Chrysaor Policies

 

Chrysaor will conduct its operations in such a way as not to harm people and minimise the impact on the environment. Chrysaor is fully committed to continuously improve its health, safety and environmental performance by the successful implementation of this policy.

Chrysaor commits it will:

  • Ensure compliance with all applicable legislation and standards;
  • Ensure an  effective  management  organisation is in place and all personnel and contractors are aware of their health, safety and environmental responsibilities;
  • Create a safe and healthy working environment for our employees, contractors and all other persons who could be affected  by its activities;
  • Identify, evaluate and control the risks and impacts associated with its activities, including where the potential exists for major accident events;
  • Ensure that energy and resource management are an integral part of the business;
  • Promote resource and energy conservation, waste minimisation and pollution prevention;
  • Recognise and respond to employee and community concerns regarding the health, safety and environmental aspect of the company's operations;
  • Ensure all employee and contractors are competent to perform their health, safety and environmental roles; and
  • Achieve continuous improvement of its business processes through the implementation of its Values and Business Principles.

Chrysaor will ensure that the necessary resources are provided to fully support this Policy and will ensure that it is subject to audit and review as part of the Management System goal of continuous improvement in performance.

Phil Kirk
Chief Executive

January 2017

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Chrysaor seeks to create significant value for all its internal and external Stakeholders by building a UK based business focused on bringing incremental and dormant hydrocarbon reserves to market quickly and safely, and operating our product assets in a way we can be proud of.

Chrysaor will:

  • Demonstrate management commitment to quality in its projects and operations;
  • Establish and review quality objectives and implement quality plans to meet these objectives;
  • Ensure  an  effective  management  organisation  is  in  place  and all  personnel  and contractors are aware of the Company’s quality expectations;
  • Foster pride in its work and demonstrate its Values and Business Principles in its output.

Chrysaor is fully committed to continuously improving its corporate performance by the successful implementation of this policy and will ensure that the necessary resources are provided to support it.

 

Phil Kirk
Chief Executive
January 2017

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Our Approach

The highest standards of integrity are fundamental to the way Chrysaor conducts business. As part of this commitment, Chrysaor will not tolerate any form of bribery or corruption in our business. Compliance with anti-bribery and anti-corruption laws, in particular the UK Bribery Act, and understanding those laws and the ethical standards required of all of us is essential.

Who does it apply to?

All individuals working for Chrysaor at all levels, including those acting for or on Chrysaor’s behalf, are strictly prohibited from offering, paying, soliciting or accepting bribes or any form of kickback, including facilitation payments.

What happens if I don’t comply?

Given the serious nature of a breach, an individual’s failure to comply with this policy, whether intentionally or by an act of negligence, may lead to disciplinary action being taken that could ultimately result in termination of employment or engagement.

What is bribery?

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

Offering and agreeing to accept a bribe is still a bribe and it doesn’t matter if the bribe is ultimately not paid. Some typical examples of bribery include:

  • you offer a person tickets to a major sporting event, but only hand over the tickets if that person agrees to do business with you;
  • cash payments by employees to third parties such as consortium members, introducers or consultants;
  • loan guarantees or other extensions of credit providing a subcontract to a person connected to someone involved in awarding the main contract;
  • political or charitable donations made to a third party linked to, or at the request of, someone with whom Chrysaor does business; or
  • a contracted project manager makes a payment to someone in order to expedite the work of the project.

What are facilitation payments?

Chrysaor does not make, and will not accept, facilitation payments of any kind, or in any circumstances. Although these are not commonly paid in the UK, we uphold the prohibition of the making and receiving of such payments wherever we operate.

Does this policy apply to third parties?

We require that third parties, including contractors, who have a contractual or other business relationship with Chrysaor to adhere to this Policy.

In addition, Chrysaor requires that due diligence should be conducted on such third parties, using a risk-based approach having regard to, among other things, the work being undertaken, the location of that third party’s business and any history of non-compliance or bribery with respect to that third party.

What is the policy with regards to donations?

