North Oil Company (the “Company”) commits to doing business ethically with the highest levels of integrity consistent with its values and Business Principles. Unethical acts by or against the Company will not be tolerated. To that end, the Company is introducing this “whistleblowing” procedure that will allow anyone to report concerns and information regarding known or suspected breaches of the Company’s Code of Ethics. This procedure is applicable to both employees and external stakeholders, such as contractors, business partners, employees of suppliers and former employees.
RESPONSIBILITY FOR PREVENTING, REPORTING AND INVESTIGATING FRAUD
Unethical behaviours, such as fraud, corruption and discrimination, should be everyone’s concern. It is a risk across the entire industry with damaging consequences for all parties concerned. The Company’s Code of Ethics specifically states that “Employees have a responsibility to report any witnessed or suspected incidents of misconduct, unethical or other behaviour incompatible with the provisions and spirit of the Code”. North Oil Company believes that this responsibility is also shared with its suppliers, shareholders and other stakeholders who have a similar interest in the Company’s long-term success and its contribution to the State of Qatar.
North Oil Company does not tolerate action taken, or threats of action, against employees for asking questions, voicing concerns, or making complaints or suggestions in relation to the Code of Ethics, unless the employee acts with flagrant disregard for the truth.
North Oil Company has a duty to investigate areas of concern, including reports of potential breach of the Code of Ethics, and to refer the same either to the Compliance Officer or the Company’s Internal Audit division when necessary. Internal and external stakeholders can provide valuable assistance to North Oil Company by reporting their concerns at the earliest opportunity.
NOC provides several confidential mechanisms for reporting, including a link available on the Company’s internet and a mailing address. For the link, username and password will be required for the sole purpose to assist any future investigation. Messages left via this page will be directed for further investigation. Nonetheless, information received will be treated as strictly confidential. Persons who do not wish to use the link to report their concerns can write (anonymously) to the Compliance Officer or the Audit Corporate Manager, North Oil Company, P.O. Box 21264, Doha, Qatar.
All concerns reported will be reviewed and where there is sufficient information to investigate and corroborate the concerns, an investigation will be carried out by EITHER THE Compliance Office or the Company’s Internal Audit division.
WHAT TO REPORT THROUGH THE WHISTLEBLOWING PROCEDURE
- Any concern or information about potential fraud or illegal activity carried out by the Company’
employees or divisions.
- Any concern or information about unethical behaviour on the part of the Company and/or its employees.
- Any concern or information about any fraudulent activity carried out by employees, contractors or other
outside parties against the Company.
WHAT NOT TO REPORT THROUGH WHISTLEBLOWING PROCEDURE
- Any concern of a personal nature, such as issues relating to compensation and benefits.
- Any concerns relating to safety or security, they should be reported to HSEQ directly.
- More generally, any concern which falls within the scope of a designated division or person.