We have built our reputation as an organization that requires ethical business practices and high levels of integrity in all of our business transactions. Oceaneering’s Core Values underlie our Code of Business Conduct and Ethics and related policies and procedures (collectively, our “Code of Conduct”), which guide our employees and business associates on a daily basis.
In addition, Oceaneering recognizes that the strength of its reputation is based not only on our own conduct, but also on the behavior of those with whom we do business. As such, it is our goal to ensure that our relationship with suppliers reflects and supports the same high ethical standards. We are committed to work with our partners to promote responsible practices in general and throughout our supply chain around the world. Our intent is to ensure that all our partners acknowledge our values and share our commitment to conduct business in an ethical, legal, and socially responsible manner.
We Want to Hear From You
If you have any compliance or ethics concerns regarding our Code of Business Conduct, accounting controls, auditing matters, or any other concerns, we want to hear from you. All concerns and complaints will be reported and assigned to appropriate parties for review. Ultimately, adherence to our Core Values and compliance with our Code of Business Conduct are overseen by Oceaneering’s Board of Directors and its committees.
CODE OF CONDUCT
Our Code of Business Conduct and Ethics, Anti-Corruption Compliance Policy, and Code of Ethics for the Chief Executive Officer and Senior Financial Officers reiterate Oceaneering’s commitment to integrity and ethical standards and clearly convey to all employees and related third parties how our Code of Conduct pertains to business relationships with us.
We are committed to work with our partners to promote responsible practices in general and throughout our supply chain around the world. Our intent is to ensure that all our employees and partners acknowledge our values and share our commitment to conduct business in an ethical, legal and socially responsible manner. We strive to continually improve within the areas of human rights, labor standards, and the environment and to work against any form of corruption.
The Oceaneering Compliance Program has been designed in accordance with world-class best practices including:
- the OECD’s 13 Good Practices on Internal Controls, Ethics, and Compliance;
- the United States Sentencing Guidelines’ 7 Elements of an Effective Compliance Program;
- the Department of Justice’s Resource Guide to the U.S. Foreign Corrupt Practices Act;
- the United Kingdom Bribery Act 2010; and the
- the Ministry of Justice’s Guidance on the United Kingdom Bribery Act.
ANTI-CORRUPTION COMPLIANCE POLICY
Oceaneering has zero tolerance of corruption or bribery in any form. Oceaneering policy and laws such as the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, and similar anti-corruption laws around the world prohibit our employees or our agents from giving or offering to give money or anything of value, directly or indirectly, to anyone to induce that person to affect any governmental act or decision, or to assist Oceaneering in obtaining or retaining business or securing any improper advantage. This prohibition applies to all customers, whether government-owned or controlled or privately held, and to all government officials regardless of rank and duty.
Oceaneering suppliers may not act in any way, in their business relationship with Oceaneering or otherwise, that violates this principle. Additionally, Oceaneering suppliers must only themselves use suppliers that do not violate ethical standards through bribes, kickbacks, or other similar improper or unlawful payments. Suppliers must maintain awareness and comply with all applicable bribery and corruption laws and regulations of the countries of their operation.
HUMAN RIGHTS PROGRAM
Slavery and human trafficking is a serious concern. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Code of Conduct reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
CONFLICT MINERALS PROGRAM
Oceaneering has adopted a policy of supporting industry efforts toward conflict-free supply chains and complying with related reporting requirements imposed on the company by applicable law. We expect our suppliers to support us in these endeavors.
Oceaneering suppliers should responsibly source materials used in their products and services. Suppliers must implement supply chain due diligence policies and take affirmative measures to determine if proceeds from the mining, trading, transportation, smelting or refining of any ores, minerals or derivatives are used to benefit or fund individuals or groups engaged in violence or human rights abuses. When suppliers become aware that these materials are in their supply chain, they must find alternative sources.
Annual Form SD Filings
Oceaneering responsibly complies with tax laws and aims at full transparency towards tax authorities. All taxes and charges are paid in accordance with relevant domestic laws and regulations in the countries where we operate. As a good corporate citizen, we believe that tax policy is an important part of building a strong global economy and infrastructure system that can benefit all stakeholders and the communities we share.
GENDER PAY GAP REPORTING
The Gender Pay Gap Reporting regulations cover UK companies with 250 or more employees as of 5 April 2018. As one such organization, we are required to publicly report gender pay gap metrics, with the aim of eliminating the gender pay gap. In the Oceaneering group, Oceaneering International Services Limited (“OISL”) is required to publish its gender pay gap metrics. Pay gap calculations are based on the OISL workforce as of 5 April 2018.