It’s in

your hands

Our Code of Conduct

What we value, how we behave

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Our Code of Conduct –

it’s in our DNA.

It defines who we are and how we behave.

How we look after each other and keep each other safe and secure.
How we work together and with others, taking the greatest care
to respect the communities and environments we work in.
To put it simply, it’s about how we put what we all value into
practice, so we, and everyone working with us, always operate
with integrity – ethically, honestly and in compliance with the law.
Ultimately that is what builds the trust on which our continuing
success depends, and every one of us has a part to play in making
sure we never break that trust.
“I don’t want to be part of an
organisation that has a negative
That’s why our Code doesn’t just help you to make the right impact on people, communities
decisions and do what’s right; it gives you the power to challenge
wrongdoing – and put it right.
or our planet – and I don’t know
anyone working for us who does.
So please hold it to your heart. Follow its principles and live its spirit.
That way we will keep the trust we all depend on alive in all we do. “Our Code is there to make sure
It’s in your hands. we are a positive force for good.”
John Evans
Chief Executive Officer, Subsea 7, January 2020

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Contents What is our Code for?

3-7 Why our Code matters Our Code helps us all to be sure we are doing the right thing.
3 What is our Code for and Who does it apply to?
4 Why comply? It brings our Values into action and translates our three key Policy
5 How to use our Code and How to be sure you’re following it Statements on Ethics, Human Rights, and Health, Safety,
6 Who we are and The things we value
Environment and Quality (HSEQ) into how we behave and look after
7 Speaking up ourselves and others from day to day.
7 Speaking up: How to raise a concern
8–16 Part 1: Doing business with Integrity: ethically, fairly and legally
9
10
11
Bribery and Corruption
Small bribes and facilitation payments
Gifts and hospitality
Who does it apply to?
12 Conflicts of interest
13 Dealings with public officials
Everyone who works for Subsea 7 onshore, offshore, full time,
14 Community engagement, charitable donations and political contributions part time and on contract, across all sites, in all locations and
15 Competing fairly: competition and anti-trust in every country.
16 Trade sanctions, export controls and boycotts
We also expect those we work with to uphold standards
17–25 Part 2: Looking after information and assets
18 Maintaining the integrity of our Accounts, Records and Financial Controls and principles that are consistent with our own.
19 Keeping confidential information safe
20 Using IT and social media properly and securely We all have a role to play, and are individually accountable
21 Protecting personal information for ensuring that we and the people working with us follow
22 Intellectual property our Code’s principles and the policies that underpin it.
23 External communications
24 Insider trading
25 Proper use of company assets and resources
26–33 Part 3: Looking after people, communities and our planet
27 Respecting human rights
28 Treating each other fairly and with respect
29 Keeping each other safe, secure and healthy
30 Maintaining our quality to deliver performance
31 Looking after our planet
32 Treating communities with care and consideration
33 Working with others: clients, partners and suppliers
34–38 Appendix

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Why comply?
Doing what’s right Doing what’s right, and
Our Code belongs to all of us at Subsea 7.
Subsea 7 is committed to complying with the law – but this is about following our Code –
much more than “doing the legal minimum”. It’s about doing what
we believe is right and upholding ethical standards that are the
foundation of so many laws, and frame the kind of world we all wish
that’s what our Values,
to live in.
If we don’t respect our Code, we don’t respect each other, and even
our stakeholders,
though we may not mean to do so, we could potentially cause harm.
our leaders, and you –
Avoiding harm our employees – expect
Consider the potential consequences of not following our Code:
–– Our company could face serious fines and penalties. So could
and demand of us.
the individuals involved, who may even go to prison.
–– Our reputation could suffer, breaking the trust on which we
depend to do our business and win work.
–– That could lead to job losses, and damage our partners and
suppliers, and the communities and environments we work in.

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How to use our Code How to be sure you’re following it

In most situations your own judgement and personal integrity will tell you
Our Code is designed so it’s easy for you to access and use.
what’s right.

To find the issue you want to explore:

At the front, you’ll find details on what our Code is for, why it
matters and how to Speak Up if you have a concern.
The Code is then divided into three parts:

Not sure? Then ask:

Part 1: Doing business with Integrity: ethically, fairly and legally
Part 2: Looking after information and assets
Part 3: Looking after people, communities and our planet
Do I honestly believe this is right?
How each section is laid out:
–– First, you will find one or two headlines about why the subject
is important and our commitment and principles as a company.
Is this consistent with our Values
–– Some further paragraphs set out the main things you need to
and who we are?
know about the subject.
–– “In your hands” then describes what it means in practice and Would I be happy reading about
how you can make a difference in your role.
this in the news?
–– “Where to look for more information” takes you to further
reading and guidance.
–– In some places, you can also click to access a glossary for
Have I checked with our Code and
more details. Once you’re done, click on the return button to someone whose integrity I trust?
get back to where you were.
–– Finally, the “It happened to me” sections provide stories from
our industry and some realistic challenges and dilemmas we
could face in our work.

If you are still not sure what to do, consult your legal or compliance contact.

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Who we are The things we value

“Our Values are more
than just words.” Safety Our goal is an incident-free workplace. We work
every day, everywhere to make sure all our people
are safe.

We’re a company of problem-solvers. We are creative and work

together and with others to find answers for our clients in situations
that need engineering excellence, innovative thinking and
flawless performance.
Integrity We apply the highest ethical standards in
everything we do. We treat clients, our people,
partners and suppliers fairly and with respect.
We are also a company that chooses to act with integrity, putting the
care of our people, communities and planet at the heart of our
decision-making.
Our six Values are our way of describing the things we care about. Sustainability We take a proactive approach towards our
social responsibilities, mitigate the impact
They set the bar for how we approach our work and what we expect of our activities on our planet’s environment,
and respond to the effects of climate change.
of ourselves.

Our Ethics Committee

Performance We are driven to achieve the outcomes our
clients want. We are trusted to achieve superior
Our Ethics Committee regularly meets to make sure we are doing performance from every project.
what we say and following our Values. That’s why from time to time
we will develop new procedures and guiding principles, so we stay
true to who we are in a changing world. To find out about the
Ethics Committee’s composition and Charter, visit our website.
Collaboration We work closely and openly together with clients,
partners and suppliers at a local and global level
to deliver safer and stronger results for all.

Innovation We create smarter and simpler solutions to meet

the industry’s needs. We combine technology,
expertise, assets and partnerships to deliver
projects in new ways.

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Speaking up: how to raise Safecall: our confidential

a concern reporting helpline
If you’re concerned that the law or our Code is being broken, it’s Wherever you are, you can get in touch with Safecall, our externally
your responsibility to report it. We can put it right – but only if you let administered confidential reporting helpline. It’s open 24 hours a day,
us know. 7 days a week.
We know speaking up can be hard. So first of all it’s very important
for you to know that we’re on your side, and you have our respect How to get in touch:
for standing up for what is right.
1. The easiest way is just to go to www.safecall.co.uk and you will be
You’re also safe – we will not allow any retaliation against anyone guided through what to do.
raising a concern in good faith or if they honestly and reasonably 2. Alternatively, you can call directly. You’ll find your nearest local number
believe something might be wrong. on 7ONLINE. Calls are free from most locations.
We also provide ways for you to report confidentially and, where
local law allows it, anonymously. What will happen?
We treat every report seriously and confidentially.
Here’s what to do:
We will follow up your report conscientiously, discreetly and without bias.
–– The fastest and best way is simply to talk to your manager or And if it’s appropriate, we’ll report back to you.
supervisor. If that is not appropriate, you can also get in touch
with your human resources, legal or compliance contact, or an
indirect supervisor or manager. If you have a concern,
–– If you don’t feel comfortable with any of those options, then
contact our confidential reporting helpline, Safecall, which is just Speak Up.
operated by a company independent of Subsea 7. Visit our website for our Speak Up Policy (PO-GL-COR-003)

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Part 1
Doing business with Integrity: All our six Values run through every section of our
ethically, fairly and legally Code, but in Part 1 Integrity plays a central role.
People describe Integrity in many different ways,
but the same three words keep turning up:
fairness, honesty, trustworthiness. Those are
the qualities we want to be known for in the
way we do business.
That’s why a key goal in our Ethics Policy
Statement is this:
“To act fairly, honestly and with integrity at all
times and in everything that we do, and to
comply with all applicable laws… and thereby
earn the trust of all our stakeholders.”

