Aker BP strives to uphold the highest standards of ethical behaviour in all our operations across the entire value chain.
We are committed to acting ethically, responsibly and in compliance with applicable laws, rules and regulations, as well as internationally accepted guidelines, conventions or similar standards relating to corruption, money laundering, fraud, modern slavery, forced and child labour, environment, human rights, financial accountability or similar activities.
Our commitments to responsible business conduct are set forth in our Code of Conduct, as well as our Anti–Corruption Policy and Human Rights Policy.
We value everyone who works at and for Aker BP and we are committed to creating a working environment free from any form of discrimination, abuse, harassment, intimidation by or towards our employees or others affected by our operations, as detailed in our Code of Conduct. Aker BP values the unique contributions of our employees and consultants and believes that a diverse and inclusive workforce enhances deliveries and accomplishments. Our commitments to ensuring a diverse and inclusive working environment are described in the Diversity & Inclusion Policy.
The company’s values of Seekers, Accountable, Foreseeable, Enthusiastic, Responsible (SAFER) and One Team define the way we work in Aker BP. The values also guide our behaviour in the workplace and supplement our Code of Conduct. The Code of Conduct is our main governance tool, it provides guidance to Aker BP representatives on how to act in accordance with the company’s core values, and includes references to relevant policies, processes, procedures, resources and tools.
Aker BP’s Board of Directors approves and oversees administration of the Code of Conduct, the Anti-Corruption Policy and the Human Rights Policy. The Lead Compliance Officer is the functional owner and is responsible for the maintenance, communication and monitoring of the Code. The CEO is ultimately responsible for the implementation of the Code and for the monitoring of its operational effectiveness.
The Code of Conduct, the Human Rights Policy and the Anti-Corruption Policy are communicated internally and on the company’s website. Our Code of Conduct is available in English and Norwegian.
Our commitment to respecting all internationally recognised human rights is further reinforced in our Human Rights Policy and integrated into our policies and practices.
Aker BP supports and acknowledges the fundamental principles of human and labour rights as set out in the UN International Bill of Human Rights, UN Guiding Principles on Business and Human Rights and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work. We align our human rights work with the OECD Guidelines for Multinational Enterprises and OECD Due Diligence Guidance for Responsible Business Conduct.
Our responsibility means that we must know our actual or potential impacts, prevent and mitigate abuses, and address adverse impacts where we are involved.
When considering new investments or when tendering for goods and services, we review any associated human rights issues and consider how we can ensure that our operations do not come into conflict with any of these fundamental human rights principles.
Code of Conduct training employees
employees and consultants completed the code of conduct refresher training.
Integrity channel reporting
reports through the integrity channel in the reporting period
Incidents of non-compliance with laws and regulations
incident of non-compliance.
incidents for which fines were incurred.
incidents for which non-monetary sanctions were incurred
Aker BP undertakes ongoing human rights due diligence to identify, prevent, mitigate and account for our human rights impacts and has processes in place to enable remediation for any adverse human rights impacts we cause or contribute to.
A new Transparency Act relating to enterprises’ transparency and work on basic human rights and decent working conditions was adopted by the Norwegian Parliament on 18 June 2021 and will enter into force on 1 July 2022.
The purpose of the Transparency Act is to promote enterprises’ respect for fundamental human rights and decent working conditions and ensure the general public access to information. In view of the new Transparency Act, Aker BP has updated its third-party risk model to also include two macro-level human rights risk factors: Firstly, the country in which our business partner conducts business, based on Transparency International’s Corruption Perceptions Index and international human rights indexes. Secondly, the industry in which it operates, based on an internal assessment of industry risk classification.
Aker BP operates in a low-risk environment with regard to human rights abuse as all our operations are located in Norway. Furthermore, the majority of our tier 1 vendors are based in Norway or other low-risk countries. However, we are aware of potential human and labour rights risks that may occur in our operations or further down in our supply chain.
