NNPCL Code of Conduct_Introduction.pdf

NNPC Limited Code of Conduct 1. Introduction 1.1 Employees’ Obligation Employees are the most important resource of any business. Employees are therefore encouraged to contribute to their fullest capability, take responsibility for their actions and demonstrate integrity within the workplace an...

NNPC Limited Code of Conduct 1. Introduction 1.1 Employees’ Obligation Employees are the most important resource of any business. Employees are therefore encouraged to contribute to their fullest capability, take responsibility for their actions and demonstrate integrity within the workplace and beyond. 1.2 Why Does NNPC Limited Need a Code of Conduct? NNPC Limited is determined to foster adherence to high ethical standards in all its business operations and create a culture where employees and other stakeholders align their actions with the ethical values of the Company. Therefore, employees are required to always act with honesty and with integrity and to safeguard the public / private resources for which they are responsible. Furthermore, NNPC Limited is committed to ensuring that opportunities for fraud and corruption are reduced to the lowest level of risk and where possible, eliminated. Fraud and corruption are unacceptable at any level and any suspected or actual incident will be investigated and appropriate action will be taken to discipline parties involved and remediate identified gaps. Hence, NNPC Limited requires a Code of Conduct which serves as a guide on the standard of behaviour considered acceptable in NNPC Limited. 1.3 Code of Conduct This Code of Conduct is designed to provide a clear, concise, and consistent set of guidelines and principles to guide the actions of the employees in their day-to-day activities. It sets out the standards of behaviour and practices which are considered acceptable and in line with the Company’s policies and core values. The Code of Conduct is a common reference point for anyone who is unclear about what is expected of them in a specific situation; a definitive statement of NNPC Limited’s response to a variety of issues and questions. It is important to note that the Code of Conduct also summarizes the existing legal and policy requirements and provides guidance on how to meet those requirements. NNPC Limited expects that all staff will act in a manner that will continually 6 NNPC Limited Code of Conduct build the Company’s image and reputation with the business community and the public. While we will not set a fixed pattern for personal behaviour, we require that every person connected with NNPC Limited always maintains a standard of professional judgement and moderation. We expect all staff to conduct themselves in a manner that promotes cooperation, and mutual understanding and fosters good relations with all stakeholders. 1.4 What Does the Code of Conduct Cover? The Code covers the compliance requirements of employees of NNPC Limited. However, it is key to note the following: a) Employees are responsible for understanding and complying with the details of the Code relevant to their individual roles and work areas. b) The Code of Conduct does not: i. Provide detailed guidance about compliance with every local legal requirement. Therefore, as an NNPC Limited employee, you are responsible for compliance with the local laws and regulations which apply to you. ii. Provide exhaustive information about every NNPC Limited’s standard or policy. iii. Take away the need for employees to exercise good judgement in line with NNPC Limited’s values. Rather, it is aimed at facilitating good judgement by employees. 1.5 How Can the Code Help You? When faced with questions or dilemma, employees are encouraged to search the Code for guidance, advice, and answers, because it provides a variety of useful information such as: a) Practical advice on how to comply with laws and regulations. b) Guidance on how to relate with colleagues, customers, communities, vendors, competitors, and government officials. c) Answers to difficult questions and dilemma about business conduct. 1.6 How Can you find out more about the Code? The Code seeks to provide information and guidance required to handle most of the situations and questions being faced in day-to-day work at NNPC Limited. However, additional information and clarifications on the Code and NNPC Limited’s polices can be obtained from the following depending on the subject concerned: 7 NNPC Limited Code of Conduct a) Your supervisor or line manager. b) Your Human Resources representative. c) Your GRC Officer d) A legal adviser (for local laws and regulations applicable to you). e) The external whistleblowing hotline 1.7 Who Must Follow the Code? This Code applies to all NNPC Limited’s employees, including executive management, and contract staff. The Code is also applicable to contractors or consultants who are our agents or working on our behalf or in our name, through outsourcing of services, processes, or any business activity. Independent contractors or consultants will be made aware of the Code as it applies to them when dealing with NNPC Limited and its representatives. 1.8 How Can you Report a Violation of the Code? If you believe a provision of the Code of Conduct has been or is being violated, you have a responsibility to raise your concerns with someone who can appropriately address the suspected incident of violation. The reporting option available are detailed below: 1.8.1 Internal Whistle Blowing Channels a) If you want to make use of the internal reporting mechanism, you should report anonymously via the NNPC Limited’s Tip Portal at NNPC Workplace. b) Reports made to the Line Manager/Supervisor, should be forwarded by the supervisor to the relevant regulatory and compliance unit. c) You are encouraged to use the external whistleblowing channels, particularly in instances where you want to remain anonymous and/or where the nature of the concern you are reporting is sensitive. 1.8.2. External Whistle Blowing Channels a) You can choose to make a report using the external whistleblowing channels maintained by an independent consultant via telephone, email, or the web link. b) The external whistle blowing line is anonymous and your identity will not be disclosed. 8 NNPC Limited Code of Conduct c) When you make a report via the external whistleblowing channels, you should set out the nature of the incident, parties involved, relevant dates and time, place of occurrence and the reason(s) why you are particularly concerned about the situation. However, incomplete information should not deter you from making a report. NNPC Limited will take necessary steps to ensure that your report is investigated in a timely manner. If the allegations you raised are confirmed, appropriate disciplinary action will be taken against any parties found culpable. Furthermore, NNPC Limited will take steps to ensure that you are properly protected from retaliation or reprisals as a result of reporting a suspected or actual instance of unethical conduct or violation of relevant laws and NNPC Limited’s policies. We will also investigate any reported incident of retaliation and take appropriate disciplinary action against anyone who engages in such activities. Therefore, we expect employees who know or suspect that retaliation has taken place to report it through the whistleblowing hotline or via the NNPC Limited’s Tip Portal at the NNPC Workplace or to the ETHICS AND COMPLIANCE UNIT (ECU) of GRC For further information on how to report a violation of the code, please refer to the whistleblowing policy and / or consult the relevant regulatory and compliance unit. 1.9 What Could Happen When the Code is Violated? Violation of the provisions of the Code of Conduct, or of any laws or regulations governing our operations, may have severe consequences for the individuals concerned and for NNPC Limited. Employees who violate the Code or any laws or regulations may be subject to internal disciplinary action, including termination of employment. Also, a failure to follow the Code that involves a criminal act could result in prosecution after referral to the appropriate authorities. The Consequence Management policy provides additional guidance on possible outcomes and related processes when code of conduct is violated. 9