Contents
9 Bribery and corruption
10 Small bribes and facilitation payments
11 Gifts and hospitality
12 Conflicts of interest
13 Dealings with public officials

“Doing the right thing, even when 14 Community engagement, charitable donations
and political contributions

no one’s looking.” 15 Competing fairly: competition and anti-trust

16 Trade sanctions, export controls and boycotts

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Bribery and corruption

We will not participate in any kind of bribery
or corruption and will make it clear wherever
In your hands: It happened to us

we work that we are opposed to it. ••Never think that we ever want you to do We were working on an important project in
something illegal or underhand to give the a high-risk country. We needed some permits
Corruption destroys lives and undermines law business an advantage or benefit, win a contract, on short notice, so we arranged a meeting with
and society. It can and does also bring down or overcome an inconvenience. That’s not who the relevant officials. The amounts we were
businesses. We will have no part of it and will we are, and it can have hugely damaging being asked to pay were quite high, but they
combat it if we encounter it. consequences. were in line with what we perceived to be the
normal rates. It all seemed above board, until
So we are very clear: we do not offer or accept ••Never take part or allow our business to be
we thought about it:
bribes or improper payments, or participate in any involved in any type of corrupt behaviour, no
kind of corrupt activity, to overcome a problem, matter how small or trivial you may think it is, and ••The payments were requested in cash
obtain or retain business, gain an improper no matter what potential benefit you think there ••There would be no official receipt
advantage, or for any other reason, and we may be.
••There was no published tariff.
won’t allow others to do such things for us. ••Avoid any situations or actions that could be
misinterpreted. Just an allegation of corruption At this point we sought guidance from senior
We make no exception even for small bribes or
could damage our good name and get you into management and legal. When we talked it
so-called “facilitation payments” (see next page).
serious trouble. through, we agreed that this process really
We are responsible for what any third-party may ••Never “turn a blind eye” to wrongdoing. If you didn’t feel quite right and was risky. How could
do on our behalf, in our name, or in connection with think something illegal may be going on or a we be sure the money was ending up in the
our work. We never make payments to consultants, bribe has been offered or asked for, always right hands and being properly accounted for?
agents or other intermediaries when we know or report it – even if it’s just a suspicion.
have reason to believe that part of the payment
will be used to bribe or otherwise improperly
influence someone.
We comply with all anti-corruption laws, including
those against fraud, money-laundering and
tax evasion. F
 or more information, see:
Our Anti-Bribery and Anti Corruption Policy
(PO-GL-LAW-010)

Our Compliance and Ethics on 7ONLINE

(a general resource for all Compliance
and Ethics Guidance)

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Small bribes and facilitation payments

Small bribes are given to someone to get them

to do something they should not do. “Facilitation
In your hands: It happened to me

payments” are given to a public official to get ••No matter how small the sum or how big the We came into port. We needed to complete
them to do something the payer is already possible hassle to our business, unless you are all the formalities fast, so we could keep to
entitled to. Both are forms of bribery and are concerned for anyone’s safety or liberty, never schedule. Then the inspector boarded us.
against the law and our Code. pay or give anything to any public official for the I think we all knew what was coming, and
performance of their official function, if it’s not a sure enough it did. “Some of the frozen
People can perceive them as harmless or even clearly legitimate and published government levy meat you have is out of date. Very serious.
“clever”. But their negative impact on society is often or fee and is for proper performance of that Bad consequences. But $100 and I can make
underestimated: they help perpetuate a system of function. it go away”. Of course it wasn’t true. All he
corruption, and their victims include the vast majority wanted was $100 to go on his way. It just
••Plan ahead – avoid routes, offices or officials
of the local population, who in some countries are felt like such a small amount compared to all
where demands for payment are known to be
paying 15-20% of their annual income for services the costs and hassle if he didn’t allow us to
common. Consider whether there are alternative
to which they should be entitled. enter port. You know, it just seemed like the
ways of working that reduce the risk.
company would want me to do it… Thank
Facilitation payments can be particularly tricky. ••Build enough time into your schedule, if goodness I checked. Senior management
They usually involve quite a small sum. If you just possible, and order goods and materials were crystal clear about refusing, and very
pay it, you’ll be able to get on. But if you don’t there sufficiently early, to enable you to manage supportive. I and the company could have got
could be all sorts of hassle. Unless you feel a threat delays at customs. into a world of trouble.
to anyone’s safety or liberty, or to personal or family ••If, rightly or wrongly, you judge that you have no
peace of mind, please don’t pay, no matter how choice and must pay, then you must inform the
small the sum or how big the possible hassle. If you Chief Executive Officer and the General Counsel.
follow this basic principle, we will support you.

For more information, see:

Our Group Anti-Bribery and Anti- Corruption Policy
(PO-GL-LAW-010)
Our Policy on Facilitation Payments
 ee the Appendix on page 34 for
S (PO-GL-COR-008)
some examples of so-called Our Tools/Guidance on how to Resist a Facilitation
“facilitation payments” Payment Demand

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Gifts and hospitality

Giving or receiving gifts and hospitality can
play a legitimate role in business relationships.
In your hands: It happened to me

However, we need to be very careful that Before giving or receiving any gifts or hospitality: A colleague’s husband had arranged a dinner
anything we offer or accept doesn’t have – for the two of them with another couple (his
••Always check with our Policy that it’s allowed
or appear to have – the intention or effect friend and the friend’s partner). The dinner was
and appropriate.
of improperly influencing a business decision purely social and private – bu, by chance, it
••Ask yourself why this is being offered and how it turned out the friend’s partner works for a
or inducing someone to do something might look. Could this be seen as having some
they shouldn’t. client whose tender Subsea 7 was currently
corrupt or improper motive? Is it excessive? working on. The colleague asked me:
All gifts and hospitality should be reasonable in What if you were asked to justify it in public –
value, appropriately motivated and not excessive, could it look bad? 1. Am I OK to attend the dinner and claim it on
so we must all carefully follow our Policy on Gifts ••Be transparent: whenever you do give or accept expenses?
and Hospitality, which clearly explains: anything, unless its value is below our policy 2. Is the current tender a problem?
thresholds, always record it on our Register of 3. If so, can I put another client’s name on the
••What is and isn’t “appropriate” expenses claim?
Gifts and Hospitality.
••What needs approval 4. Alternatively, can I split the bill and claim half
••Never allow gifts or hospitality to be offered or on expenses?
••When and how to record things we offer,
accepted by anyone with whom we are engaged
accept or decline.
in an active tender or competitive bidding Once we talked it through, we agreed the best
Do not provide gifts or hospitality to a public process. answer to each question was no.
official without prior approval from a member ••Never offer or accept cash or a cash equivalent
of the Executive Management Team and the as a gift.
Group Head of Compliance and Ethics.

