SBM Offshore’s Compliance Program aims to guide the Company’s Management and employees in applying their moral compass, as well as strengthening the management control system. SBM Offshore has integrated the Compliance Program into its organizational structure and promotes a culture of integrity and compliance in the day-to-day way of working of all employees, increasingly focusing on targeted training initiatives, digitalization of processes and data analysis. SBM Offshore maintains an effective compliance risk management and control system, which includes monitoring and reporting, and upholds the Company’s zero-tolerance for bribery, corruption, fraud or any other form of misconduct. The Company maintains a global management control framework, while the Company’s Management is responsible for embedding compliance in day-to-day business practice.
The Compliance Program is built on three pillars :
- Compliance governance and organization
- Hard and soft controls1
- Organizational culture and employee behavior
Key elements of the Compliance Program
- Commitment of the Management Board and the Supervisory Board.
- Responsibility and accountability for compliance implementation and management residing in line management and, ultimately, with the Management Board.
- Oversight by and autonomy of the GCD and adequate, qualified resources in the department.
- Company Code of Conduct and Compliance policies and procedures.
- Regular communication, training and continued guidance and advice.
- Convergence of compliance initiatives with other responsible business conduct initiatives
- Regular monitoring of compliance risks, mitigating measures and risk-based controls, as well as incident and action reporting.
- A thorough third-party management process, including an internal Validation Committee, which reviews the due diligence outcome on high-risk third-parties prior to engagement.
- Independent verification (e.g. compliance audits).
- Compliance-related internal financial controls.
- Confidential reporting procedures, including an Integrity Line and internal investigations.
- Annual compliance statements from employees in middle and senior management positions.
The Management Board has assessed its Compliance program against a basic maturity model (from ‘minimum standards’ to ‘value led business’). The table below displays the Compliance program maturity level as per end of 2020. Overall, the Compliance program is continuing to transition from ‘Compliance culture’ to the ‘Beyond Compliance’ level, although certain elements of the Compliance program, notably the focus on responsible leadership behavior, fall within the ‘value-led business’ maturity level. This is supported by ongoing convergence of compliance intitiatives with other initiatives that focus on responsible business conduct, such as LifeDay, Right365 and vendor engagement events. Through evolving Compliance Program enhancements and by integrating compliance in business events, the Company strives for continuous improvement in embedding compliance as an integral part of its business processes.