In cases where Aker BP’s operations might have caused or contributed to adverse human rights impact, we will provide or cooperate in providing appropriate remediation to individuals, workers and local communities. To such effect, we will also provide or cooperate in effective grievance mechanisms, where relevant.
As emphasised in our Human Rights Policy, we pay special attention to the rights, requirements, values and integrity of individuals and groups which may be particularly vulnerable to adverse impacts.
As part of a collaborative approach to responsible business conduct, operating companies on the Norwegian Continental Shelf have established a joint qualification system (Magnet JQS) for sharing human rights assessments of suppliers in the energy sector.
The Collabor8 Human Rights Assessment service entails a common standardised framework for conducting human rights assessments of suppliers, based on the above-mentioned law, guiding principles and best practice. The assessments are conducted by independent auditors and the results are shared among the participating companies.
The initiative is managed by Norwegian Oil and Gas, which is the professional body and employer’s association for oil and supplier companies and aims at assisting participating companies in improving worker welfare in line with the UN Guiding Principles on Business and Human Rights and the fundamental conventions of the International Labour Organisation. Aker BP has been actively engaged in the various working groups within Collabor8 since 2019.
In 2021, the Human rights working group within the Collabor8 initiative developed a common scoring protocol for the service providers to be implemented in the system to align on the scoring approach and improve the effectiveness of the system.
Since 2021 Aker BP has started to use Magnet JQS for conducting human rights assessments in the supplier pre-qualification process. The plan for 2022 is to conduct in-depth assessments on the existing suppliers and start conducting onsite audits.
Aker BP’s commitment to human rights is embedded in our internal company policies and reporting documents such as the Anti-Corruption Policy, the HSSEQ Policy, Diversity & Inclusion Policy, employee handbook and our Sustainability Framework.
Our success depends on capabilities, expertise and compliance in our strategic partnerships and alliances, and the overall supplier network. Aker BP expects suppliers and business partners to act with integrity and ethics, and to have implemented sound labour practices, respect human rights, ensure protection of health, safety and the environment, and to have zero tolerance for corruption.
Our expectations to our suppliers and business partners’ ethical business conduct are reflected in contractual provisions. All suppliers to Aker BP are required to sign Aker BP’s supplier declaration form, that is aligned with the principles of the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, International Petroleum Industry Environmental Conservation Association (IPIECA) standards and contains e.g., other principles on eliminating all forms of forced and compulsory labour and prevention of child labour.
Aker BP evaluates its prospective suppliers with regards to corruption risk, human rights risk, environmental impact, and reputation risk. The evaluation process is detailed in the Aker BP Business Partner Integrity Process.
Aker BP is responsible for ensuring that suppliers and sub-tiers comply with high ethics standards and human rights legislation. New suppliers shall comply with all requirements in our “Supplier Declaration” to become shortlisted in a tender process. Integrity Due Diligence is performed for procurement over USD 250.000. The process considers confirmation of commitment to key principles for anti-corruption, environmental protection, health and safety, labour rights and human rights. In 2021, we have improved the process implemented in 2020. Both in relation to new governing legislation, and by improvement of the process itself – based on implementation of a new business management system, and roll-out of better supplementing tools to support the Integrity Due Diligence (IDD) process. We have not identified any breaches or accidents impacting society, and there have been no fines or non-monetary sanctions for non-compliance with laws and regulations in the social and economic area in 2021.
In our strategic partnerships and alliances – we aim to ensure governing models in full compatibility with our own standards and practices, including performance-, risk- and opportunity management. The alliance setup is key to establish shared responsibility for achieving high performance in ethics, integrity, climate footprint, health, security and safety.
Our relationships are managed by evaluations, monitoring and reviews, both in the selection phase and in the regular supplier management. In 2021, Aker BP has increased the level of effort related to risks and non-conformance with legislation for labour rights, anti-child labour, anticorruption, environmental, and HSSEQ conditions – including a proactive focus on improving transparency in tiers behind the supplier.