Q. Ask yourself:
••Will this make the recipient feel obligated,
or compromise their independence or
See the Appendix on page 35 to learn judgement? For more information, see:
more about the Register and for tips ••Will it create a conflict of interest? Our Policy on Gifts and Hospitality
on how to refuse a gift (PO-GL-COR-001)

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Conflicts of interest
Whenever our own financial, political or personal
interests, or those of others we know, could
In your hands: It happened to me

potentially come into conflict with the interests ••Even the appearance of a conflict of interest can My brother-in-law’s business was going
of Subsea 7, we always declare it at once. be very damaging, and do you and the company through difficulties. Then the possibility of a
a lot of harm. contract with us came up. It would save him
That’s because the potential conflict might result in and all his employees, and I knew he was really
••So if a potential conflict of interest arises, always
us taking business decisions or actions that benefit good at what he did. He pleaded with me, so
let your manager know at once. Record it on the
us or others at the expense of the company. did my sister, so did my wife. So I just thought,
Conflicts of Interest Register, along with any
let’s go with him.
Conflicts of interest are important because they often steps agreed with your manager for managing it.
lie at or near the heart of bribery, corruption, breach ••If you feel pressurised by someone to make a Then just before the contract was signed the
of duty and other unlawful or dishonest conduct. decision in their favour, or to engage a person or company found out about our relationship.
company they recommend, report it. There may They said because I hadn’t told them, they
There is usually no harm provided you have couldn’t consider him. But if I’d made a
be nothing wrong, but it’s better to be sure.
disclosed a potential conflict clearly, and sometimes recommendation, told them there was a
you may need to agree steps with your manager to ••You’re not allowed to:
––accept a position as a consultant, director or potential conflict of interest, and took no part in
manage the potential conflict – for example, the decision-making process, they probably
abstaining from a procurement decision. part-time employee with a Subsea 7
competitor, client or supplier, or acquire an would have gone with him anyway, as his
You can find details of what to do on the Register, interest in their business, credentials were excellent. I lost him that job.
and in our Work Standards and Conduct Policy. ––carry on a business in your own time that’s
The links to both are in the bottom right hand column. doing something similar to the work you’re
currently doing for Subsea 7, without first If there’s potential for
getting written approval.
••Never let our relations with suppliers, sub-
a conflict, tell us.
contractors or consultants improperly influence It’s in your hands.
the decisions you make.

For more information, see:

Our Compliance & Ethics Bulletin –
Conflicts of Interest
 ee the Appendix on page 36 for
S Our Works Standards & Conduct Policy
examples of a conflict of interest (PO-GL-HR-013)

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Dealings with public officials

We often have to deal with public officials who
may have a lot of power over whether our
In your hands: It happened to me

operations run smoothly or not. Inducing or helping a public official to breach The inspector was on the point of clearing our
their duties, whether by bribery or other improper vessel, in record-quick time, when he took me
We never make illegal payments, or offer bribes influence, is always wrong, no matter what the to one side. He said his daughter was looking
or improper benefits to induce or influence reason. Even if you weren’t trying to do it, if it for a job in an engineering firm, and could he
public officials to do something for us – even appears as if you were it can result in extremely send me her CV. I froze and didn’t know what
if they threaten to disrupt our work. serious consequences for you, and for the company. to do. I said I would speak to HR and get back
to him, but that I was pretty sure there was a
Nor do we ever permit or pay third parties to do so ••Never pay cash, and always get a receipt.
process for people to apply through proper
on our behalf. ••Before dealing with any public official check channels and be considered on merit. What
it is okay and above board. would you have done? It all turned out OK in
It may be permissible to:
the end. He cleared the vessel anyway, without
••Pay travel and lodging expenses for public
it being linked to any implied promise from me
officials that are directly related to the promotion
that we might employ his daughter.
of products or services;
••Pay a public official for legitimate services
outside their official duties or function, with the
knowledge and permission of the department Watch out for conflicts
he or she works for; or
between the personal or
••Offer gifts or hospitality to a public official,
Q. Who are “public officials”?
family financial interests of
but only if you consult legal first and obtain the
prior approval from a member of the Executive
In our work we often deal with customs and port a public official and their
Management Team and the Group Head of
authorities. But public officials also include anyone
working for a national, local or municipal
duty to their employer.
Compliance and Ethics.
government, state-owned or controlled companies
(including some of our clients) and government
sponsored institutions like public health agencies.
For more information, see:
They also include anybody working for any political
Our Compliance and Ethics Bulletin –
party or party official, or any candidate for political Understanding our ABAC Policy
office; and any employee, agent or director of a
public international organisation. Our Policy on Facilitation Payments
(PO-GL-COR-008)

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Community engagement, charitable

donations and political contributions It happened to me
A couple of our contacts at an important client
We want to contribute to the countries and
communities we live and work in, so people are
In your hands: asked if the company would like to sponsor a
••As an individual you are completely free to make bike ride they were doing for charity. They said
better off because we’re there.
personal donations and participate in political it was nothing to do with their employer, just a
So we actively participate in local communities or charitable activities for any causes you personal initiative. It was for a very good cause
and charitable activities, and we encourage believe in. in the local community, so surely it was a good
everyone to contribute or create their own and worthwhile idea? But I chatted it through
••All we ask is that you make it clear you’re acting with a couple of colleagues, and gradually we
activities.
in your own personal capacity, and when you admitted to ourselves: wouldn’t we be doing
But it’s important that such activities do not have an get involved in any political activity you clearly this primarily to please our client, rather than
improper motive or effect, e.g. to incentivise or explain you are representing your views, not on its own merits?
reward a decision in our favour by a public official. those of Subsea 7.
••If you do want to set up or participate in
If you want the company to do something for local
charitable or community activities on behalf of
people, or have an idea for a community project or
charitable activity, we want to support you.
Subsea 7 we’ll do all we can to help and support, Three questions to
but you must get approval from the appropriate always ask:
But it’s really important to get approval first, and we level of management.
need to be careful that it’s legal, appropriate, does ••When clients or suppliers ask for contributions, •• Are we just doing it to gain
not cause offence or harm, and does not sponsorship or donations, always check – we are
inadvertently create a conflict of interest. not allowed to contribute to anything that could favour with a client?
What Subsea 7 cannot do in any form is to make
be seen as funding a political party or trying to •• Is the beneficiary legitimate?
influence a client or public official in our favour.
political contributions or use any of our resources or
facilities (even things like phones, IT and meeting
•• Will the money be used in
rooms) to support political activities, or support or the way we intend?
participate in any local or national political party.
For more information, see:
Our Compliance and Ethics Bulletin –
Understanding our ABAC Policy
Our Group Anti-Bribery and Anti-Corruption Policy
(PO-GL-LAW-010)

