OUR COMPLIANCE PROCESSES
We operationalize our Integrity Culture through a variety of compliance processes described below:
1. Reporting Compliance Concerns
To promote an atmosphere where our employees and other stakeholders feel free to raise concerns without fear of retaliation, we have a variety of ways to report compliance concerns.
We have a global organization of Compliance Helpline Leaders. Helpline Leaders are the ambassadors of SABIC’s Compliance Program. They are employees of all levels who are responsible for receiving concerns and ensuring they are investigated and addressed. Employees can also raise their concerns through several other platforms including, any manager, Human Resources, or Legal Affairs or an internal reporting icon. Additionally, any internal or external stakeholder can report concerns through an email address designated for reporting concerns or by calling our Compliance Helpline.
The number and type of concerns raised, as well as their disposition, are measured, tracked and reported.
2. Compliance Reviews
SABIC conducts Compliance Reviews designed to engage our business units and corporate functions to assess compliance processes, prioritize key risks and develop mitigation plans to address those risks.
This process results in the development of risk mitigation or action plans for the highest priority risks. These plans include assigning the responsibility for mitigation actions to particular individuals with required dates for completion. The progress toward completion of the plans is tracked every month through a digitized system tracker and is also discussed at periodic meetings of our regional Integrity Councils.
3. Integrity Councils
The oversight of SABIC’s compliance program is performed by a network of regional Integrity Councils, also called Compliance Councils. These Councils meet periodically to identify any new significant compliance concerns, review the activities of the Legal Compliance Team, and monitor our Integrity Culture.
4. Compliance Training
We require all employees to be trained on our Code of Ethics via a comprehensive web-based training program. All employees take General Awareness courses on the basics of the policies. In addition, there are advanced courses that are more detailed and are assigned to employees based on their roles within the company. This approach allows employees to complete training with particular focus on those compliance policies and practices that pertain most directly to the issues they face in performing their job duties. Our employees are required to take an average of about 15 advanced courses during a two-year training cycle. Several of our compliance courses are available in the languages most commonly used by our employees.
In addition to the Code of Ethics specific training, we also conduct live training based on job scope or location for high-risk topics (e.g. EHSS, International Trade and Antitrust).
Another feature of our compliance training program is the executive level training delivered by our company’s senior leadership, with the support of the Legal team. This training is designed to train senior management on the compliance responsibilities of a leader, emerging compliance risks, how to conduct compliance investigations and a review of our compliance infrastructure.
5. Supplier Qualification Process and Contracts
We have a supplier registration and due diligence program, Supplier Lifecycle Management (SLM). All suppliers must register and complete due diligence around ethical standards as described in our Supplier Code of Conduct, including fair employment practices, responsible sourcing, anti-corruption, data privacy and EHSS matters such as providing a safe work environment, pollution prevention, waste minimization and recycling, and safe and secure transportation of materials. All suppliers must answer a due diligence questionnaire to register in SLM, and those deemed to be in a high-risk category also may be subject to on-site audits. In addition, our standard forms of contract contain multiple provisions designed to ensure our suppliers meet our integrity standards and EHSS expectations.
For our additional supply chain disclosures please see:
6. Digital Tools and Periodic Compliance Messaging
Several digital tools enhance the robustness of our compliance program.
Customers, vendors and banks are regularly screened to ensure that no business is done with parties that are on sanctions lists. Such screening of customers is conducted through the Global Trade Services module in SABIC’s enterprise operating system, SAP, with escalations handled by company trade compliance professionals using our subscription to the LexisNexis® screening software tool, Bridger Insight®. Vendor screenings are handled by the company’s trade compliance professionals using Bridger Insight®.
In addition, our leadership team engages employees through frequent communications, live training and discussions regarding compliance responsibilities.