23
Management and Integrity
Management Team
Integrity is the foundationof theway
DolphinEnergy conducts business.
DolphinEnergy’s expectations - and
its strict procedures - relating toethics
and integrity are laidout inaCodeof
BusinessConduct (CBC) and inour P&C
procedures. Computer based interactive
training on theCBC is provided annually to
all staff, and every employee is required to
annually declare his/her compliancewith
theCBC.
The process of annual declaration
started in2009, whena declaration by all
employees pertaining to2008was rolled
out and signedoff (electronically). In
addition, all newly hired employees signed
off on a conflict of interest checklist. The
Eachof DolphinEnergy’s twogeographical
areas, Qatar andKuwait, operate their own
decentralizedorganizational structure,
withGeneral Managers (GMs) on top of
the command chain in each location. The
GM of each operational location reports
directly to theCEOof DolphinEnergy, and
training proved its effectiveness as there
were no job dismissals or contract non-
renewals due toCBC issues at Dolphin
Energy in 2009.
Oneof the key issues addressedby the
CBC is anti-corruption. This includes,
inter alia, the rules in dealingwith third
parties and for contractual arrangements.
Corruption or fraud risk is considered
in the formal risk assessment exercise
conducted by the internal audit across
theorganizationanalyzingall business
units for potential risks and any corruption
incidence. Noethical incidences have
occurred in2009, nor has therebeenany
legal prosecutionon thebasis of corruption
against DolphinEnergy in 2009.
TheFoundation:
Insisting on Integrity
Organizational Structure
is supported by functional subordinate
managers. Inaddition to countryGMs,
theCEO is assisted by an internal audit
manager, General Counsel, andVice
President for Quality, Health, Safety,
Environment andSecurityDivision (VP-
QHSE&S).