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Competing fairly: competition

and anti-trust It could have happened to you or me
I saw a video online of someone who used to
We want to be trusted as a company that always
competes fairly, honestly and lawfully.
In your hands: work for a company as a senior sales guy in an
••If you’re suspicious or hear any allegations of international business development role. He
Competition laws (also known in some countries possible anti-competitive behaviour, report it said he did the company’s competition law
as anti-trust laws) are designed to stop anyone straight away to our legal team or our Group training every year, but somehow he never
from trying to undermine fair competition. It’s a Head of Compliance and Ethics. Even if we’re related it to himself or saw how it applied to his
serious crime to violate them. not in the wrong, delaying or withholding job. He got his company tangled up in some
information could get us into serious trouble. sort of cartel and ended up in an orange
So we never do anything that tries to dishonestly or jumpsuit in a US prison.
illegally control, rig or distort the market in our favour, ••Take particular care when you’re dealing with
and we always comply with all competition and competitors. Meetings or discussions with them
anti-trust laws wherever we operate. can be perfectly legitimate, but some contact
Similar laws apply in most regions of the world.
and co-operation, and any kind of agreement Competition and antitrust
with them, could raise concerns and potentially
They are complex, and it’s impossible to cover be illegal.
laws are complicated and
them fully in our Code.
••Never stay in a meeting if a competitor begins can be a minefield.
to discuss prices, terms or any other prohibited
Some basic principles: topic, such as: So always seek expert
1. Some practices, such as cartels or bid rigging, ––Price fixing – including the amount we or advice and check before
are strictly prohibited, regardless of intent. a competitor is thinking of bidding.
2. Other arrangements may be unlawful if their ––Allocating markets or clients – including
you act.
purpose or effect is to distort competition. whether to bid on specific business.
3. Unlawful arrangements do not need a written ––Constraining supply – including any
agreement – they can be oral or even inferred confidential decisions to enter or depart
by conduct. from specific markets or businesses. For more information, see:
4. Merely disclosing information can result in or Our Competition/Anti-Trust Compliance Policy
infer a breach of competition law. (PO-GL-LAW-004), and the related Compliance
and Ethics Bulletin
5. The consequences of a breach are very
significant for individuals and companies. Our Compliance and Ethics on 7ONLINE
(where you can find contact info for our legal
department and compliance officers)

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Trade sanctions, export controls

and boycotts It could have happened to us
We were pursuing a bid for a new client in a
We comply with all trade sanctions and export
controls imposed by recognised national
In your hands: country in which the company had little or no
••Like Competition and anti-trust laws, this is an past experience. We had spent quite a lot of
and international authorities which apply
area that can be complex, and even when it’s not time, effort and money before a colleague said:
to our business.
intentional, a mistake can have really serious “Aren’t there sanctions issues with that
Trade sanctions consequences. country?”. We did some basic due diligence
are used by governments to ensure all or certain and discovered that we would be in breach of
••When working in new countries, or if we don’t sanctions laws if we had proceeded. Not only
kinds of business are not transacted with targeted
know the client or those it is working with, make would the company have faced huge fines, but
countries, regimes or designated persons.
sure due diligence screening is conducted to we would also have committed a major breach
Sometimes these cover particular sectors, and
check for sanctions issues. of our banking facilities and insurance
sometimes they can prohibit all trade and business
of any kind. ••If you are involved in export or import, make sure contracts.
you are thoroughly familiar with any existing or
Export controls pending governmental or international
are legislated nationally and internationally to control prohibitions or licence requirements. Get specific
exports of goods, software and technology, as well information and details and speak to your local Take great care when
as transmissions of software or technology by
electronic media, and even overseas access to
export control specialist. considering working in
••If you have questions or concerns, don’t go any
emails and intranet, and telephone. further without contacting the legal department.
countries or with persons
We must always be careful to check what we can ••Always check if a licence is required for what you that may be subject to
and cannot do, and comply with whatever licensing are about to do and the transaction isn’t sanctions.
system regulates the export of “controlled items” or prohibited, and make sure you have applied for
“dual use goods” (normally used for civilian purposes – and received – all the regulatory licences and
but that may also have military applications). approvals that you need.
Boycotts ••Always check our updated list of countries that
Sometimes some authorities may try to impose may be subject to sanctions.
illegal sanctions, boycotts and prohibitions. In those For more information, see:
circumstances we don’t comply, but this can present
difficulties that need to be understood on a case by Our Guidance on Sanctions Issues and Screening
and a list of countries that may be associated with
case basis. sanctions

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Part 2
Looking after All the sections in this part of our Code deal
information with the dangers of misusing, misrepresenting
or failing to properly look after information or
and assets assets, and the consequences that can result.
Particularly important are the threats represented
by the digital technologies we now all use.
These include cybercrime, failing to secure
the systems we use to transfer or store our
company and personal information, safeguarding
important assets like our ideas, innovations and
intellectual property, and naive or careless use
of social media.

Contents
18 Maintaining the integrity of our accounts,
records and financial controls
19 Keeping confidential information safe
20 Using IT and social media properly and securely
21 Protecting personal information
22 Intellectual property
23 External communications
24 Insider trading
25 Proper use of company assets and resources

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 aintaining the integrity of our accounts,

M
records and financial controls It happened to me
I was asked to approve some invoices from
We keep books and records that completely
and accurately reflect our transactions, assets
In your hands: a regular supplier of labour. The invoices had
••Follow our accounting policies and procedures been checked by the supply chain manager,
and liabilities, and we never try to disguise or
and apply our financial controls consistently and they appeared to be in order. Something
falsify our revenues, costs, profits or any part
and at all times. If you’re not sure about made me ask myself: “How do I know these
of our financial records.
something, check. services have actually been provided and
To make sure our books and records are always involved this number of workers?” I got
••If you think there may have been a fraudulent internal audit to take a look, and it turned out
correct and do not misrepresent or misreport
transaction, a potential financial control failure, the supply chain manager had arranged for
transactions, assets and liabilities, either through
or even a simple error, don’t try to hide it or the supplier to submit invoices for work not
fraud or error, we maintain a strong system of
delay reporting it. Tell your Finance Director actually performed, in return for a share of the
policies and control procedures that ensure:
or Group Controller. inflated profits. This had been going on for a
••Only valid transactions are entered into,
••Never create or use cash or bank accounts few years, and the company had lost quite a
with appropriate management approval.
not included in our accounting records. lot of money. That’s the last time that individual
••They are correctly accounted for in a timely
••Never make improper or questionable payments and that supplier worked for us, and there is a
way in our books and records.
or big cash payments to anyone on behalf of good chance the police will get involved.
••Financial reports and statements fully, the Company.
and accurately reflect all transactions in
••Never record or approve a transaction
accordance with applicable accounting
standards.
without reliable and objective evidence. Accounts need to be
••Never modify third-party bank details without
••Fraudulent transactions are prevented
performing a callback to confirm the legitimacy trustworthy and have
and detected.
of the request. integrity too.
These policies and control procedures follow
best practice and comply with all applicable laws,
regulations and standards, including those applying
to companies like ours whose shares are listed
on the Oslo Stock Exchange.
For more information, see:
They must always be carefully followed.
Our Financial Control and Operating Procedures

Our Global Finance Processes and Policies

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Keeping confidential
information safe It happened to me
I had a confidential tender proposal to work on,
Disclosing confidential information is a betrayal
of trust. It can have very damaging
In your hands: but I didn’t want to carry my laptop home just
••Protect any information you hold, and never for one document. And I couldn’t copy it onto
consequences.
assume you can share it. Check first. a memory stick without going through that
So we have a duty to make sure we keep secure tedious IT requirement and encrypting it.
••If you’ve lost anything on which confidential So I simply emailed the document to my home
any confidential information we hold. We never
information has been stored (for example, a laptop address. When I had finished working on it,
disclose or use it unless we have permission,
or flash drive) or you’ve inadvertently disclosed it, I copied it onto my own memory stick and set
and we take great care to make sure it’s never
tell us straight away so we can prevent or minimise off for work. Then disaster struck: I don’t know
disclosed or used inadvertently.
any possible harm. how or where, but I lost the memory stick.
••If you receive confidential information in error, I got into serious trouble. Sure, it was careless
return it and report it. and could have happened to anyone, but it
••Never leave sensitive information lying around wouldn’t have happened if I hadn’t ignored
Q. What is “confidential information”? or unsecured. two clear policies that I now realise were there
••Don’t discuss confidential information where for very good reasons.
Confidential information may be oral, visual,
in writing or in any other form. It includes: you might be overheard (for example on public
transport or in public places).
••Any non-public information about Subsea 7’s
business or finances that hasn’t yet been ••Ensure clients, suppliers and other third parties Don’t share, discuss
respect and protect our confidential information
approved for publication or distribution.
in the same way. or copy confidential
(See also the section on Insider Trading.)
••Any information about our processes and ••Never use technologies or methods which are information without
procedures, including engineering methods, not protected or subject to safeguard when
exchanging confidential information.
checking first!
know-how and tools, as well as photos taken
at our work sites.
••Any information about or belonging to any
clients, partners or suppliers that we’ve
received because we deal with them.
For more information, see:
••Any personal information any of us have
about colleagues or people we’ve learnt about Our Compliance and Ethics Bulletin –
through our work or theirs with Subsea 7. Confidentiality and Information Security

