The Seadrill Integrity Channel is operated and handled by an independent service provider, GAN Integrity (GAN). The Integrity Channel is a confidential tool for employees, consultants or contractors working for Seadrill, as well as third parties with whom Seadrill has business relationships, to report any concerns about possible unethical behaviour and/or illegal or unsound activities within Seadrill’s operations, its suppliers and/or joint venture-partners' operations.
Why do we have an Integrity Channel?
Seadrill values openness and transparency. Openness is the premise for trust and confidence. We are judged by whom we are and how we act: our reputation is upheld by how we put into practice our core values of safety conscious, accountability, inspirational, loyal and proactive. These values underpin The Seadrill Way of Working and The Seadrill Code of Conduct. We have established an Integrity Channel to allow employees and stakeholders to raise concerns and report instances of potential non-compliance with our values and principles.
What is an Integrity Channel?
The Integrity Channel enables Seadrill employees and others to raise concerns about improper activities or misconduct, in full confidence and without fear of retaliation. Improper activities may be:
- Bribery and corruption
- Financial misconduct
- Falsification of accounting records
- Improper payments
- Kick-back arrangements
- Money laundering
- Workplace health, safety or environmental violations
- Workplace harassment
- Failing to protect intellectual property
- Data protection breaches
- Insider trading
- Other violations of the Seadrill Code of Conduct
To raise a concern is beneficial to every single employee, the Company and to the society as a whole, because improper conditions can be corrected. There are a number of reasons for reporting your concern. Every employee has a duty to report their knowledge or suspicion of incidents or practices in breach of our Code of Conduct.
Who can use the Integrity Channel?
The Integrity Channel is for all employees in Seadrill and for third parties with whom Seadrill has a business relationship (customers, suppliers etc.). However, this method of reporting is not for customer services complaints or enquiries. Please contact your local Seadrill office for customer related issues.
How to raise a concern?
Seadrill has established a 24 hours a day, 365 days a year Integrity Channel. Reports through this channel are received on behalf of Seadrill by an independent third-party specialist, GAN.
There are two external ways to submit a report:
- Call the Integrity Channel via the phone number for your country.
The full list of phone numbers can be found at: https://seadrill.gan-compliance.com/p/integrityreport
Almost every number is freephone, and the report can be made in the caller’s preferred language.
- Visit the website: https://seadrill.gan-compliance.com/p/integrityreport, where you can complete and submit a report form.
GAN will handle all submissions with confidentiality. When raising a concern to GAN, you also have the option to remain anonymous. However, it will be easier to conduct an investigation, and other follow up activities will more likely be successful if the person reporting gives his/her identity.
Seadrill employees should also feel free to discuss any suspected violation or concern with their supervisor or any other member of Senior Management or Seadrill's Compliance Function.
What happens with the complaints received?
All complaints received will be taken seriously and will be handled in an appropriate manner. The identity of the person reporting will always be handled with confidentiality. GAN will summarise the reported concern and make an initial report to Seadrill.
You have three different options when you make a report:
- Remain completely anonymous to all parties
- Identify yourself to GAN, remaining anonymous to Seadrill
- You can provide your name and contact details
What happens to a report when received by Seadrill?
Your report, once processed by GAN, will be assigned to a member of Seadrill’s Compliance Function, to review and arrange for the concern to be investigated in an appropriate manner.
If the reported incident requires expertise not available within Seadrill, an outside expert may be involved. The investigation will focus on an objective, factual analysis of the case.
Within a reasonable period, the person raising a concern and reporting instances of potential non-compliance shall receive a reply.
For every reported instance, it is important to take into consideration the interests of the person who is the subject of the report. Seadrill gives priority to ensuring that each case is treated with fairness. In most cases, this means that the person is informed about the received concerns and is given the opportunity to respond.