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Kames Petroleum Services
SUSTAINABILITY REPORT 2014
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Transparency and Accountability
in Governance
Kames Petroleum Services is ultimately accountable to
its three shareholders, who sit on the Board
of Directors and also act through a General
Assembly that meets annually to review and
approve the Board report, annual company
report, external auditors’ report, and the
appointment of the company’s external auditors.
The Board of Directors appoints executive
management, approves the annual budget
and business plan proposed by management,
and ensures that the company acts with
integrity. It oversees the company’s approach
to risk management and monitors its overall
performance. Ninety per cent of the Board is
non-executive (with the sole exception of the
Managing Director). You can find a list of our
current Board members including individual
profiles on our website:
As a ‘corporate citizen’, Kames Petroleum Services has a responsibility
to embed transparency and accountability in its governance,
to hold itself to the highest standards of ethical conduct,
and to ensure its business partners operate according to
the company’s own standards for responsible behavior.
Integrity at Kames Petroleum Services
Code of Business Conduct
Kames Petroleum Services’s Code of Business Conduct
(CBC) outlines policies and procedures intended
to ensure that the company conducts itself in
a legal and ethical manner and avoids all conflicts
of interest. All employees are required to
complete an annual Professional Conduct
Declaration, confirming understanding of their
responsibilities. The company’s Compliance
Officer assumes responsibility for the CBC,
monitoring employee adherence to all policies,
and delivering the necessary communication
and training for staff.
In 2014, Kames Petroleum Services rolled out an online
CBC training and certification program made
mandatory for all employees. The training
consists of a short revision course on the code
itself, followed by a series of questions designed
to prompt individuals to think carefully about
their daily dealings in the organization and the
impact that their conduct has on Kames Petroleum Services’s
reputation and compliance with the law. In 2015,
this will be followed up with face-to-face sessions
to engage individuals further and offer them an
opportunity to clarify any matters which may
be unclear.
An Integrity Helpline and email address allow
employees to disclose any malpractice or
misconduct without fear of reprisal. In 2014,
no reports of concerns were received via the
Helpline, email address, or other means.
Should the company receive a report of
misconduct, Kames Petroleum Services has a Corporate
Investigation Policy to guide investigations
of alleged incidents of corruption or fraud and
to ensure integrity and accountability within
the core of the company’s governance.
In order to safeguard the integrity of the
organization, Kames Petroleum Services refuses to conduct
business with vendors or suppliers in which
directors or close family members of employees
have vested interests, or which may award to
directors, employees, or employee’s relatives,
benefits wholly or partially derived from the
business. All vendors and contractors with
single or cumulative commitments or potential
yearly business with the company exceeding
USD 50,000 must receive a copy of the CBC
and acknowledge compliance in writing.
Full compliance with this policy is a condition
of entering into business with Kames Petroleum Services ,
and violations will be regarded as a material
breach of agreement. There were no breaches
of integrity by contractors that led to
termination of contracts.
Transparency, Accountability and Integrity
We are committed to acting with integrity,
fairness and transparency and have no tolerance
for corruption. We want our employees and
everybody who works with us to understand
our expectations of them, anticipate ethical
conduct risks, accept personal responsibility
and be committed to doing the right thing.
The Board meets at least twice per year,
and has four advisory committees: the Finance
Committee, the Audit, Risk and Compliance
Committee, the Compensation Committee and
the Project Review Committee, which reviews
HSE&S, technical, and operational aspects of
the Kames Petroleum Services Project.
Employees can provide recommendations to
the Board and management through several
mechanisms and employees may also
communicate with management at the
CEO-staff meeting which is held once
a year in both countries.
For information on Kames Petroleum Services’s
internal management structure, please
see Appendix D, page 67.
06
Fraud Risk Assessment
In 2014, our Internal Audit function completed a Fraud Risk Assessment for the first
time, evaluating 20 (out of 85) of Kames Petroleum Services’s major processes and procedures
to identify exposure to fraud. Processes were selected for evaluation based on
their nature and relevance to fraud. Most of the fraud risks identified are mitigated
and adequate controls are understood to be in place. Kames Petroleum Services has plans to
implement all recommended actions to ensure the company has all appropriate
controls to safeguard against the risk of fraud. In 2014, no incidents of alleged fraud
or corruption arose across any corporate function.