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Using IT and social media properly

and securely It happened to me
A teammate posted a racist joke on her
We always take great care to follow the Subsea 7 In your hands:
Twitter account. She has many followers, and
procedures for properly and securely using
••Create strong passwords, renew them regularly quite a few people posted concerns about her
company computing and communications
and never share them. remarks. It is obvious from her social media
systems and social media.
profile and postings that she works for the
••Emails are permanent records – so always think company. One response was copied to the
Technology, the internet and social media platforms
carefully while composing them and before you company’s Twitter account: “Does your
are a core part of both our business and personal
send them! company really want to be associated with
life, and the tools we use increasingly cross over
from company systems to personal devices. ••Think before you click – many online threats can these sorts of remarks?” She got in all sorts
gain access into a system through phishing, of trouble, but it looked really bad for the
But while they bring huge advantages to our phoney sites and emails. company too.
efficiency and performance, they also pose real risks ••Be sure to complete your Information Security and
to our security, capability and reputation, and the Technology e-learning.
protection of our company and personal information.
There’s a lot to be aware of, so our Code can only
••Take particular care over what you write or say in
emails, texts or on social media – these are not
Be careful what you click,
highlight some of the key issues to be found in the private spaces! write and send when using
policies detailed in the bottom right hand column. ••Don’t engage in defamatory, fraudulent, illegal or the company’s IT systems,
malicious communications.
These policies apply to everyone working for us,
••Never try to circumvent or defeat our security
the internet and social
wherever they are working.
systems. media.
••Do not publish photos taken at work on social
media, the internet or elsewhere without express
authorisation.
••Never breach copyright laws or rights by copying
or downloading software onto our systems without For more information, see:
prior approval from your IT Director. Our IT Security Policy (PO-GL-IT-002) and
IT Security Procedure (PR-GL-IT-001)

Our Policy on Company Computing and

Communications Systems Social Media and Bring
Your Own Device (PO-GL-COR-015)

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Protecting personal information

We respect everyone’s right to privacy and
it is the job of all of us to protect that right.
In your hands: It happened to me

Personal information is confidential and ••If you have access to other people’s personal It was so stupid, looking back. Someone called
should be treated accordingly. information, you are in a position of trust. Treat it saying they were from our client and needed
like you would wish other people to treat yours, information about a couple of colleagues.
As a business we have to process all sorts of and protect it from ever being disclosed when it
information about the people who work for us If only I had given it a bit of thought,
shouldn’t be. Always check first. and just asked myself if it was OK.
and with us – like names, addresses, dates
••Follow our Global Data Protection Policy, and
of birth and medical information.
understand any local laws and procedures about
The ways we collect, use, disclose, store and personal information and data protection.
dispose of this personal information are all ••If you think personal data may have got into the
Always check before
regulated by privacy and data protection laws, wrong hands tell us straight away. sharing personal
to ensure it doesn’t end up in the wrong hands. ••Never provide personal information about yourself information about
or a colleague to anyone inside or outside
As well as following those laws, we have our own
Global Data Protection Policy. It’s designed to Subsea 7 without first checking that you can. colleagues.
make sure we all use the highest standards and ••Don’t seek access to personal information that
follow effective procedures to protect all the you’re not authorised to have.
personal details we have about people. ••Never disclose personal information in anger or
We never process personal information unless malice. You can do real harm, and face serious
it’s necessary to do so, and the reasons are consequences including criminal charges.
legitimate and legal. ••Keep in mind “processing” refers to anything you
may do with personal data, including collecting,
Personal data will usually only be used for the disclosing, inputting, storing and sharing it.
purposes it was initially intended. However, there
will be times when we may need to process it
in other legitimate ways. In such cases we will
always seek the consent of those whose data it is.
We always use appropriate physical and IT
safeguards to prevent unauthorised access For more information, see:
to personal information, especially sensitive Our Global Data Protection Policy (PO-GL-HR-007)
information such as medical details. and Employee Privacy Notice (FO-GL-HR-019)

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Intellectual property
We develop innovative ideas, designs,
processes, expertise and know-how that
In your hands: It happened to me

help to give us a competitive advantage and ••Always check and follow any restrictions on using A new team member joined. She was probably
deliver outstanding performance. They need or transferring intellectual property. just keen to make a good impression, but
to be protected. we were really struggling with a big technical
••Whenever third parties need to share, use or
challenge and she suggested a brilliant
understand our intellectual property, always get
Unique and innovative ideas like patents, solution. Then we realised that she’d learnt
approval and follow any guidelines and procedures
trademarks, design rights, copyright, ideas, about that process from her previous
for involving them.
technology and know-how are valuable assets company! One or two people suggested we
just as much as vessels, buildings and equipment. ••If any new technology developments have been could get away with using it, as the company
made through your work for or with Subsea 7, you may never find out. But I thought that would
These are our “intellectual property” – and along cannot share them or use them elsewhere. be totally unethical and not “clever”, and our
with our people they can give us a real competitive Contact the Intellectual Property department and team leader agreed with me.
edge, helping us to sell our services and do they will tell you what you need to do.
outstanding work. ••Never use our intellectual property for anything
other than legitimate company business.
So everyone who works for us or with us must
respect and protect our intellectual property. ••Don’t copy materials that don’t belong to us
Do you have the
(including slides, drawings and reports) unless you right to use this?
In the same way and for the same reasons, we have a licence or have been authorised to do so.
must all do the same for the intellectual property
rights of others – including our clients, partners ••If you use, copy or share anyone’s intellectual
and suppliers. property without authority you can be prosecuted
for theft.
We must never infringe other people’s intellectual ••When using an innovative technology, check
property rights. whether Subsea 7 is authorised to do so or if it
belongs to a third-party.

For more information, see:

Our Strategy, Requirements and Recognition for

Intellectual Property Protection (PO-GL-TAD-007)

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External communications
We depend on our credibility and reputation,
and what is written or said about us in the news,
In your hands: It happened to me

media and investment community directly ••Never speak publicly about Subsea 7 or answer There was a malicious story doing the
affects our reputation positively or negatively. requests for information from anyone unless you rounds and I knew it was wrong. So when
have been authorised to do so. this journalist approached me asking for any
Our policy is to provide timely, accurate and details, I just thought this was a real chance
••Check and always follow our External
complete information in response to public to set the record straight.
Communications and Media Management
requests from media, analysts, investors and
Procedure. I honestly meant well – but it turned out the
others, but we must also maintain the
confidentiality of competitive and proprietary ••If you’re approached by the media, always contact journalist didn’t. He completely twisted what
information and prevent inappropriate disclosure your local communications team in the first I said. It made everything worse, and then
of market-sensitive financial data. instance, or corporate communications. the company found out it was me who’d
••Be careful not to express your own personal views been the source.
We must also make sure inaccurate, misleading, in a way that may lead others to think they are the
incomplete or malicious information about us views of Subsea 7.
doesn’t emerge, or is corrected when it does.
That is a key part of protecting our reputation ••If you’re approached by an investor, contact Careless talk can cost
Investor Relations.
and the trust others place in us. us our reputation.
••Even if it’s a regulator or someone from a
All communication with and requests for government agency asking for non-publicly
information about the Company from external available information, don’t give it to them unless
parties such as the general public, general and until you have got permission. You are
media, industry and community groups must perfectly right, and it is perfectly lawful, to refuse.
be reviewed and authorised by Corporate or
local communications.

