Compliance

Code of conduct

Compliance

For the Hess AG, fair and generally accepted guidelines are the main principle of all business operations. They are an important part of our company policy and our internal management principle. We develop the best possible solutions for our customers. Above all, this requires our staff, our comprehensive and marketoriented products and services portfolio as well as the following guiding principles.

Guiding principles

Quality
It is our ultimate goal to produce and deliver all products in first quality.
Trust
We create trust through our reliability and transparency.
Responsibility
We show responsibility and respect for our employees and our customers. We strive for the creation of a win-win situation for our employees, our customers and the Hess AG. Companies are not evaluated solely by economic performance measures. They built up communities of values that are increasingly being judged by the principles they follow to achieve their results in the business world. As a global company we are aware that our responsibility is beyond purely technical and economic aspects.
Transparent, fair, consistent, and socially responsible action becomes more and more important. Therefore, we work on the basis of ethical standards as well as the attached Hess Code of Conduct. Hereby, we fulfil our obligations to our employees, customers, and to society.
In general, contraventions can be avoided by timely information or advice. For this purpose, the respective superiors and Hess compliance officer (member of the executive board) are available to advice and assist.
We expect our management to exemplify and communicate the basic principles of Hess Code of Conduct which form an integral part of the Hess AG compliance. Each employee is responsible to behave after these principles in business life. Violations will not be tolerated; corresponding consequences, if necessary even labour law implications, will be applied.
Ethical and fair business practices are an essential part of our collaboration. We have confidence in each employee to cope with this demand.

1. Hess AG – Ethical principles at a glance

Loyalty and integrity characterize our business activities. This is reflected by the following principles:
  • We work globally, taking account of recognized standards
  • All applicable laws and regulations are complied with wherever we operate
  • We are accountable for our actions and stand by them
  • Our employees are continuously informed about how to deal with ethical issues
  • We improve continuously
Internal violations of the Hess Code of Conduct are to be reported by the staff. In doing so, names of the parties as well as time, place, and nature of the offence must be named. All affected employees have to be heard to.
Basically, the immediate supervisor is the primary contact for a violation report. For his support, he can consult the respective administrative person in charge (particularly human resources, finance and accounting) or the compliance officer.
We take responsibility for our employees. No one shall be penalized by complying with the Hess Code of Conduct.
We reject unfair business practices. We do business without corruption or bribery.

