Living by our principles
Our core values of honesty, integrity and respect for people underpin our work with employees, contractors, suppliers, non-governmental organisations and others.
The Shell General Business Principles describe our core values, our responsibilities and the principles and behaviours by which we do business.
Visit www.shell.com/about-us/our-values for more on our values.
In 2019, we continued working to ensure everyone at Shell complies with our global framework for data privacy compliance. We focused on our incident handling process to ensure that we can meet the 72-hour reporting requirement under the EU General Data Protection Regulation.
Our Ethics and Compliance Office updated and improved our data privacy training and simplified our approach to personal data risk assessments. We introduced a virtual assistant that responds to general ethics and compliance questions, including guiding employees to appropriate requirements for storing and deleting information.
As part of our renewed incident handling process we have put in place systems and controls to identify and address any data protection incidents which arise, including notifying appropriate regulators and people that are impacted, where required. We regularly review our incident handling process to ensure we further improve our approach.
In 2019, we built on our ethical leadership expectations programme, which was introduced in 2018 for all senior executives across Shell. The programme was designed to reinforce and explore the level of commitment to ethics and compliance in senior leaders. It supports the move in Shell to approach ethics as a topic of personal ownership rather than a matter of technical compliance. We launched an online toolkit to provide material and support for more than 1,000 leaders to set out ethical leadership expectations in team sessions. These sessions are designed to reinforce what Shell requires of leaders, focusing on values, behaviours, business pressures and leadership, with an emphasis on ensuring people feel comfortable speaking up.
Shell employees, contractors and any third party can report any potential breaches of the Code of Conduct confidentially and anonymously through several channels, including a global helpline, which is operated by an independent provider.
Shell has specialists who investigate concerns or allegations about a breach of our Code of Conduct. If a violation is confirmed, the relevant Shell company will take appropriate action up to and including a contract termination or dismissal. We maintain a stringent no retaliation policy to protect any person making an allegation in good faith.
Internal investigations confirmed 263 substantiated breaches of the Code of Conduct in 2019 compared with 370 in 2018. As a result, we dismissed or terminated the contracts of a total of 93 employees and contract staff, compared with 92 in 2018. Most Code of Conduct violations related to harassment, conflicts of interest and protection of assets.
Anti-bribery and corruption
There is no place for bribery or corruption at Shell. Shell has clear rules on anti-bribery and corruption that are included in our Code of Conduct and ethics and compliance manual. Both are available publicly online. Contractors and consultants are also required to act consistently with our Code of Conduct when acting on our behalf.
Various national and international laws prohibit business involvement with certain individuals, entities and organisations. Our anti-bribery and corruption, anti-money laundering and trade compliance programmes set out the requirements for screening business partners to comply with those laws and to ensure we understand who we do business with. Using a risk-based approach, we screen potential business partners before and during the contractual relationship. In 2019, we carried out 8,363 enhanced pre-screenings for higher-risk contracts. Additionally, around 3.5 million counterparties are screened on a continuous basis against a range of trade compliance, anti-bribery and corruption and anti-money laundering watch lists.
The court case regarding our investment in Nigerian oil block OPL 245 and the 2011 settlement of litigation pertaining to that block is currently ongoing in Milan, Italy. We are under investigation for the same matter in other jurisdictions (see Note 25 to the Consolidated Financial Statements in our Annual Report).