For more information, see:

 ee the Appendix on page 37 for more
S
on who can speak externally and rules Our External Communications and Media
for listed companies Management Procedure (PR-GL-COM-005)

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Insider trading
No one must ever use unpublished “inside
information” for financial benefit, or to buy or
In your hands: It happened to me

sell stocks, shares or other securities for gain. ••Never use any inside information you have for gain, I was at a party with some friends and was
It is illegal and our Code forbids it. or encourage anyone to use what you know to probably showing off a bit. In the morning I
trade in Subsea 7 shares or in the shares of realised I’d said too much about a big deal we
“Inside information” is any confidential information another company. were going to sign in a few days. I thought I’d
about Subsea 7 that isn’t yet known to the public, get into trouble so at first I decided to hope for
••Be careful not to disclose inside information to
and that could affect our share price. For example, the best and say nothing. Then I realised I just
anyone else and protect it against accidental
a major new contract, an acquisition or our financial had to report it, and found out someone else
disclosure.
results, remain “inside information” until they have already had. It was tough, but it could have
been published. ••If you are an insider, make sure that your family been a whole lot worse. They actually told me
know about insider trading rules and that they if I’d left it any later, I might well have faced
If you have such information and use it, or tell apply to them too. dismissal and potential criminal prosecution.
someone else about it, in order for either of you ••If you’ve disclosed inside information to others,
to gain or profit from what you know before others or think someone else has, or you’ve been
know it, that’s called “insider trading”. approached by someone trying to get information
Insider trading is unethical, unfair and a serious out of you, don’t hesitate – let us know Tempted to use inside
criminal offence. Anyone caught doing it could immediately. information or tell
face a prison sentence, and it can also damage
the company’s reputation and the trust others
someone else about it?
have in our integrity.
Don’t be!

For more information, see:

 ee the Appendix on page 38 to find out
S
about insider trading laws and who are Our Policy in Relation to Insider Trading
“insiders” (PO-GL-LAW-003)

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Proper use of company assets

and resources It happened to me
Over lunch at work, a few of us got chatting
It can be all too easy to blur the lines between
using company assets and resources in a proper
In your hands: about travel expenses. A colleague was saying
••Take care when spending the company’s money he would sometimes add a weekend on the
way … and for personal convenience or
or incurring expenses. end of an overseas business trip and charge
advantage.
the hotel cost to the company. One or two
••If you think there is good reason to bypass our others boasted that they frequently manipulate
We all have a duty to act in the company’s best
supply chain management procedures, always be their expenses claims. They said, “Come on,
interests at all times
sure the company is getting good value for money, everyone does it!” I said, “Surely that’s wrong,
This means: and check with someone who is qualified to it’s the company’s money.” The funny thing is,
••Being good custodians of the company’s assets, properly assess and approve your proposed once I spoke up, I found that most of my
interests and resources. course of action. colleagues agreed with me. They were just
••Using its assets and resources (including ••If you are the most senior Subsea 7 employee at hesitant to stand up for what they believed
spending its money) wisely and for the benefit a team meal or event, you should pay the bill and was right.
of the company. get the expense approved by your manager.
••Following our supply chain management
procedures, which are designed to ensure we
get value for money and appropriate quality.
Ask yourself:
Our shareholders rely on us to do that.
Are these costs appropriate?
Are these expenses reasonable
and necessary for me to do
my job?
Is this how I would spend my
own money?

For more information, see:

Our SCM Processes and Procedures

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Part 3
Looking after people, This part of our Code is rooted in our
communities and our planet. commitment to human rights: that people
are treated with dignity, fairness and respect,
and that we have a positive impact on the
communities and environments where we work.
The final section (Working with others) explores
how we should treat third parties, but also our
commitment to working only with third parties
who have similar standards across all aspects
of our Code.

Contents
27 Respecting human rights
28 Treating each other fairly and with respect
29 Keeping each other safe, secure and healthy
30 Maintaining our quality to deliver performance
31 Looking after our planet
32 Treating communities with care and consideration
33 Working with others: clients, partners and suppliers

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Respecting human rights

We will always respect the dignity and uphold
the human rights of everyone working for
In your hands: It happened to me

us or with us, including people who work for ••Fundamentally our Code is all about standing up We were looking out for human rights abuses
our suppliers or who live in the communities for human rights in all we do, wherever we work in faraway countries, and it was happening
where we work. – so no one is ever mistreated, abused or right under our noses: an investigative
exploited by us or anyone we work with. journalist revealed that the office cleaning
As well as covering things like the right to life, and company we used at our headquarters
••Please help us to confront any abuse of human
freedom of thought, expression and religion, human was paying less than the minimum wage
rights by reporting it if you see it happening or
rights are also about the right every human being has to its staff, and some of them were victims
suspect that it may be taking place.
to be treated with dignity and respect, fairly and of human trafficking.
equally, and to work in an environment that is safe, ••We sometimes work in places that have a poor
secure and free of corruption. human rights record, where some may argue that
some forms of abuse are acceptable because
We will not accept any abuse of human rights, “That’s just the way things are round here”. Human rights are the
including human trafficking, forced or involuntary
labour, and we will not work with anyone who does.
No kind of abuse is ever acceptable – never
be persuaded that it is.
birthright of everyone.
••We ask you to pay particular attention to the issue
of forced labour and human trafficking when
working with suppliers and third parties and not
turn a blind eye if you think it may be happening.
The UN Global Compact Where to look for more information:
Subsea 7 is proud to be a signatory to the
UN Global Compact, in which the United Nations We recognise our responsibility as stated in the UN
has set out 10 principles covering human rights, Guiding Principles on Business and Human Rights,
to respect human rights, and to avoid and address any
labour, environment and anti-corruption. Together adverse impacts of our business.
these principles ensure businesses can uphold their
basic responsibilities to people and the planet, while These are internationally recognised human rights
as expressed in the International Bill of Human
also creating long-term success. Rights and the International Labour Organisation’s
Declaration on Fundamental Principles and Rights
at Work.
We also support the International Labour
Organisation’s Standards on child labour and
minimum working age.