2. Hess Code of Conduct: Lawful and responsible action

I. Integrity of our services
Quality and professionalism with which we add value for our customers are key features of our services. We provide our services independently and professionally, taking into account the technical standards as well as methods, standards and processes existing at Hess.
We document the results of our services accurate and complete.
II. Integrity of our financial and corporate documents
Internal and external transparency as well as compliance with usual business standards are normative rules for our corporate behaviour. We track all business transactions applying the relevant documents and correct receipts. We keep such records in compliance with the relevant statutory regulations.
III. Avoiding conflicting interests
Loyalty to companies and employees is fundamental to our business philosophy. We avoid situations where personal or financial interests come into conflict with those of the Hess AG. This applies particularly to investments in companies of suppliers, customers, and competitors as well as the establishment of private business relationships (i.e. consulting contracts) with these. We are not allowed to use insider knowledge for our advantage or that of third parties.
We abstain from receiving or accepting direct or indirect personal gains, particularly from reimbursements (socalled “kick-backs”) or personal gifts or invitations from which can be assumed that they might influence business decisions or transactions.
We refrain from ancillary activities outside of the Hess AG without prior approval by the supervisor.
The above-mentioned conflicting interest are listed here as an example. Conflicting interests may arise from any situation in which the interests of Hess differ from the employees’ personal interest or that of such people with whom they are in close contact. We avoid any appearance of conflicting interest. In case of doubt they have to be reported to the superior for clarification.
IV. Bribery/Corruption
Neutrality and integrity of our services are of utmost importance for the reputation of our company. We separate private and business sphere and refrain from any action that might give an illegitimate direct or indirect competitive edge to business partners or authorities and their employees or other third parties (i.e. offering/granting of money or personal gains). This is especially true if the nature and extent of these benefits are capable of influencing actions or decisions of the recipient in an inadmissible way.
Gifts, hospitality and entertainment must always be related to business relationships or associated with a real business purpose being in line with a socially adequate and legally accepted setup. Violations are against the interests of the company as the consequences may be personal prosecution, high fines, subsequent payment of taxes, and civil law claims.
If we are offered gifts, money or similar benefits they must be reported immediately to the supervisor. The only exception is for common objects (i.e. pens, small calendars) of a total value not exceeding 25,- EUR.
V. Competition and anti trust law
We are committed to fair and open competition within a free market economy. We refrain strictly from illegal practices (i.e. illegal collusive tendering and price agreements) precluding, restricting or distorting competition, the exchange of competitive information, and the discrimination of competitors.
VI. Confidentiality and privacy
Customer confidence and trust in employees is key business principle of our company. We respect operating and business secrets of the Hess AG and its business partners, contractual confidentiality obligations with third parties and all applicable data protection regulations.
VII. Labour and product safety, health and environmental protection
The protection of people and the environment is a fundamental principle. This applies to both the fulfilment of the responsibilities for our own company and the provision of services for our customers and business partners. We respect the laws and regulations on labour safety and health protection as well as product and workplace safety.
VIII. Handling property of Hess and third party property
Responsible dealing with own and other people’s property as well as with intangible property, i.e. know how and intellectual property (trademarks, patents) is significant for Hess. We carefully deal with our own and other people’s property, with our own know how and intellectual property and respect foreign know how and property rights.
IX. Money laundering
As a competitive company, the appropriate remuneration of its services is for the Hess AG of high importance. We comply with the money laundering regulations. We refrain from business that serves the conversion or transfer of money into the economic cycle which originates directly or indirectly from previous crimes.
X. Manners between employees and with business partners
Fairness and respect in dealing with each other as well as in the behaviour towards employees, customers, and business partners is a key cornerstone of the Hess corporate philosophy. We act respectfully within and outside the company towards applicants, employees and customers and refrain from any form of discrimination and bullying at work (i.e. concerning gender, age, disability, sexual orientation, ethnicity or religious beliefs).

3. Implementation and monitoring of the Code of Conduct

I. Commitment
The Hess Code of Conduct is a vital part of the Hess business philosophy. The Code of Conduct is supported by the senior management. It is explicitly accepted by all employees and is a part of their employment duties as well as a standard for their own entrepreneurial behaviour.
We are committed to conducting our business without corruption and bribery. Here we follow the Code of Conduct of “Transparency International” which defines transparency, responsibility, integrity, solidarity, moral courage and constitutional legality as key principles and values of action.
We therefore refrain consciously from business relationships with third parties of whom we know practice granting and demanding dishonest benefits. As a longterm thinking and sustainably acting company we are convinced that this policy allows for even more successful competitiveness and does not contradict profitability or growth.
II. Personal Responsibility
We are all personally responsible for complying with the Hess Code of Conduct. Therefore all employees are provided with the Hess Code of Conduct. For new hires it is to proceed accordingly.
Every executive manager is responsible for the abidance of this Code of Conduct among the employees under his supervision and has to exemplify it in his personal and business behaviour. No employee shall be penalized by complying with the Code of Conduct.
III. Responsibilities
The board of the Hess AG has entrusted a compliance officer to implement the Code of Conduct and to clarify all related matters. The compliance officer is a member of the executive board.
The compliance officer also coordinates training and qualification within Hess administration. All employees are obligated to comprehensive information for the compliance officer’s task performance. All reports made by the staff shall be directed first to the immediate supervisor who will pass them on to the compliance officer if required.
The same applies in any case of suspected violation of the Code of Conduct and any unfair advantage that is demanded by or offered to employees by third parties. Nevertheless, the compliance officer is available for direct contact for all employees, especially in case of doubt or conflict situations.
The compliance officer will discuss each question and suggestion strictly confidential and investigate these in accordance with the requirements of each individual concern. The employee will also be informed about what action has been taken due to his information upon request.

Contact

The compliance officer can be contacted via mail, phone, fax or email by all employees. Third parties who don’t belong to Hess AG may, (if necessary), contact the mentioned contact person.
Sandra Haus
Compliance Officer
Human Resources/
Organisation/Communication
Senior Management Team Member
Hess AG Form + Licht
Lantwattenstraße 22
D – 78050 Villingen-Schwenningen
Tel: +49 7721 920 466
Fax: +49 7721 920 771335466
E-Mail: Sandra.Haus@hess.eu