RESPONSIBLE BUSINESS CONDUCT
Shelf Drilling is committed to honest, transparent and ethical conduct. We have embedded these values in our way of working with customers, suppliers, employees, shareholders and the communities in which we operate. Our commitment to responsible business conduct is outlined in our Code of Business Conduct and Ethics (“Corporate Code”).
Shelf Drilling’s Corporate Code defines the standards for how we do business. It reflects our commitment to conduct global operations according to the highest ethical standards.
Our Board of Directors has specifically directed the issuance and implementation of the Corporate Code and retains ultimate responsibility.
Shelf Drilling has zero tolerance for corruption and has adopted a Global Anti-Corruption Policy, which commits us to stringent rules and regulations in line with global anti-corruption laws, including the U.S. Foreign Corruption Practices Act (FCPA) and the UK Bribery Act 2010.
Our anti-corruption policy requires all employees and third-party representatives to comply with applicable anti-corruption laws and regulations in countries where we conduct business. We have internal controls and procedures in place as well as conduct training to assure compliance with company policies, laws and regulations. This policy is supported by the following three documents which provide detailed guidance regarding key risk areas, these include:
- Shelf Drilling Facilitating Payments Policy
- Shelf Drilling Gift, Meal, Travel & Entertainment Procedure
- Shelf Drilling Third Party Due Diligence Procedure
All our employees also complete annual re-certification in relation to the Corporate Code and its supporting policies.
RIG RECYCLING AND EQUIPMENT REUSE
Shelf Drilling recognizes the risks associated with rig recycling, including potential adverse effects on human rights, health and the environment associated with rig recycling. As a responsible and transparent rig owner, we are committed to recycling rigs at the end of their useful life in a safe and sustainable manner that complies with applicable laws and minimizes risk to people and the environment. Shelf Drilling has developed a policy, approved by the Board, that defines the specific laws and conventions that will be adhered to in recycling any jack-up rig (‘rig’ or ‘rigs’ hereafter), including the Hong Kong Convention.
As outlined in the policy, Shelf Drilling will only sell its rigs intended for recycling to certified recycling yards or intermediate brokers who commit to ‘green-recycling’ with sufficient infrastructure, equipment and procedures to ensure safe and environmentally sound dismantling practices in accordance with our recycling policy. Shelf Drilling will also engage, or require the buyer to engage, independent third-party contractors to audit and oversee end-to-end recycling/dismantling of our rigs at the recycling yards.
Prior to recycling, Shelf Drilling removes substantial volumes of equipment that is then refurbished and reused by our operating fleet. In addition to being a cost-effective way to maintain our fleet, this also results in a significantly reduced impact to the environment (less scrapping, less demand for new equipment etc.).
Through 2018 and 2019, Shelf Drilling has recycled or reused over 1,000 items with an estimated steel content of 1,900 tonnes corresponding to an approximate saving of 3,500 tonnes of CO2.
WHISTLEBLOWING / SPEAK-UP
Shelf Drilling is committed to promoting and sustaining a culture where everybody is comfortable to report concerns in good faith and without fear of retaliation. Through our ongoing “Speak Up” initiative we encourage our employees to ask compliance and ethics questions, raise concerns and report actual or suspected wrongdoings.
Concerns by employees or third-parties can be reported to the “Shelf Drilling EthicsPoint Helpline” either via telephone (toll-free) or webform. The helpline is available in multiple languages and is operated 24/7 by an independent third-party provider to help maintain confidentiality and, when requested, anonymity.
PRIVACY AND DATA SECURITY
Privacy regulations are increasingly important as more and more countries develop their own data privacy laws. In line with this development, Shelf Drilling implemented a privacy program in 2018, adopting the General Data Protection Regulation (GDPR) standards. Equally important is Shelf Drilling’s focus on data security and ensuring personal data is protected from unauthorized third-party access or malicious attacks and exploitation of data by employing essential IT and cybersecurity measures.
Our policies and procedures such as Vendor Selection and Review and Third-Party Due Diligence Procedure, outline how our vendors are selected and reviewed to ensure that they conduct their business in a manner that is consistent with Shelf Drilling’s corporate values and policies.
Our Vendor Code of Conduct sets out Shelf Drilling’s business conduct and ethical performance requirements for all vendors in terms of integrity, anti-bribery, compliance with local regulations, declaration of conflicts of interest, respect for human rights, health, safety and the environment and dealing with confidential data. All vendors must comply or explain deviations with the code’s provisions during the onboarding process.