In 2016, Ophir continued to carefully manage exposure to corruption and bribery risks across all of its operations.
All Ophir Directors, employees and contractors are required to comply with Ophir’s Code of Conduct, Global Anti-Corruption Policy and ethical conduct Standards (Compliance Processes). Ophir introduced an electronic sign-off process for all staff at the beginning of 2016, whereby staff confirm that they have not breached the Compliance Processes in the prior year. This is being maintained in 2017 and beyond.
Compliance registers are maintained across all assets and business functions covering government hostings, per diems paid to government officials and hospitality given to or received from third parties. Activities above certain financial thresholds require pre-approval before they can be performed.
Tailored due diligence is performed across a range of business activities covering the supply chain, Corporate Responsibility and business development and M&A activities to enable Ophir to make informed decisions about who to contract with, who to do social investment work with, and who to partner with.
In relation to the supply chain and third party contracting, Ophir has implemented an Intermediaries Standard and an Ethical Compliance Due Diligence Standard. Additionally, Ophir maintains an Intermediaries register to keep a record of and manage Intermediaries appointed by the Company.
Further, in relation to CR, Ophir has introduced a Social Investment Due Diligence Standard which requires due diligence to be performed before Ophir allocates money to community development projects.
In the context of business development, global new ventures and M&A, there is a standalone due diligence process in place which applies before a decision is taken to farm-in to a new licence and/or contract with a new partner and to make a corporate acquisition.
Ophir expects staff to disclose all conflicts of interest, any personal connections which staff may have to people in government and to notify the General Counsel & Company Secretary of any exposure to corruption. Where any instance of a request to make a corrupt payment arises, staff are expected to immediately report.
With effect from the start of 2017, a Compliance Monitoring Plan has been put in place to provide the Board with more clarity in relation to key corruption prevention activities. This is intended to elevate the ongoing discussion about exposure to corruption risk and to improve corruption detection. Where corrective action is taken to mitigate corruption risk identified through the Compliance Monitoring Plan, it will be done so in consultation with the Audit Committee. The objective is to understand where real corruption risk lies and to limit Ophir’s exposure to it.