We have implemented a more comprehensive supplier risk monitoring software and related process to onboard, monitor and manage suppliers related to HSSEQ standards and social criteria, both internally – and by increased engagement in the cross-operator platforms Magnet JQS and Human Rights Assessment Service.
Aker BP also aims to ensure joint environmental contribution with strategic partners and through our alliances. We require our suppliers to commit to preventing or minimising their environmental impact and encourage innovation and solutions that contribute to reducing the carbon footprint. In 2021, none of the major suppliers were identified as having significant actual or potential negative environmental impacts.
In cases where suppliers do not align their conduct with Aker BP’s expectations, and do not show satisfactory efforts to be aligned, Aker BP will initiate the necessary steps to implement corrective actions or have the contract discontinued.
Our zero tolerance for corruption approach is set forth in Aker BP’s Anti-Corruption Policy, which sets out a framework for preventing all forms of corruption and provides guidance to our employees and business partners on how to apply these principles in their work. We encourage our business partners and suppliers to make a clear commitment against corruption and bribery.
We regularly map our risks of being involved in corruption or bribery and implement targeted preventive actions based on this information.
Though we generally consider corruption risks in Norway to be low, we believe it is important to be aware that corruption also happens here, and that we need to be conscious of potential dilemmas and grey areas such as conflicts of interest, relationships with business partners, gifts and hospitality. Our goal is to act in an ethical and transparent manner, so that we can be a trusted business partner, employer, and corporate citizen.
Our internal anti-corruption and anti-bribery system includes necessary controls embedded in the company’s financial and procurement procedures, audits, business partner due diligence and anti-corruption training, integrity channel for reporting concerns, as well as awareness activities among employees.
In 2021, Aker BP continued to strengthen its Anti-Corruption Compliance Programme with training and awareness activities, risk mapping of suppliers and improving monitoring activities across the supply chain.
Conducting Integrity Due Diligence research on business partners constitutes an integral part of our compliance programme. The requirements for Integrity Due Diligence are stated in the Business Partner Integrity Procedure which is updated every two years and is available internally in the business management system. The due diligence process together with the human rights due diligence constitute an integral part of the procurement process and other relevant processes for interaction with third parties.
Aker BP regularly communicates the company’s Anti-Corruption Compliance Programme and relevant policies and procedures to its employees via internal websites and targeted awareness campaigns.
Aker BP’s Anti-Corruption Policy is made available to its business partners on the external website and compliance with applicable anti-corruption laws is referenced in contractual requirements set out for our business partners and suppliers.
Business ethics, compliance training and awareness
Aker BP considers Code of Conduct training an important part of its compliance programme.
Aker BP requires all new employees to participate in ethics and anti-corruption training when they join the company, and all employees and consultants receive Code of Conduct training annually. Upon completing the training, everyone must sign a declaration of compliance that they have read, understood, acted and will continue to act in accordance with Aker BP’s Code of Conduct.
In 2021, Aker BP launched an online Code of Conduct mandatory refresher course which included selected topics from the Code of Conduct such as gifts and hospitality, speaking up, conflict of interests and sponsorships and donations, the topics that we consider to be important for our Anti-Corruption Compliance Programme. A total of 2,247 employees and consultants, which corresponds to 90 percent of total registered headcount participated in the training in 2021.
To strengthen our efforts in promoting respect for humanrights and fair working conditions, Aker BP plans to launch company-wide human rights training and awareness campaigns among our suppliers and business partners in In addition, specific training in human rights due diligence and updated requirements to due diligence process will be provided to supply chain personnel and relevant stakeholders in the organisation. In order to monitor the effectiveness of its compliance training, Aker BP has aligned its training to the compliance risk profile and updated its compliance survey with relevant questions to measure the extent to which the training is applicable to the employees’ role. Aker BP regularly communicates the content of its policies through internal channels and external website, as well as meeting with suppliers, business partners and supplier days. Our contractual provisions set expectations for our business partners to align their business conduct with Aker BP’s standards and include audit clauses.
