio | 91% |
Offshore Leadership Completion ratio | 70% |
Offshore non-Leadership Completion ratio | 71% |
- 1 Including Code of Conduct, theme based e-Learning courses and annual compliance statements.
Overall number of Compliance Trainings conducted in 2023 worldwide | Trainings | Training hours |
|---|---|---|
Face-to-face trainings1 | 1,229 | 1,172 |
e-Learnings2 | 6,384 | 4,749 |
Total | 7,613 | 5,921 |
- 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 | 34 | 51 |
Targeted Compliance topic training1 | 1,195 | 1,121 |
Training of third parties | 0 | 0 |
Total | 1,229 | 1,172 |
- 1 Training on relevant Compliance topics for risk based target audiences.
Speak Up Line reports | Total |
|---|---|
Reports received under SBM Offshore’s Speak Up Policy | 194 |
Future
In 2024, SBM Offshore aims to continue to drive initiatives to establish, develop and promote a compliance culture as well as policies and procedures with respect to business conduct matters.
- Promoting a speak-up culture and responsible business conduct.
- Updating compliance policies and processes.
- Upgrading digital tools.
- Increase monitoring and reporting capabilities by progressing to data-driven compliance.
- Applying a risk-based approach to third-party due diligence and monitoring.