BecomeaBetter CorporateCitizen
As a 'corporate citizen', DolphinEnergy has a responsibility tooperatewith transparency,
accountability and integrity, and to invest in creating shared value for the communities that
support its operations.
OperatingwithTransparency,
Accountability and Integrity
Global economic challenges, heightened
stakeholder expectations, and an
increasingly complex regulatory
environment demand that we conduct
our business at a high standard. Trust,
transparencyandaccountabilityare today's
expectations for companies, startingwith
Boardmembers and senior executives
and extending into the supply chain.
Transparency andAccountability
inGovernance
DolphinEnergywas createdby, and
is ultimately answerable to, its
shareholders, who act through aGeneral
Assembly thatmeets annually to review
and approve theBoard report, annual
company report, external auditors’
report, and the appointment of the
company’s external auditors.
TheBoardof Directors, comprising
representatives of DolphinEnergy’s three
shareholders, is the highest governing
body of the company. It appoints
executivemanagement, approves
the annual budget andbusiness plan
proposedbymanagement, and ensures
that the company actswith integrity.
Ninety per cent of theBoard is
independent of thecompany’soperations
(with the soleexceptionof theManaging
Director). You can find a list of our
current Boardmembers including
individual profiles onour website:
-
dolphin/board-members
TheBoardmeets at least twiceper year,
andDirectors are compensatedwith
a standard annual fee. TheBoard’s
primary focus is the company’s risk
management andoverall performance,
consistingof the company’s economic,
environmental, and social performance.
TheBoardhas four advisory committees:
the FinanceCommittee; theAudit,
Risk andComplianceCommittee, the
compensationcommitteeand theProject
ReviewCommittee, which reviews
HSE&S, technical, andoperational
aspectsof theDolphinGasProject.
DolphinEnergy has several mechanisms
to allow employees toprovide
recommendations to theBoard and
management. TheGeneral Manager’s
(GM) meetings, held inbothQatar and
theKuwait, invite employees topresent
questions and suggestions directly
to theGM. Employeesmay also
communicatewithmanagement at
theCEO-staffmeetings that are also
heldonce a year inboth countries.
For informationonDolphinEnergy’s
internal management structure, please
seeAppendixD.
Integrity at DolphinEnergy
DolphinEnergy’sCode of Business
Conduct (CBC) outlines policies and
procedures intended to ensure that
the company conducts itself in a legal
and ethical manner and avoids all
conflicts of interest. TheCBC is
approvedby theBoardof Directors, and
all employees are required to complete
an annual Professional Conduct
Declaration, confirming understanding
of their responsibilities. TheCompany’s
ComplianceOfficer assumes
responsibility for theCBC,monitoring its
implementationandemployeeadherence
toall policies, including thoseconcerning
staff communication and training.We
plan to implement online training and
certification for its annual CBCemployee
certification requirement in early 2014.
To ensure immediate and unimpeded
reportingof any violations of Dolphin
Energy’sCBC, an IntegrityHelpline and
email address allow employees to
disclose anymalpractice ormisconduct
without fear of reprisal. In2013, no
reportsof concernswere received via the
Helpline, email address, or othermeans.
TheCBC sets out clear policies to avoid
any formof bribery and conflicts of
interest. Inorder to safeguard the
integrity of the organization, Dolphin
Energy refuses to conduct businesswith
vendors or suppliers inwhichdirectors
or close familymembers of employees
have vested interests, or whichmay
award todirectors, employees, or
employee’s relatives, benefitswholly
or partially derived from thebusiness.
All vendors and contractorswith single
or cumulative commitments or potential
yearly businesswith the company
exceedingUS$50,000must receive
a copy of theCBC and acknowledge
compliance inwriting. Full compliance
with this policy is a conditionof entering
intobusinesswithDolphinEnergy, and
violationswill be regarded as amaterial
breachof agreement.
Therewere nobreaches of integrity by
contractors that led to terminationof
contracts, and all business unitswere
covered inour annual risk assessment,
which includes an analysis of corruption.
In 2013, DolphinEnergy finalized a
Corporate InvestigationPolicy toguide
investigations of alleged incidents
of corruptionor fraud and to ensure
integrityandaccountabilitywithin thecore
of the company’s governance. In2013,
no incidents of alleged corruption arose
across any corporate function, including
financial fines or non-financial sanctions.
TakingResponsibility
for our SupplyChain
Good corporate citizenship is not only
demonstratedbycommunity investment
and integrity inour operations, but also
lies inour responsibility toensure that the
companiesweworkwith adhere to the
same high levels of quality, health, safety
andenvironmental excellence thatwedo.
DolphinEnergy has a comprehensive
system inplace inorder to ensure that
its contractorsmaintain its standards for
Health, Safety, Environment andSecurity
(HSE&S). Tobeginwith, all applicants
interested inbidding for aProjectscontract
or any tender valuedaboveUSD$1million
must complete apre-qualification
questionnaire, answeringquestions
on their approach to the following:
• HSE&S leadership
• subcontractormanagement
• hazards andeffectsmanagement
• planning andprocedures
• implementation and
performancemonitoring
• incident reporting and investigation
• auditing and review
• emergencymanagement and response
DolphinEnergy
SustainabilityReport 2013
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