Aker BP is committed to protecting fair and open competition, and to competing in a fair and ethical manner.
We do not tolerate any violations of applicable rules relating to competition. We do not engage in or tolerate any violations of applicable rules, nor do we engage in any anti-competitive behaviour, such as price fixing, bid rigging, arket sharing or abuse of market power. There have been no legal actions pending or ompleted during the reporting period regarding anti-competitive behaviour or violations of monopoly/antitrust legislation in which the organisation has been dentified as a participant.
Freedom of association
Aker BP is a staunch supporter of employees’ rights to form and join trade unions, and equally their right to remain non-unionised.
Employees are informed of their trade union rights during onboarding and unions may market themselves freely. The unions have appointed full-time union leaders and Aker BP helps in administering their ayroll. The company communicates, consults and negotiates with employees and their trade unions on relevant matters such as reorganisations and the annual salary review. Norwegian Oil and Gas, where Aker BP is a member, has framework agreements in place with affiliated unions which ensure annual negotiations. Approximately 66 percent of Aker BP employees are covered by collective bargaining agreements in one of the following unions: Industri Energi, Tekna, Safe, Lederne or NITO. Subjects covered by collective bargaining can include HSSEQ, remuneration, ESG issues, working hours, training, career development, work time flexibility, life-long learning, stress management and equal opportunities.
Reporting of concerns
Aker BP’s Integrity Channel provides employees and contractors with a possibility to report concerns regarding compliance with applicable laws and/or ethical standards, we also welcome raising of concerns by external parties.
All reports are handled confidentially. In Aker BP, employees and consultants are encouraged to speak up about negative conditions in the workplace and seek advice if they are in doubt. They can report a concern to their line manager, a representative of senior management, the Compliance or Legal departments, other functional unit, or report anonymously via the company’s Integrity Channel. Aker BP has a strict non-retaliation policy for those who report concerns in good faith. Reporting a concern shall have no negative impact on the individual’s opportunities or professional development.
The Aker BP Integrity Channel is available to employees and external parties and is managed by an independent thirdparty, which guarantees the confidentiality of the reports. All documentation is stored in accordance with the relevant policies for data retention, data protection and data destruction. The mechanism for raising concerns is detailed in our Speaking Up Policy developed in compliance with the requirements for such reports in the Norwegian Working Environment Act and the EU Whistleblowing Directive. Procedure for Handling of Integrity Reports describes in detail the process through which concerns are investigated and documented. Both documents are available to employees and consultants in the Aker BP business management system and the revision period is two years.
In addition, “Speaking up posters” describing the key principles for speaking up in Aker BP, the routines for reporting and principles for handling reports are made available in English and Norwegian on the internal communication site and in the office landscape. The Compliance department, responsible for handling integrity reports, launched several awareness initiatives about speaking up in 2021, and will continue with internal awareness activities to ensure that employees feel safe to report potential violations of laws or the company’s Code of Conduct and other internal policies and procedures. Five whistleblowing cases were received via the Integrity Channel in 2021. Actions were taken to address the concerns raised and the reports are now closed.
Given the nature of the oil and gas industry, Aker BP is particularly affected by policies and framework conditions directly or indirectly related to energy production offshore Norway.