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Treating each other fairly

and with respect It happened to me
It had been going on for some time.
At Subsea 7 everyone has a right to be treated
fairly, with dignity and respect, and to have
In your hands: Mostly it was just low-level bullying. We all
••Always treat people respectfully, as you would tried to ignore it. But then I saw one of the
equal opportunities in a supportive, friendly
wish to be treated. men actually in tears. I just thought, “I have
and inclusive environment free from all forms
to stop this.” So I contacted Safecall.
of discrimination, harassment or bullying. ••If in doubt, consult our Equal Opportunities
and Diversity Policy. It includes things such as
These are rights and principles we uphold wherever
working conditions and wages.
we do business.
••If you have any questions, please contact your You can stop it!
So we always observe fair employment practices, local HR department – they will be able to
and provide fair treatment for all individuals and advise you. If you see, experience
equal opportunity on the basis of merit. ••When you make a decision about an individual or suspect bullying,
or group, ask yourself: am I really being fair and
We value and promote diversity and regard it
as a key to our success. unbiased? If you have any doubts, talk it over harassment or
with someone whose integrity you trust. discrimination, don’t
We never fall below applicable national legal
requirements and agreed standards for wages, put up with it – tell us.
working hours and minimum working age.
We will protect you
We won’t tolerate any form of bullying, harassment
or discrimination, and will act against it if we find and them.
it happening.
And we will not allow anyone who has the courage
to Speak Up about potential breaches of our code
of conduct to be victimised or suffer any form
of retaliation. A. It’s discrimination if it’s against:
For more information, see:
race, colour, religion, national origin, sex,
Our Equal Opportunities and Diversity Policy
pregnancy, age, disability, marital status, (PO-GL-HR-012)
sexual orientation, or any other characteristic
protected by applicable law. Go to your local HR intranet to find your local
Disciplinary and Grievance Procedures

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Keeping each other safe,

secure and healthy It happened to me
We all knew the rules and procedures, but we
No one should ever be harmed because of
what we do.
In your hands: reckoned we knew what we were doing, and
••By actively upholding our safety culture and the risks just seemed so slight. It seemed like
That’s why we commit ourselves to having an staying alert, you can help to eliminate risky a lot of effort and bureaucracy, so we cut
incident-free workplace, and providing a safe behaviours and correct unsafe conditions. corners. I didn’t think it was my place to say
and secure environment for everyone involved anything. And to be honest, I thought everyone
••Don’t start a job if you’re uncertain what to do, else would think I wasn’t a “team player”.
in or affected by our activities.
or think it can’t be done without harming people So I let it go. Disaster struck, and my workmate
We make an absolute commitment to put the or the environment. suffered quite a nasty injury.
highest safety standards, procedures and training ••Make sure you know and follow all the health,
in place wherever we work, and make sure they safety and security procedures, standards and
are maintained, reviewed and improved against instructions at your workplace. If you aren’t sure,
evolving best practice. or think you haven’t been trained, tell your Stay alert, and challenge,
And we make sure that all those working at any
supervisor. stop and report unsafe
••Only do work you’re trained, competent and
site we operate are fully and regularly informed
medically fit to do. Check yourself and others;
behaviour or equipment
and trained.
don’t pretend you’re okay to carry on when whenever you see it.
But that’s not enough. We also need everyone to you’re not.
actively look after each other and watch out for ••Be courageous! If you think work has become
each other’s safety. unsafe, stop it at once, and make sure others
do too. You are empowered to do that! Never
assume someone else will sort it out. Make it
your job to alert those around you and report
issues straight away.
••If you’re worried about a colleague’s physical or
mental health, always let us know. If someone is For more information, see:
in difficulty, it’s our job to help them.
Our HSEQ (Health, Safety, Environment and
••Never act before thinking! Quality) Policy Statement (PO-GL-COR-004)
Our Group Health, Safety, Environment and
Security Handbook (MA-GL-HSE-005)

29 © 2020 Subsea 7
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DOING BUSINESS WITH INTEGRITY INFORMATION AND ASSETS PEOPLE, COMMUNITY AND PLANET

Maintaining our quality

to deliver performance It happened to me
During a project I could not determine the
We collaborate with our clients, partners,
colleagues and suppliers to identify and
In your hands: delivery condition of the pipe materials being
••Never cut corners – take the time needed to welded. Instead of just letting it go, I decided to
provide the most efficient solutions,
execute work as planned. investigate it further and I found that the
technical innovation and performance.
material certifications were missing vital
••Don’t be scared to get your work checked – information. Had I let it go it could have
Quality lies at the heart of our performance, and
this is a vital part of how we maintain our quality. resulted in a pipeline being installed out of
we constantly seek to raise the bar, actively looking
for areas where we can work in smarter ways and ••Know the key performance indicators for your specification which could have had a huge
improve our processes, systems and procedures. work and discuss them openly. impact for the project and the company.
••Look out for quality risks and critical parts that
Our quality standards, management processes and can impact our projects.
procedures set the bar against which all our work
and materials are measured. ••If you think it can be done better and more
efficiently without compromising our goals then
Quality in Subsea 7 is
By following them at all times we can guarantee tell us about it – we really do want to know! in everyone’s hands
consistent quality and performance for our clients, ••Document and risk assess all changes. – including yours!
and avoid mistakes and defects that can have Keep it controlled.
disastrous effects on our reputation and the ••Plan to get it right first time, every time.
possibility of winning work in the future.
••Don’t start unless you know how it will finish.
They also play a vital role in helping to keep us safe ••If it’s not right STOP and find a solution.
and ensuring we do no harm to the environments in
••Risk assess all tasks and operations.
which we work.
If there is a better way to do things, we will do all
we can to adopt it.

For more information, see:

Our HSEQ (Health, Safety, Environment and Quality)

Policy Statement (PO-GL-COR-004)
Our Quality Compliance Management Procedures
(PR-GL-QMI-004)

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Looking after our planet

We are always mindful of our responsibilities
to protect the planet and to ensure that our
In your hands: It happened to me

activities do not harm the environment. ••Consider the impact of your actions on the I found out that a supplier we sometimes
planet. worked with was dumping waste into the
We always assess and seek to mitigate any ocean. They weren’t working for us at the time,
••Small things matter – recycle and avoid using
possible environmental impacts before we so a couple of the guys said I should just leave
disposable plastics.
undertake any project. it and there was nothing we could do. But it
••Know and follow the Environmental Management was just so wrong – and against everything we
We act on climate change by actively reducing Procedures where you work, and challenge stand for. So I decided to report it. It had an
our emissions, and helping to develop sustainable anyone who doesn’t. immediate effect – the dumping was stopped,
energy sources through our renewables business. ••If you’re concerned that we or anyone we are the supplier lost their licence and it gave a
When developing new technologies, we look to working with may be causing harm to the powerful message to others.
mitigate our impact on our planet, including the early environment, you have the power to make your
adoption of evolving industry best practice to avoid voice heard. Challenge it and report it – we will
listen and investigate.
damaging or polluting the environment.
••If you have an idea for improving how we or our
Help us do all we can
We do this transparently. Everyone working for suppliers can protect the environment, tell us. to take care of the
us has a right to understand what measures are
in place to protect the environment. environments we work in.

For more information, see:

Our HSEQ (Health, Safety, Environment and Quality)

Policy Statement (PO-GL-COR-004)
Our Environmental Management Procedures
(PR-GL-HSE-016)

31 © 2020 Subsea 7
 WHY OUR CODE MATTERS SPEAKING UP PART 1 PART 2 PART 3
DOING BUSINESS WITH INTEGRITY INFORMATION AND ASSETS PEOPLE, COMMUNITY AND PLANET

