Corporate Citizenship And Goverance

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Corporate Citizenship and Governance

SpringRock recognizes its roles as a good corporate citizen. In addition, we believe good corporate governance is key to guaranteeing our long term business viability and it is also essential in promoting the economic development and empowerment of the communities where we live and work.

Good corporate governance is lived up to through a series of policies and practices and through good corporate governance we would avoid corrupt practices while also promoting transparency in our business practices.

Ethics Policy

SpringRock’s Ethics policy reflects the high standard of business conduct that is expected within the Company. Our Ethics Policy defines our commitment to support a culture of openness, trust and integrity in all we do.

We are committed to conducting all of SpringRock’s affairs and activities with the highest standards of ethical conduct. We would obtain business only through the use of our ability and track record of delivering superior quality returns in our investments, services and products. All of us have an obligation to adhere to this policy and encourage others to do the same.

 

Code of Conduct

The Ethics Policy clarifies the standard of conduct. It makes clear that SpringRock expects employees to understand the ethical considerations associated with their actions. Our Ethics Policy affirms our commitment to not merely obey the law, but also to conduct our business with integrity and without deception, specifically in regards to the relationship, interaction, and affairs conducted with government officials, representatives, and delegates.

Employees should not give or accept gifts of more than token value to (or from) any individual or company or that does business with SpringRock, or seeks to do so.

SpringRock expects all employees to speak up and to ask questions when in doubt.  Employees are encouraged to contact their manager to raise and address any issues of concern. They can also report issues to SpringRock Legal Counsel/Director of Compliance, or Chief Executive Officer.

SpringRock management is committed to ensuring that legitimate areas of concern or violations are promptly addressed.

Any violation of our code of conduct may subject the employee to disciplinary action

Anti-Corruption

Integrity is one of the values of SpringRock. And to live up to our value of integrity, we maintain the highest anti-corruption compliance in all of our business dealing. Everyone acting on behalf of SpringRock are strictly prohibited to engage in improper payment or engagement that can unduly influence government officials or clients or anyone we do business with.

All employees, contractors and stakeholders are trained on our anti-corruption awareness program which is built to create awareness and knowledge on our commitment to the national laws in the countries we operate, the US Foreign Corrupt Practices Act FCPA and the United Kingdom Bribery Act and Global Anti-Corruption Standards.

Reporting of Wrong Acts and Practices

Our employees, contractors and all stakeholders are encouraged to voice any concerns they may have related to any practice or occurrence that they do not see as being at the level of integrity and ethical practice expected in SpringRock. They are also encouraged to report any wrong doing they encounter.

Employees are to report wrong doing to their supervisors and managers or to the director of compliance. In addition, SpringRock maintains a hotline for reporting of a wrong doing on the phone anonymously. We also have an email address to which wrong doings can be emailed.

The program guarantees confidentiality and holds a strong prohibition from any form of intimidation and retaliation.

All reports are thoroughly reviewed by the Compliance function following a well laid out procedure for investigation, reporting and recommendation of corrective actions and disciplinary actions where applicable.

Internal Controls and Audits

A crucial part of our practice is the use of internal controls and audits to ensure rigorous implementation of our ethical policy and code of conduct. We conduct self-assessment yearly to enable each operating location assess their level of compliance.

In addition, we conduct audits led by persons from other business groups and the group headquarters to measure the level of compliance and identify any areas of improvement in each operating unit or business group’s operations.

Transparency and Exemplary Practices

SpringRock is committed to ensuring transparency in our conduct and engaging in exemplary practices. The first step in ensuring transparency starts with us in our reporting of our activities, compliance with regulatory requirements, payment of our taxes and all statutory obligations not only properly but also in a timely manner.

We also undertake to participate in initiatives that encourages transparency in government activities and reporting of government revenues from the energy industry thereby helping to reduce corruption.

We also encourage the use of best practices and international standards are related to reporting of government payments.

The Sustainable Development Process in SpringRock