We do not make contributions to political parties or politicians in any country. We only make charitable donations that are legal and ethical under local laws and practices. No donation should be made, under any circumstances, without the prior approval of the Chief Executive Officer.

What are my responsibilities?

Every Chrysaor employee is responsible for compliance with this policy. You must ensure that you read, understand and comply with this policy at all times.

Who monitors adherence to the policy?

Adherence to the policy will be subject to regular review by the General Counsel. Chrysaor will also provide appropriate training for relevant employees regarding this policy and general compliance with anti-bribery obligations.

The General Counsel has responsibility for the day-to-day implementation of this policy, monitoring its suitability, adequacy and effectiveness.

How do I report an issue?

All Chrysaor employees are required to assist in tackling fraud, corruption and other malpractice within the organisation. If you are aware of, or suspect that bribery may be taking place within Chrysaor, you should report your suspicions to an appropriate person. If you are in doubt that your concerns have been or will be dealt with properly, you should raise the matter directly with any Executive Director or the General Counsel.

What will be the consequences of reporting?

If you genuinely believe that there is some form of malpractice occurring and raise a concern in good faith and without malicious intent, Chrysaor will ensure that you do not suffer any disadvantage in the workplace as a result of speaking up, whatever the outcome of the investigation.

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Introduction

Chrysaor is the leading UK North Sea independent E&P Group with a portfolio of assets balancing:

  • production,
  • near-term development with production growth, with
  • significant gearing to appraisal and exploration success.

We aim to generate superior equity returns by developing and commercialising incremental oil and gas resources in a safe and responsible manner.

Chrysaor’s core values are integrity, passion, innovation and safety.   Our approach to tax is fully aligned with Chrysaor’s core values and business principles, which are published in full on our website.
In making this strategy available, Chrysaor is fulfilling its responsibilities under Schedule 19 of the Finance Act 2016.

Tax Residency

Chrysaor Holdings Limited (the holding company of the Chrysaor Group) was incorporated in the Cayman Islands in 2007 to facilitate US inward investment and increase flexibility around dividend distribution. However, it is and has always been tax resident in the UK and has not sought nor obtained any UK tax advantage by virtue of being incorporated in the Cayman Islands. All the subsidiary companies in the Chrysaor Group are incorporated in the UK and are also all tax resident in the UK.

Interaction with Tax Authorities

Our activities are subject to a significant number of different taxes including:

  • corporation tax
  • supplementary charge
  • employment taxes
  • customs duties
  • stamp duties
  • VAT

We aim for an open and constructive relationship with HM Revenue & Customs and stakeholders so that we can comply with both the letter and the spirit of the applicable tax laws and regulations.

We also engage with both HM Treasury and HM Revenue & Customs on the development and interpretation of tax laws through the various trade associations of which we are a member.

Tax Planning

We arrange our tax processes to ensure that we comply with the relevant tax laws and we pay all taxes as they arise. At the same time, we engage in efficient tax planning to support the commercial and economic goals of our various investments.

In so doing, we regularly seek external tax advice prior to making use of the various tax concessions, exemptions, incentives and reliefs that are made available by the tax authorities.

Tax Risk Management

The Chrysaor Board of Directors retains ultimate responsibility for the Group’s tax-related policies, practices, procedures and principles and, within this, the Chief Executive and Chief Financial Officer have accountability to them for the management of the business’ tax risks. In addition, where appropriate, the Board uses independent third-party professional advisors to monitor, check and confirm the tax-related aspects of all plans and proposals presented to them.

The management of tax risks forms part of our overall internal control framework with potential weaknesses being identified, assessed and managed on an ongoing basis. Where appropriate, this will include the use of external third-party professional advisers to ensure that we correctly consider the facts, risks and conclusions in support of our decision-making processes. The following considerations are key within our management of tax risk:

  • Our core values and business principles;
  • Our reputation with our stakeholders including the tax authorities, the industry as a whole, and our employees;
  • The legal and fiduciary duties of our directors and officers; and
  • Our reported post-tax results, cashflow and the associated generation of equity returns.

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