statement of business principles 2017 - nigeria lngnlng.com/business-with-nlng/shared...

S ta tement o f Bus iness PRINCIPLES & ETHICS

Nigeria LNG Limited (NLNG) is a private joint venture company registered in Nigeria and formed by its shareholders to be a global LNG Company, helping to build a better Nigeria.

Our mission is to market, produce and deliver LNG and NGLs to customers safely, rel ably and profitably, to grow the bus ness and its people to their full potential and to be a trusted partner with all stakeholders n the sustainable development of Nigeria's gas ndustry and of NLNG's host communities

Our shared values of ntegrity teamwork excellence and caring for peop e underpin all the work we do and are the foundation of our Business Princip es.

NLNG ins sts on honesty, integr ty and fairness in a aspects of our business and expects the same in our relationships with all those with whom we do business.We comply with all applicab e aws and regulations of the Federal Republic of Nigeria and the countries n which we operate

In our interactions with employees, bus ness partners, communities and stakeho ders, we seek to listen and respond to them honestly and responsibly.

As part of our Business Principles, we commit to contribute to sustainable development. This requires balancing short and long-term interests, integrating economic env onmental and social considerations nto bus ness decis on-making.

Our Business Principles apply to all our activities large and small, and d scrib s the behaviour xpected of directors, emp oyees, subs diaries agents, intermediaries consultants joint venture or other business partners and any other persons, organ zations or bodies doing business with NLNG or any of its subsidiaries.

We demand that our directors, officers and emp oyees adhere to the highest egal and eth cal standards to ensure and reinforce NLNG's status as a responsible corporate c tizen and to maintain the utmost confidence of our stakeholders.

In NLNG we recogn se the importance of matching our words with action. Consequent y, the applicat on of our Business Princip es & Ethics is underpinned by policies and procedures which are designed to ensure that those who work for us understand these principles and that they act in accordance with them.We also recognise that maintaining the trust and confidence of customers, shareholders, emp oyees, contractors, suppliers and business partners as well as society and the community in which we work, is vital to our success. In NLNG, we intend to earn th s trust by conducting ourselves according to our Business princip es and Ethics.

As part of our compliance system, we provide employees and stakeholders with safe and confidential channe s to raise concerns and report instances of non-compliance.It is the responsib ty of NLNG employees and stakeholders to report suspected breaches of the Business Principles and Ethics to NLNG using our Comp ance Hotl ne.

NLNG's operat ons must comp y with all applicable laws rules and regulations, as well as this Statement of Bus ness Princip es and the policies and procedures that support them Act ons contrary to the Statement of Business Pr nciples are harmful to our Company and ts reputation. Violations of our Business Princip es will result n sanctions.It is the responsibility of the management of NLNG to ensure that company stakeho ders are aware of these principles and those who work for us behave in accordance with this Statement.

,

ii i

i .

i , , respect, l , l

i i ll

l l i.

i l

, ir i i i

, e e el i , , , ,

i

l ii

i l il

l

i

ilili

i l , il . i i

i il

l

l

l

i

l

Tony AttahManaging Director / Chief Executive OfficerSeptember 2017

NLNG VENDOR CONSEQUENCE MANAGEMENT MATRIX

S/N Type of Breach Description Applicable Sanction Duration

1 Poor Performance

Persistent underperformance or failure to deliver as per

specified terms and conditions with respect to quality,

delivery and warranty.

(i) Put Vendor On Hold pending investigation based

on poor performance or breach. 3 Months

(ii) If outcome of investigation shows vendor

negligence, vendor will be counselled to improve

performance and placed on Probation.

6 Months

(iii) Subsequently, if performance remains

consistently poor, vendor shall be placed on

Suspension.

1 Year

2 Commercial Bid withdrawal at

Award stage

Withdrawing from contract pre award due to inability to

meet commitments at bid price. Suspension# 1 Year

3 Withdrawal from Contract Withdrawing from contract post award for any reasons

deemed within contractors’ control or expected risk. Suspension## 3 years

4 Breach of Ethical Standards

* Bribery & Corruption in order to obtain commercial

advantage

* Anti-competitive arrangements with competitors.

* Restrictive arrangements with customers or resellers.

* Market abuse, Regulatory disclosure & Insider Trading

* Falsification/forgery of records and documents e.g.

financial reports, tax documents etc.

* Undeclared conflicts of interest.

* Fraud or proven intention to defraud NLNG.

* False allegations against NLNG, especially in

connection with the evaluation of bids and award of

contracts.

De-list vendor from NLNG Vendor database Permanently



5 Breach of Obligations

* Willful delivery of sub-standard critical materials.

* Failing to preserve, secure and protect the

physical, financial and intellectual assets of NLNG,

against the waste, loss, damage, misuse, theft,

misappropriation or infringement & failure to

report such instances. (E.g. preparing or approving

false invoices. Failure to follow the IP Standard.

Supply of counterfeit/sub-standard goods.)


6 Breach of NLNG Policies,

Procedures and Principles

* Accepting or giving gifts or entertainment that

exceed the policy limits or violate another policy or

NLNG Business Principles, such as respect for

people.

* Breach of NLNG Policies (HSE Policy, Security

Policy, Nigeria Content Policy, ABC policy etc.)

Violation of any NLNG Policy or Procedure.

* Failure to comply with the company’s document

retention and destruction programme. Unlawful

alteration or destruction of documents.

*Inciting of community violence.

* Staff harassment.

* Substance abuse.




7 Regulatory and statutory

Non-Compliance

*Non-compliance with regulatory requirement,

taxation, etc.

* Unethical conduct or practices, and indictments

by a regulatory agency or court order/jurisdiction

that may impair vendor’s ability to deliver on their

commitment to NLNG.

Violation of any existing law.


8 Case of Vendor

Bankruptcy/receivership.

This is applicable to vendors that have become

insolvent and can no longer honor commitments. De-list vendor from NLNG Vendor database Permanently

9

Non-compliance with

deliverables and

commitments in the NC

Execution Plan (NCEP)

against which the contract

was awarded.

Underperformance or failure to deliver as per NC

commitments by contractor in their Nigerian

Content Execution Plan

(i) Following failed efforts to ensure compliance

with deliverables, Vendor shall be put On Hold. 6 Months

(iii) Subsequently, if persistent non-compliance

prior to completion of contract, vendor shall be

placed on Probation.

1 Year

10 No response to enquires

No response to 3 or more enquiries received

within 6 months and total number of enquires > or

= 5

Suspension# 1 Year


LEGEND On Hold Continue other existing work. No new Enquiries. De-mapped from affected Product Groups (Time Bound)

Probation Continue other existing work. No new Enquiries. De-mapped from all Product Groups (Time Bound).

Suspension Stop work. No new Enquiries De-mapped from all Product Groups (Time Bound).

Suspension# Continue other existing work. No new Enquiries. De-mapped from all Product Groups (Time Bound).

Suspension## Continue other existing work. No new Enquiries De-mapped from all Product Groups (Time Bound).

De-listing

Stop work. No new Enquiries. Remove from NLNG database (Not Time Bound).

statement of business principles 2017 - nigeria lngnlng.com/business-with-nlng/shared...

Documents