Chrysaor will conduct its operations in such a way as not to harm people and minimise any impact on the environment. Chrysaor is fully committed to continuously improving its health, safety and environmental performance by the successful implementation of this Policy.
Chrysaor consents 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 aspects of the company’s operations;
- Ensure all employees 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 Core 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.
Chrysaor seeks to create significant value for all its internal and external Stakeholders by building a market-leading North European exploration and production company focused on bringing incremental and dormant hydrocarbon reserves to market quickly and safely and operating our producing assets in a way we can be proud of.
- 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; and
- Foster pride in its work and demonstrate its Core 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.
Chrysaor is committed to maintaining the highest standards of integrity in the way it conducts business in the jurisdictions in which it operates. In order to maintain Chrysaor’s core business values of Integrity, Safety, Innovation and Passion; ensure a safe and sustainable business; and protect its reputation:
- Chrysaor will comply with all relevant laws in the jurisdictions in which it operates.
- Chrysaor will not tolerate any form of bribery, corruption, fraud, misconduct or wrongdoing in its business dealings.
- Chrysaor employees, officers, directors, contractors, agency workers, temporary workers, joint venture partners, service providers, suppliers, vendors, agents, intermediaries, advisors and consultants are strictly prohibited from offering, paying, soliciting or accepting bribes or any form of kickback, including facilitation payments, in any circumstances and in any jurisdiction that Chrysaor operates in.
- Chrysaor will not make contributions to political parties or politicians in any country. Chrysaor will only make charitable donations that are legal and ethical under local laws and practices.
Adherence to this policy is subject to regular review by the General Counsel, Chrysaor. Chrysaor Legal will provide appropriate training for all relevant Chrysaor personnel regarding this policy. General Counsel, Chrysaor has responsibility for the day-to-day implementation of this policy; this includes monitoring its suitability, adequacy and effectiveness and putting in place appropriate business processes and procedures to ensure compliance with this policy and with all applicable laws in the jurisdictions in which Chrysaor operates.
This policy applies to all Chrysaor business activity and to all Chrysaor employees, officers, directors, contractors, agency workers and temporary workers. Chrysaor joint venture partners, service providers, suppliers, vendors, agents, advisors, intermediaries and consultants are required to be aware of and act consistently with this policy.
3.0 REPORTING CONCERNS
Chrysaor is committed to maintaining a working environment and conducting its business in such a manner where concerns can be raised openly, are listened to and are promptly acted upon without fear of retaliation.
Any instances of wrongdoing (whether actual or suspected) relating to Chrysaor or its associates should be reported to the Chrysaor Compliance team through our dedicated email address (Chrysaor.Compliance@chrysaor.com) or through our external independent confidential SeeHearSpeakUp reporting service. The SeeHearSpeakUp service is available at any time of day by phone (UK - 0800 988 6818 or Norway - 800 15 838, email or via web portal.
Chrysaor does not tolerate retaliation in any form against any individual who speaks up in good faith, even if the concern is later determined to be factually incorrect or unfounded. Chrysaor treats all speaking up cases seriously and, when required, Chrysaor will initiate an investigation to determine the facts. Where Chrysaor consider it necessary, Chrysaor will inform the relevant authorities or law enforcement agencies.
Chief Executive Officer
30 January 2019
This Corporate Major Accident Prevention Policy (CMAPP) applies to all of Chrysaor’s offshore operated production installations in the UKCS. Chrysaor has no offshore operated production installations outside the EU.
Production Installations in the UKCS
This Policy applies to operations including those undertaken on the Armada Hub, North Everest and Lomond offshore installations. These UK assets are managed by the upstream business unit known as Chrysaor UK Operations, on behalf of the directors of Chrysaor Limited and Chrysaor North Sea Limited. For the purposes of this CMAPP,
Chrysaor Limited and Chrysaor North Sea Limited is referred to as “Chrysaor”.
The Chrysaor UK Operations organisation conducts the operated producing activities and provides advice and support to Chrysaor in respect of those companies’ offshore operated production assets in the UKCS. Further support, in relation to wells and pipeline activities associated with those offshore operated production installations in the UKCS is provided by the Chrysaor UK Operations organisation.
Whilst Chrysaor has delegated corporate authority to make certain decisions to personnel within the Chrysaor UK Operations organisation, the Boards of Chrysaor Limited and Chrysaor North Sea Limited retain ultimate responsibility for ensuring that this CMAPP is suitable, implemented and operating as intended.
Chrysaor recognises that the operation and activities associated with the offshore installations, wells and pipelines over which it has operational command and control have the potential to give rise to Major Accident Hazards and is committed to implementing robust controls to systematically identify, evaluate and manage these Major Accident Hazard risks during all phases of the asset lifecycle from design through to construction, operation and ultimately decommissioning, in line with our Business Principle of achieving no harm to people and protecting the natural environment.
