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Launching a new Code of Conduct

Operating responsibly is vital to our licence to operate and builds trust among stakeholders. Our new Code of Conduct is designed to enable all of us to make informed and ethical decisions, and to continue to raise the bar.

The challenge

The many jurisdictions in which we operate each have their own regulatory frameworks and compliance standards – ranging from basic safety laws, to stringent corporate responsibility protocols. As a mature global business operating in 49 countries, we are committed to applying the same high standards of ethics, integrity and transparency wherever we go. 

What we did

2017 was an important year in terms of how we uphold high standards of ethics and compliance. Having broadened the remit of the Compliance Committee to also cover Ethics, it has convened every few months and has effectively raised the bar by increasing the focus on ethical conduct issues.

We relaunched our Code of Conduct and made it available to all colleagues around the world in English, Spanish, Burmese, French, Portuguese, Estonian and Russian. The launch has progressed well across the company with all countries now complete.

To expand the messages to our diverse regional colleagues, we set up a network of Code Ambassadors. We also created an online ‘Speak Up’ channel and dedicated phone line so that employees can raise any ethical conduct issues and can do this anonymously if desired. We continue to build momentum around the importance of ethics and compliance for each of us at Puma Energy. This means tracking awareness of the Code of Conduct and how it is being applied in practice.


Our new Code is supporting colleagues in very different markets to make objective decisions. It makes our expectations of acceptable – and unacceptable – behaviour completely transparent. And, with approximately one Ambassador per country, as well as regional compliance officers in each of our four global hubs, we now offer an accessible point of contact. As well as Code Ambassadors, Speak Up is giving colleagues the reassurance that they can raise any concerns anonymously – and that trained investigators will rigorously review and act on any concerns raised.

Going forward we will launch the ‘Living Code’ – a version for smart devices that will include animations and videos to bring the Code to life and we will work closely with our human resources teams to further embed ethical conduct into recruitment and reward processes. We will continue to develop our ethics and compliance training offer for staff with a particular focus on our Code of Conduct and competition risk. Finally, we will remain vigilant to abide by all applicable sanctions as we expand into new jurisdictions and on growing concerns such as cybersecurity threats.

“By launching our new Code of Conduct, we are supporting staff through our ethical decision making model and strengthening our Speak Up culture. The code sets clear principles and values for our staff to follow and know the high standards the company expects.”

Andrew McClarron, Global Head of Compliance

We apply a robust global approach to managing risk, transparent reporting and high standards of ethics, integrity and governance.

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