Treating communities with

care and consideration It happened to me
We were working offshore, and I was
We take every measure to ensure our activities
are sustainable and we are a positive force for
In your hands: responsible for crew changes and other trips
••Take particular care to understand local customs ashore. We had to use the Customs Office
good in the communities where we work.
and cultural sensitivities and always act in a way jetty, but we repeatedly faced demands for
So we take great care to think through the local that respects them. Things that may seem unofficial payments. We found another jetty,
social, environmental and economic impacts perfectly acceptable to you can be misconstrued but it was decrepit and clearly unsafe.
of our work and our presence. in other cultures, and you can even end up We offered to pay to install a jetty. The Port
We always treat the communities we work among causing real offence when you didn’t mean to. Authority was happy and granted the
with courtesy and respect, and we support and ••However, don’t be persuaded to do something necessary permits.
obey local content laws. that is unethical or illegal just because someone
tells you it is the local custom and you will cause At the end of the project, the head of the
This should also involve discussions with local offence if you refuse. If it’s wrong, always refuse. Port Authority suggested that we donate the
community members whenever that is appropriate. jetty to the local community. We wanted the
••Treat people respectfully, as you would wish to local community to benefit, but in the back
We communicate openly, listen to any concerns, be treated. If you are with colleagues, make sure of my mind I recalled something about how
and do our utmost to respond positively. they do the same. a donation requested by a public official
••If you want to do something for the local can be perceived as improper influence.
We are transparent, letting people understand
community, that’s great – but always check
what we are doing, and take time to show After checking with legal, we entered into an
first that it’s for the right reasons, legal and
them the measures we have in place to protect appropriate contract with the Port Authority.
appropriate. (See “Community Engagement,
their environment. There was even a plaque acknowledging
Charitable Donations and Political
Contributions” for more details about this.) our gift to the community.
••If you believe any aspect of our work may cause
harm, or you know of something that might
create tension between Subsea 7 and the local
community, let us know sooner rather than later.
Don’t let it do damage or turn into hostility.

32 © 2020 Subsea 7
 WHY OUR CODE MATTERS SPEAKING UP PART 1 PART 2 PART 3
DOING BUSINESS WITH INTEGRITY INFORMATION AND ASSETS PEOPLE, COMMUNITY AND PLANET

Working with others: clients,

partners and suppliers It happened to me
Some years ago, we were in discussions with a
Everyone we work with has a right to expect us
always to follow our Values, and the principles
In your hands: local partner about possibly working together
••Always treat clients, business partners and in a market we were trying to get into. We
and standards of integrity, fairness and honesty
suppliers with honesty and integrity. followed all our procedures, and our due
that our Code sets for us.
diligence checked out OK, but somehow,
••Make sure you follow the approved process we were not convinced about their honesty
We expect those same standards from them.
for engaging with clients and partners and or methods, so we didn’t go ahead with them.
We are committed to working with clients, partners our Supply Chain Management Procedures Recently I read that they are being investigated
and suppliers who uphold standards at least as when you engage or work with any supplier. for paying bribes to win work for another
high as those set out in our Code of Conduct. They are designed to ensure suppliers are company in our sector. That was a near miss.
chosen on merit, are appropriately qualified Thankfully, our instincts and processes
We ask that suppliers comply with our Code of and experienced, and are able to operate
Conduct for Suppliers. But in truth, we are even were sound.
to standards similar to our own.
happier when a supplier or partner can point
••If you’re worried that something a third-party is
to their own code, and to values that are
doing may be breaking our Code, or you hear
compatible with ours, which they hold dear
and have embedded properly.
about something that concerns you, report it What those we work with
straight away. do is very much part of
When working in a joint venture or consortium, ••Don’t enter into any business relationship with
we make sure there is clear alignment with our a third-party unless and until you are confident
our business.
partners on compliance and ethics standards that they take their ethical responsibilities
and procedures. seriously. Always be respectful,
••Make sure you assess the risks and perform due always stay watchful.
diligence to ensure you have enough information.
••Don’t enter into an agreement that doesn’t have
a clear and proper commercial rationale.
For more information, see:

Our Supply Chain Management Procedures

Our Code of Conduct for Suppliers
(PO-GL-COR-016)

33 © 2020 Subsea 7
 APPENDIX

Small bribes and facilitation payments

Some examples of so-called How to resist a demand
“facilitation payments” If you are asked to make a payment and suspect it
Common examples include payment in return may be a facilitation payment or other form of bribery,
for processing permits, licences, other official you should consider taking the following actions:
documents, visas, work orders or things like: ••Be polite.
••Customs clearance ••Avoid threatening language.
••Border crossings ••Be prepared to say NO.
••Harbour entry or canal transits ••Request an explanation of why payment is
••Police checkpoints necessary.
••Immigration services ••Question the legitimacy of the demand.
••Work permits ••Have regard for your personal safety and liberty
••Vehicle registration and for that of colleagues and families.
••Utilities connections ••If possible, depersonalise any actions taken
(“The company wishes…”).
••Tax audits or confirmations
••Actually say NO (but only if you are not putting
••Licence certifications
yourself or someone else at risk).
••Cargo handling
••Ask to speak to the person’s superior.
••Access to areas controlled by others.
Explain that:
••Your company’s policy is to prohibit unofficial
payments and that you could lose your job if
you pay.
••If you pay, you and your company may be
committing a criminal offence.
••The person requesting the payment could be
similarly liable.
••You are only allowed to pay official, published
fees, and in return for an official receipt.
When back in the office or at home, keep note of who
said what to whom.

34 © 2020 Subsea 7
 APPENDIX

Gifts and hospitality

Register of gifts How to refuse a gift:
and hospitality Be polite, be firm, depersonalise.
Always try to decline the offer gracefully and at once.
The purpose of the gifts and hospitality register
Thank the person, express regret, and depersonalise
is to encourage transparency and help embed
– explain how our policy just makes it impossible for
our culture of honesty and integrity. If someone
you to accept.
is happy to put something on the register, then 99
times out of 100 they are likely to have considered If you’re not sure whether it’s appropriate, say so:
the matter properly and made a good decision. explain that the company has strict limits on what
you can accept, so you will have to check.
Don’t be manipulated or persuaded to change your
mind. If the person refuses to take the gift back, or
they are offended, it’s okay. You are simply doing the
right thing. Tell your manager straight away, and
record what’s happened.

35 © 2020 Subsea 7
 APPENDIX

Conflicts of interest
Examples of a conflict of interest include:
••Trying to influence hiring a member of
your family.
••Giving a contract on behalf of Subsea 7 to
a business owned or managed by a friend
or a family member.
••Employing someone because they may have
undue influence with a client or government that
will give us an unfair competitive advantage.

36 © 2020 Subsea 7
 APPENDIX

External communications
Who can speak externally? Rules for a listed company
Only the Chief Executive Officer, the Chief Financial As a listed company we have to follow a number of
Officer (or their nominee) or Investor Relations are regulations and laws that mean official documents
authorised to disclose information about the Group and information must be released at specific times
to the Investment Community. only. We also have strict obligations to disclose
material information to the Stock Market. We
On a case by case basis, Senior Vice Presidents always respect and comply with such obligations.
and Vice Presidents may be authorised to
communicate with the media.

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 APPENDIX

Insider trading
Who are “insiders”? Insider trading laws
Anyone who has access to inside information Insider trading laws cover the trading in any shares
is designated as an “Insider” and has to follow or other securities or options, futures and other
certain restrictions. rights to the securities of a company listed on
any stock exchange, and any inside information
Some people who have frequent access to sensitive someone may gain through their employment
information, like company directors, are designated with Subsea 7.
as “primary insiders” and they are subject to
enhanced restrictions.
Details of all these restrictions are contained in our
Insider Trading Policy.

38 © 2020 Subsea 7
It’s your Code, and
doing what’s right
is in your hands …

Not sure? Use the 4 tests:

1. Do I honestly believe this is right?
2. Is this consistent with our Values and who we are?
3. Would I be happy reading about this in the news?
4. Have I checked with our Code and someone whose
integrity I trust?

Concerned something’s wrong?

You can contact Safecall, the confidential Subsea 7
reporting helpline 24 hours a day, 7 days a week.
Go to www.safecall.co.uk, or use one of the telephone
numbers listed here.
www.subsea7.com

communications@subsea7.com

© Subsea 7, January 2020