1. Chrysaor will build and maintain a strong safety culture, which will ensure a high likelihood of safe operation and maintenance of plant, processes and equipment. This will include:
- Effective inductions to company core values and specific worksite hazards;
- Hazard Awareness Courses, including specific courses for Major Accident Hazards;
- Awareness of the Chrysaor Life Saving Rules;
- Encouragement of and rewarding the reporting of incidents and near misses; and
- Effective consultation with the workforce and their representatives on Major Accident Hazards.
2. Management of Major Accident Hazards will be reviewed by:
- Scheduled CEO and senior management reviews of the SEMS and the HSEQ performance of the business utilising published leading and lagging indicators;
- The provision of focussed performance data for the Boards, management and the workforce;
- Scheduled audits; and
- Incident and accident investigation and analysis.
The frequency of these audits will be of an appropriate extent and intensity commensurate with the associated risks. Significant findings will be escalated to the CEO and senior management and actions will be tracked to closure. The audit programme underpins continuous improvement in the control of Major Accident Hazards.
3. Chrysaor will encourage safe behaviour by recognising good safety performance through programmes such as:
- Intervention card recognition programme for both offshore and onshore;
- Programmes set out in company and asset annual HSEQ improvement plans to drive continuous improvement in safety performance; and
- Recognition and Reward through the company annual bonus award scheme.
Personal HSEQ performance and the support of others is a key consideration for promotion to supervisory roles.
4. Chrysaor’s HSEQ policies, procedures, capabilities and goals will be reviewed utilising both external and internal audits undertaken by competent personnel. This CMAPP will also be subject to monitoring arrangements to assure effectiveness and compliance with relevant statutory provisions, the objectives set out by this Policy and the BMS, including the mechanisms for investigating and taking corrective action in the case of incident or non-compliance to ensure that the CMAPP and Chrysaor’s culture and processes remain aligned. The procedures will cover the reporting of major accidents and near misses, particularly those involving failure of protective systems, and their investigation and follow-up including the sharing of any lessons learned.
5. Core to all of Chrysaor’s activities is safety and environmental protection. We will not operate if it is unsafe to do so or if there is a major threat to the environment. We will align our management systems to relevant national and international standards to ensure best practice.
6. Incidents will be investigated, root causes established, and actions taken to avoid repeats. Crisis management will involve members of Chrysaor’s leadership team.
7. Competency requirements of key roles performing safety and environmentally critical tasks will be assured by the Chrysaor competence assurance management system which details necessary training and experience and ensures compliance. Assurance processes are also established to confirm the competence of individuals engaged through contracting companies.
8. Chrysaor will identify all safety and environmental critical elements (SECEs) and ensure that they are maintained to the requisite level to complete their function and achieve desired reliability. They shall also be designed to survive any incident they are controlling/mitigating or fail in a state which achieves the desired objective. All SECEs will have performance standards with defined Functionality, Availability, Reliability, Survivability and Inter-dependence.
9. Major Accident Hazards (MAH) will be managed primarily through prevention. Asset Integrity will be ensured by a thorough risk-based inspection and maintenance programme.
10. Assurance of the health of the barriers in place to prevent or mitigate a MAE shall be carried out regularly. At no time will it be considered appropriate to continue operating if there are insufficient barriers to prevent or mitigate the consequences of a MAE.
11. Chrysaor will conduct periodic thorough reviews of all safety cases and supporting studies to ensure compliance with company standards and legislation relating to MAH management.
12. Chrysaor has a Safety Representative and whistle-blower scheme designed to encourage reporting in an anonymous and protected way. Tripartite discussions between the competent authority, Chrysaor and the workforce and their Safety Representatives will be held for any changes relating to the management of MAH, and Chrysaor will implement appropriate actions arising from such discussions.
13. All instrument data and alarms from the Distributed Control System are recorded and securely stored on an independently managed read-only logging system to facilitate objective post-event incident investigation.
14. Chrysaor understands that any weakness in Cyber Security control has the potential to impact MAH barriers. Chrysaor will identify which barriers may credibly be affected and reduce any impact to an acceptable level.
15. Chrysaor will maintain systems to prepare, test and review incident and crisis management plans to enable effective Command and Control of the consequences of any foreseeable MAE. The company and each installation utilises published Incident Response Plans and resources are made available to manage such incidents. All personnel, including senior management, with a role in the management of a MAE are trained and provided with scenario-based exercises to become competent and confident in their roles.
16. This policy will be reviewed as required and, as a minimum, at the annual HSEQ management review facilitated by an independent third party and attended by the Chrysaor CEO, HSEQ Director and Senior Management Team. The CEO has overall responsibility to ensure this CMAPP is suitable, implemented and operated as intended to drive continuous improvement. The CEO reports directly to the Board of Chrysaor Holdings Limited.
Chief Executive Officer
IntroductionChrysaor is the leading UK North Sea independent E&P Group with a portfolio of assets balancing:
- Near-term development with production growth; with
- Significant gearing to appraisal and exploration success.
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 ResidencyChrysaor 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 AuthoritiesOur activities are subject to a significant number of different taxes including:
- Corporation tax
- Supplementary charge
- Employment taxes
- Customs duties
- Stamp duties
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 PlanningWe 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 ManagementThe 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.
Chief Executive Officer