Case study: How Noble combats corruption

What are the material issues the company has identified?

In its 2018 Sustainability Report Noble identified a range of material issues, such as product quality, supply chain management, talent attraction, human rights, employee training and development. Among these, combatting corruption stands out as a key material issue for Noble.

Stakeholder engagement in accordance with the GRI Standards              

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The reporting organization shall identify its stakeholders, and explain how it has responded to their reasonable expectations and interests.”

Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups Noble engages with:

How stakeholder engagement was made to identify material issues

To identify and prioritise material topics Noble developed surveys to collect feedback from Noble’s senior functional managers, key customers, analysts and investors on the relative importance of different sustainability topics.

What actions were taken by Noble to combat corruption?

In its 2018 Sustainability Report Noble reports that it took the following actions for combatting corruption:

• Implementing a Code of Conduct
• Noble’s Code of Conduct sets out compliance requirements and guidelines on key ethical issues. The Code of Conduct imposes specific obligations regarding anti-corruption, anti-trust, anti-money laundering, combating financial crimes, counter financing of terrorism, sanctions and fraud. Every employee must acknowledge that they have read and understood Noble’s Code of Conduct and policies, as part of their induction and on an ongoing basis. Regular refresher training is organised, to maintain the effectiveness of compliance programmes and highlight some of the perception gaps and possible “grey areas”. Specific rules on securities trading when in possession of internal, confidential information are also circulated among employees and set out in a separate policy. This includes a procedure for the good faith reporting of any infringement of the Code of Conduct or other Noble policy. Concerned employees are encouraged to report without fear to the Compliance or Legal departments, when any suspicions arise.

• Promoting compliance
• Noble regularly reviews its policies and procedures to adapt to the changing regulatory landscape and, taking into account these developments, industry guidance, customer experience and societal expectations, implements internal controls that safeguard its operations against regulatory and reputational risk. Noble’s experienced Compliance Team is dedicated to making sure that its business conforms to applicable laws and regulations. Compliance Team personnel are based in Noble’s trading offices, and serve as a valuable resource for providing technical assistance and training in the regulatory sphere. Before entering into any contracts with new counterparties, Noble undertakes a World-Check risk search as a key component of its mandatory risk screening. Additionally, Noble employees worldwide are given explicit guidance on ethical business practices, such as conflicts of interest, entertainment and gifts.

• Applying a whistle-blowing policy
• Noble has adopted and implements a whistle-blowing policy through which employees may, in confidence, raise concerns regarding matters not only about workplace misconducts, but also any unlawful activities, policies or practices, suspected fraud, corruption, dishonest practices or other similar matters. There are also arrangements for an independent investigation of such issues and for appropriate follow up actions where necessary. During the reporting period, Noble had no confirmed cases of corruption in its operations.

• Providing ongoing training
• Noble’s corporate policies are reviewed and updated on a regular basis, while training on business ethics and conduct is regularly carried out in Noble’s offices, to reinforce the procedures for reporting potential violations. All relevant staff are given regular updates on rules and regulations relevant to their particular markets and jurisdictions, and important notifications are communicated via compliance emails to employees globally. Education and refresher trainings on compliance, financial crime, anti-bribery and anti-money laundering (AML) are delivered via e-learning programmes and classroom sessions. In 2017, 85 employees across Asia attended face to face training. Among these, around 10% of attendees were management level staff. This programme caters to the different needs of different business functions. For example, front office members receive training on financial crimes, bribery acts and market abuse, which is less relevant in other business areas. Other training includes regulations related to illegal conduct and references on anti-corruption laws and published cases.

Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?

The GRI Standards addressed in this case are:

1) Disclosure 205-2 Communication and training about anti-corruption policies and procedures

2) Disclosure 205-3 Confirmed incidents of corruption and actions taken

Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:

• Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
• Business theme: Anti-corruption

 Disclosure 205-3 Confirmed incidents of corruption and actions taken corresponds to:

• Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
• Business theme: Anti-corruption

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References:

1) This case study is based on published information by Noble, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:

http://database.globalreporting.org/

2) https://www.globalreporting.org/standards/gri-standards-download-center/

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