Petro-Canada’s commitment to integrity and ethics is the foundation for our Code of Business Conduct and the other Company policies that reinforce it. We set high standards for ethical conduct and compliance, consistent with laws and regulations for our employees. We expect those with whom we do business to act in a manner consistent with our standards.
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Code of Business Conduct
The Code of Business Conduct (the Code) sets out the basic rules, standards and behaviours that allow Petro-Canada to maintain the confidence of our customers, colleagues, shareholders, vendors, and the communities and governments where we do business globally. The Code affirms the basic requirements for our business and the general behaviour expected of employees. It provides practical advice about how to proceed or act in a particular situation.
Every director and employee of Petro-Canada must understand and follow the Code of Business Conduct. Compliance with the terms of the Code is a requirement of office or employment with Petro-Canada, and a failure to do so may result in serious consequences, including termination of employment with Petro-Canada. Contract staff must also comply with the Code. Contractors or consultants who are acting as Petro-Canada’s agents, or are working on the Company’s behalf or in its name through outsourcing of services, processes or any business activity, are required to act consistently with the Code when acting on behalf of Petro-Canada.
The Code was updated in early 2008 to incorporate more current ethical issues. It is based on our Principles for Responsible Investment and Operations and provides guidance on broader ethical issues such as gifts, entertainment, conflicts of interest, intellectual property, use of Company assets, accounting and financial reporting, health, safety and the environment. The Code also outlines our commitment to comply with applicable legislation on such issues as bribery, corruption, privacy and competitive practices. We let people know where to get more detailed information on legal compliance and who to contact with questions.
Annually, officers of the Company sign an assertion that they have communicated the Code to employees and are not aware of any breaches of the Code. Each employee and all contract personnel are required to read and undertake to comply with our Code when they join the Company. Every two years, all employees and contracted employees are required to repeat this process. In late 2008, an interactive, web-based training module was developed and delivered to all employees and contract employees to strengthen their understanding of the Code. As at year end, the training had been completed by 4,419 employees and 408 contract personnel, with a target to complete training for all employees and contractors by mid-2009.
Policy for the Prevention of Improper Payments (PPIP)
Corruption is an obstacle to sustainable economic activity; it hinders the development of fair market structures and distorts competition. More importantly, participation in corrupt business practices undermines citizens’ trust in the political and business system, in its institutions and in its leadership. As a good corporate citizen, Petro-Canada strives to act transparently and in the best interests of the communities where we operate.
Petro-Canada’s position on bribery and corruption is clear. No employee, agent or contractor of Petro-Canada must ever offer or accept a bribe. More specifically, the direct or indirect offer, payment, soliciting or acceptance of bribes in any form (including a kickback, facilitating payment or favour) is unacceptable and contrary to Petro-Canada’s Policy for the Prevention of Improper Payments (PPIP), as well as applicable local and foreign laws.
The ethical and legal requirements in these situations are complex and to help employees understand their obligations relating to the PPIP and similar legislation, the Company's chief compliance officer held group workshop style training throughout 2008 for more than 400 employees, contractors and agents in higher risk areas in both our international operations and some Canadian operations throughout 2008. During 2009, web-based training will be deployed to designated employees and contract personnel. Also during 2009, we will conduct an internal audit on the processed and controls in place related to the Policy for the Prevention of Improper Payments. The results of the audit will serve to prioritize our efforts to strengthen our compliance program.
Privacy
Petro-Canada collects, uses and stores personal information about its employees, contractors, customers, suppliers, associates and others in the course of its business activities. This collection, use and disclosure of personal information is subject to provincial, federal and international laws. We respect the privacy rights of all individuals, and have adopted policies, procedures and practices to protect those rights.
At hiring, each new employee or contract employee is required to take a basic web-based orientation to ensure they understand their role in protecting privacy. Awareness training is repeated every two years and for those employees in higher risk roles, workshop in-depth training is provided. In 2008 we also strengthened our process to assess the adequacy of the privacy controls in our business processes.
Competitive Practices
Petro-Canada does not engage in anti-competitive activities. We compete for business vigorously, honestly and in compliance with all applicable antitrust and competition laws. These laws are designed to encourage fair competition in the marketplace for products and services.
In 2009, we will continue to deliver workshop-style training to help business areas understand the implications of this legislation to their businesses and develop mitigation plans to address them. Recently, changes were announced to the Competition Act that may affect our business practices. During 2009, we will review and appropriately revise our competition law compliance program in light of the Bill C-10 amendments.
Transparency
Open, honest and transparent relationships support sound corporate governance and high ethical standards. Within the bounds of commercial confidentiality, we commit to transparent relationships with employees, shareholders and stakeholders alike. We encourage transparent transactions and operating agreements with provisions that respect the local laws, wherever we operate around the world.
Many of our investments and projects are long term in nature and we expect to be a corporate citizen in the communities where they are located for many years. We have a clear interest in the social and economic development of the regions and countries where we work. We prefer to invest and work in countries that are tackling corruption, promote good governance and the rule of law, and that are concerned about the health, education and well-being of all of their people.
As such, we support public accountability by governments and the transparency of revenues as a means to promoting political and economic stability in the regions in which we operate. We acknowledge the work that the Extractive Industries Transparency Initiative does in this regard and, while we have not formally endorsed the initiative, if requested, we will support host countries seeking to implement greater transparency.