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Safeguarding integrity 4/15/2022

Maturing the Ethics Compliance function at PrimaLNG

The Ethics & Compliance (E&C) community of SHV Energy is committed to collaborating with colleagues, with the aim of designing the best solutions to the challenges we encounter. We believe our diverse backgrounds facilitate the analysis and approach from different angles and thus we obtain the most comprehensive response. We would like to share with you briefly how we have structured this sharing knowledge forum within the E&C Community.

Creation of multi-disciplinary groups

In 2021, the E&C community, formed by Compliance Officers from all business units, created a number of multi-disciplinary working groups, formed of people with diverse backgrounds, experiences, nationalities, and even time zones, to work together on the most relevant E&C topics such as competition law, anti-bribery and corruption, data privacy, trade compliance, reporting, and awareness, so that, together, we can contribute to continuously improving our own compliance programmes.

 

The benefits of collaboration

Each business unit has its own particularities, its own way of operating and a different business to run. However, if we focus on the similarities, we can identify many opportunities for collaboration, from joining efforts to determine the content of training to being inspired by how other business units generate awareness.

In addition, this idea of collaboration has also been replicated at SHV Holdings level, and several of the Compliance Officers who lead the working groups at SHV Energy are now in contact with E&C colleagues in other subsidiaries of the company. The collaboration has therefore become more significant and more extensive, which maximises its benefits.

 

An example of best practice sharing

The competition law working group prepared a train the trainers session to provide Compliance Officers with tools to carry out good formative sessions in their business units. These sessions were focused not only on expanding knowledge on the topic but also adapting our responses to current scenarios, especially now that many of our employees are frequently working from home.

In addition, Calor Ireland has a ‘dawn raid’ toolbox available in the office which contains the relevant manuals and instructions in case of receiving notice of an investigation, as well as the necessary material to record everything that happens. As this is a best practice, the toolbox will be replicated in other business units, including Primagas Spain.