We define our commitment to high ethical standards in our code of conduct. It is based on our values and clarifies the principles and expectations for how we work at BP
Our code of conduct covers operating safely, responsibly and reliably; respecting and valuing our people; how we work with our partners and suppliers; protecting BP’s assets; and working with governments and communities, including our commitment to human rights. Our code applies to all employees, officers and members of the board. We expect and encourage our contractors and their employees to act in a way that is consistent with our code and we take appropriate actions where we believe they have not met our expectations or their contractual obligations. We provide our employees with training and communications on how to apply the code’s principles. Managers are responsible for helping their teams understand how the code guides the way we work and are expected to have conversations with their teams throughout the year. Each year, our employees certify that they understand the code, have abided by their responsibilities and have reported any breaches of which they were aware. In 2015 we extended this certification process to include our board members, who all certified during the year.
Our values express our shared understanding of what we believe, how we aim to behave and what we aspire to be as an organization
We are committed to providing an open environment where our employees, contractors and other third parties are comfortable speaking up whenever they have a question about our code or see something they feel to be unsafe, unethical or potentially harmful. Employees are encouraged to discuss their questions or concerns with their managers, relevant supporting teams or BP’s confidential helpline, OpenTalk. A total of 1,158 people contacted OpenTalk with concerns or enquiries in 2015 (2014 1,114; 2013 1,121). We look for opportunities to reinforce our culture of speaking up. For example, we identified that the number of concerns raised by our employees in Azerbaijan, Georgia and Turkey was lower than expected. Following a survey, we discovered that employees were not aware of the channels available to raise concerns or were reluctant to use them. To address this, we delivered more than 100 training sessions to employees, contractors and suppliers. The sessions reinforced the importance of ethical behaviour, explained how to raise concerns and outlined our policy of zero tolerance towards retaliation. Since the programme began in 2013, the number of concerns raised in the region increased from 37 to 58 in 2015.
Consequences for misconduct or retaliation range from coaching and performance management through to dismissal. Our businesses dismissed 132 employees for non-conformance with our code of conduct or unethical behaviour in 2015 (2014 157; 2013 113). This excludes dismissals of staff employed at our retail service stations.
Anti-bribery and corruption
We operate in some of the world’s highest risk countries from an anti-bribery and corruption perspective, as measured by Transparency International’s Corruption Perceptions Index. Our code of conduct explicitly prohibits engaging in bribery and corruption in any form. We have a responsibility to our employees, our shareholders and to the countries and communities in which we do business to be ethical and lawful in all our dealings. Our group-wide anti-bribery and corruption policy applies to all BP-operated businesses. The policy governs areas such as the inclusion of appropriate clauses in contracts, risk assessments and training. We provide training to those employees for whom we believe it is most relevant, for example, depending on the nature or location of their role or in response to specific incidents. Before working with suppliers, we conduct assessments in order to determine the degree of bribery and corruption risk posed. This helps us put mitigation plans in place when needed. We also check suppliers once contracts are in place. For example, in Upstream we carry out anti-bribery and corruption audits on a risk-prioritized basis to confirm whether suppliers are complying with related contractual terms. We issued a total of 35 audit reports in 2015 (2014 36; 2013 44).
Lobbying and political donations
We do not use BP funds or resources to support any political candidate or party. We recognize the rights of our employees to participate in the political process, provided they make it clear that they do not represent BP and do not use BP time, property or equipment. We require employees who plan to seek or accept a role in public office to notify their line manager in advance.
Employees’ rights to participate in political activity are governed by the applicable laws in the countries in which we operate. For example, in the US we support the operation of the BP employee political action committee (PAC) to facilitate employee involvement and to assess whether contributions comply with the law and are publicly disclosed. The way we interact with governments depends on the legal and regulatory framework in each country. We engage across a range of issues relevant to our business, from compliance with regulation to understanding our tax liabilities to collaborating on social and community initiatives. In some instances we will engage with governments through lobbying, a process that in many countries is strictly regulated by national laws. For example, in the US we are required to file quarterly and twice-yearly lobbying disclosure reports. Any lobbying activity we undertake is done in accordance with local laws and our code of conduct.