Frequently Asked Questions

Reporting a Concern

How can I report a concern using the Speak Up Hotline?

By clicking on Report via the Internet using a Web Intake form or by clicking on Call to place a call using the telephone. When submitting the report, you will be asked to choose a password then you will be provided with a report key after you submit it. You can return to the portal at any time by Internet or telephone to follow up or add more details or answer questions posed by the authorized system administrator or the case investigator. In case you chose anonymity, we strongly encourage you to return to the portal on regular basis to follow up on your report and to answer company questions. You and the company now would have entered into an “anonymous dialogue”.

What happens after I raise a concern?

The Group Investigations Team (GIT) formed by the Investigations Director and the Chief Compliance Officer is notified of all concerns raised on the portal or via a call. The GIT will assess the concern to determine whether the concern is investigable or not and who is the right function to investigate. If the Speak Up is not investigable, further information should be sought from the person raising the concern before closing the Speak Up.

In the event the investigation is investigable, GIT or the relevant function will investigate in an objective timely and thorough manner. We encourage you to regularly check on the status of the investigation by clicking the Follow-Up link on the Speak Up portal.

What type of concerns should I report?

Any concerns related to a potential violation of Petrofac’s Code of Conduct, Petrofac’s Policies, Standards and Procedures or relevant applicable laws. It is advisable for the reporters to be specific about the concerns they raise in the report. In the absence of additional information provided by the reporter, concerns that are vague and general in nature, might not always be investigable.

If I have a concern, shouldn't I just report it to my manager, security, or human resources and let them deal with it?

Ideally yes. The first point of contact should be your line manager or supervisor or other member of the management team or Legal, Finance, Human Resources or Petrofac’s Chief Compliance Officer. However, if you are not comfortable reporting the concern in that manner, the Speak Up Hotline will provide you with a safe and confidential alternative for reporting the concern.

I am not sure if what I have observed or heard is a violation of company policy, or involves unethical conduct, but it just does not look right to me. What should I do?

Ask HR, Legal or Compliance or Report it here. We would encourage you to report a situation that turns out to be harmless, rather than let possible unethical behavior go unchecked because you were not sure. Reporting in good faith will not subject you to retaliation even if the allegations were not substantiated.

Why should I report what I know?

Because we all have the right to work in a positive environment and because employees are required to report breaches of the Code as per their employment contracts and, if required, to also cooperate with investigations into alleged breaches of the Code.

No Retaliation, Confidentiality & Security

Will I face retaliation for reporting a concern through the Hotline?

The short answer is NO. As stated in Petrofac’s Code of Conduct, Petrofac strictly forbids retaliation against employees for submitting a compliance concern whether the underlying facts proved to be correct or not or resulted in any corrective actions. If you believe you have been subjected to retaliation for your having reported your concern, please report it to the Chief Compliance Officer or through the Speak Up Portal so that the company may take appropriate actions after investigating. In the event retaliation is substantiated, disciplinary actions will be taken in accordance with Petrofac’s relevant consequence management matrices. However, employees who knowingly provide false or misleading information to the company may be subject to disciplinary actions.

Does management really want me to report a concern?

Yes. Management does. In fact, we need you to report. You know what is going on in our company - both good and bad. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the company and our people.

It is my understanding that any report I send from a company computer generates a server log that shows every website that my PC connects with, and won’t this log identify me as a report originator?

No, it will not. EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available. In fact, EthicsPoint is contractually committed not to pursue a reporter’s identity.

Can I file a report from home and remain anonymous?

Yes. If you chose to remain anonymous, any report whether from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is totally maintained. Plus, EthicsPoint is contractually committed not to pursue a reporter’s identity.

I am concerned that the information I provide to EthicsPoint will ultimately reveal my identity. How can you assure me that will not happen?

The EthicsPoint system is designed to protect your anonymity. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that the body of the report does not reveal your identity by accident.

Is the telephone toll-free hotline confidential and anonymous too?

Yes. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into the EthicsPoint Website. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

You can do that. There is a section in the report for identifying yourself if you wish.

Who receives the report after I submit it?

Reports are entered directly on the EthicsPoint secured server to prevent any possible breach in security. These reports are available on a need to know basis and only to specific individuals, compliance officers, legal counsels or investigators within the company who are authorized to receive and assess the reports.

Are the follow-ups on reports as secure as the initial report?

Yes. All Speak Up correspondence is held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.

Miscellaneous

Can I still file a report if I do not have access to the Internet?

Not on the Internet. If you do not have access to the Internet or are uncomfortable using a computer, you can call the EthicsPoint toll-free hotline, which is available 24 hours a day, 7 days a week, 365 days a year.

What is EthicsPoint and who is NAVEX? How do they relate to the Petrofac Speak Up Hotline?

EthicsPoint is a third-party company providing a comprehensive and confidential reporting tool to Petrofac employees, which we call the Speak Up Hotline. The Speak Up Hotline also referred to as the Petrofac Speak Up system is managed by NAVEX to assist management and employees in working together to address fraud, abuse, and other misconduct in the workplace, all while cultivating a safe and positive work environment.