Aker BP thus recognises the value of engaging with public authorities and other stakeholders in relation to the development of various policy initiatives that impact our industry. We promote our views on issues of importance either through direct interaction with public authorities or through various industry associations. Aker BP engages directly with public authorities, including the Ministry of Petroleum and Energy, the Norwegian Petroleum Directorate, the Petroleum Safety Authority (PSA) Norway and the Norwegian Environment Agency (NEA). These interactions include separate, annual contact meetings with top management from each of the government bodies. Any presentation material reviewed at these contact meetings is sent to the respective government agencies and thus made public in public case registers. Norwegian Oil and Gas (NOROG) is Aker BP’s key network for reviewing and responding to relevant public issues related to framework conditions, regulations or other significant issues. Aker BP is represented on NOROG’s board as well as in various committees in the NOROG organisation. NOROG’s views on relevant policy issues are publicly available at www.norog.no. In addition to the engagement conducted by NOROG, Aker BP engages directly with elected political representatives in the Norwegian Parliament who are members of the Energy and Environment Committee. After the 2021 election, Aker BP conducted company presentation meetings with representatives from the political parties represented in the mentioned committee.
Aker BP proactively engages with the network of companies in Aker ASA’s portfolio. Aker ASA has a long tradition of Intro Approach Economic Environmental Social Disclosures Responsibility cooperation on employment matters between the main shareholder, management and union representatives, alongside an open dialogue with authorities and other partners. This is referred to as the “Aker model” and also describes the Aker BP’s way of collaborating. The Aker model is described in more detail in Aker ASA’s ESG-reports available on akerasa.com/en/esg Aker BP’s employees are in a position to exert formal influence on decisions, and four employee representatives serve on the board of Aker BP. Data on public affairs and lobbying is gathered from Aker BP’s Communication department. This unit covers all consolidated activities. Approximately 1,0 full-time equivalent (FTE) was dedicated to public affairs and public policy development in According to our Code of Conduct, Aker BP may not make financial contributions to political parties. We have no indications that such contributions took place in 2021.
Aker BP uses the annual submission of reports to authorities, audits performed by regulatory agencies and self-assessments to ensure environmental compliance.
The compliance checks in the self-assessment process consider both environmental aspects and regulatory requirements. Evaluation of environmental performance and compliance with legal laws and regulations for fields in operation, are monitored in our environmental accounting system and closely monitored and highlighted in dashboards and available for all personnel. We drive continuous improvement of the environmental performance by setting annual environmental targets even stricter than the legal limit for all operating fields. Annual HSE plans also include external environmental improvement activities and drive improved environmental performance. Discharges to sea from our operations and exploration activities are regulated by our discharge permits issued by the NEA. We annually report compliance status of our discharges and emissions to the authorities, for both operating fields and exploration drilling. Annual reports together with feedback on annual reports from the NEA also provide input to continuous improvement of environmental performance. Internal and external audits are subject to evaluation of compliance against external environmental permits/legislation. Aker BP holds field-specific permits under the European Union Emissions Trading System (EU ETS) and the annual third-party verification is detailed in the Environmental impact chapter, section on scope 1 emissions.
Compliance with laws and regulations
In February 2021, the Norwegian Discrimination Tribunal concluded that the company had retaliated against an employee in 2018 after said employee had reported on alleged gender discrimination earlier the same year. Compliance and Internal Audit investigated the case and ensured that necessary remediating measures were implemented.
In 2021, we had zero monetary fines of significant value, no non-monetary sanctions or cases brought through dispute resolution mechanisms related to environmental compliance.
During an inspection in September 2019, the NEA identified a discrepancy between two of Ivar Aasen’s reported seawater treatment chemical discharges and the field discharge permit. Following the inspection, we improved our systems for monitoring chemical usage and discharge across all Aker BP assets. NEA issued a new discharge permit for Ivar Aasen and the matter was closed. NEA reported the matter to the police in 2020.
In 2019, we also experienced an incident where the discharge permit for two water treatment chemicals on Alvheim was exceeded, which led to NEA conducting an inspection on the asset in 2020. By then, the matter had already been identified and handled by Aker BP. This was done as part of a full review on all assets to verify compliance with the respective discharge permits. Aker BP responded to the inspection report in April 2020 and the process was closed in June 2020. NEA reported this matter to the police in July 2020. In 2021 the police have finalised the investigation for both cases and handed them over to prosecution for resolution and potential penalty.