Creswick Petroleum will conduct its operations in such a way as not to harm people and minimise the impact on the environment. Creswick Petroleum is fully committed to continuously improve its health, safety and environmental performance by the successful implementation of this policy.
Creswick Petroleum commits it will:
- Ensure compliance with all applicable legislation and standards;
- Ensure an effective management organisation is in place and all personnel and contractors are aware of their health, safety and environmental responsibilities;
- Create a safe and healthy working environment for our employees, contractors and all other persons who could be affected by its activities;
- Identify, evaluate and control the risks and impacts associated with its activities, including where the potential exists for major accident events;
- Ensure that energy and resource management are an integral part of the business;
- Promote resource and energy conservation, waste minimisation and pollution prevention;
- Recognise and respond to employee and community concerns regarding the health, safety and environmental aspect of the company's operations;
- Ensure all employees and contractors are competent to perform their health, safety and environmental roles; and
- Achieve continuous improvement of its business processes through the implementation of its Values and Business Principles.
Creswick Petroleum will ensure that the necessary resources are provided to fully support this Policy and will ensure that it is subject to audit and review as part of the Management System goal of continuous improvement in performance.
Creswick Petroleum seeks to create significant value for all its internal and external Stakeholders by building a international based business focused on bringing incremental and dormant hydrocarbon reserves to market quickly and safely, and operating our product assets in a way we can be proud of.
Creswick Petroleum will:
- Demonstrate management commitment to quality in its projects and operations;
- Establish and review quality objectives and implement quality plans to meet these objectives;
- Ensure an effective management organisation is in place and all personnel and contractors are aware of the Company’s quality expectations;
- Foster pride in its work and demonstrate its Values and Business Principles in its output.
Creswick Petroleum is fully committed to continuously improving its corporate performance by the successful implementation of this policy and will ensure that the necessary resources are provided to support it.
The highest standards of integrity are fundamental to the way Creswick Petroleum conducts business. As part of this commitment, Creswick Petroleum will not tolerate any form of bribery or corruption in our business. Compliance with anti-bribery and anti-corruption laws, in particular the UK Bribery Act, and understanding those laws and the ethical standards required of all of us is essential.
Who does it apply to?
All individuals working for Creswick Petroleum at all levels, including those acting for or on Creswick Petroleum’s behalf, are strictly prohibited from offering, paying, soliciting or accepting bribes or any form of kickback, including facilitation payments.
What happens if I don’t comply?
Given the serious nature of a breach, an individual’s failure to comply with this policy, whether intentionally or by an act of negligence, may lead to disciplinary action being taken that could ultimately result in termination of employment or engagement.
What is bribery?
A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
Offering and agreeing to accept a bribe is still a bribe and it doesn’t matter if the bribe is ultimately not paid. Some typical examples of bribery include:
- you offer a person tickets to a major sporting event, but only hand over the tickets if that person agrees to do business with you;
- cash payments by employees to third parties such as consortium members, introducers or consultants;
- loan guarantees or other extensions of credit providing a subcontract to a person connected to someone involved in awarding the main contract;
- political or charitable donations made to a third party linked to, or at the request of, someone with whom Creswick Petroleum does business; or
- a contracted project manager makes a payment to someone in order to expedite the work of the project.
What are facilitation payments?
Creswick Petroleum does not make, and will not accept, facilitation payments of any kind, or in any circumstances. Although these are not commonly paid, we uphold the prohibition of the making and receiving of such payments wherever we operate.
Does this policy apply to third parties?
We require that third parties, including contractors, who have a contractual or other business relationship with Creswick Petroleum to adhere to this Policy.
In addition, Creswick Petroleum requires that due diligence should be conducted on such third parties, using a risk-based approach having regard to, among other things, the work being undertaken, the location of that third party’s business and any history of non-compliance or bribery with respect to that third party.
What is the policy with regards to donations?
We do not make contributions to political parties or politicians in any country we have projects. We only make charitable donations that are legal and ethical under local laws and practices. No donation should be made, under any circumstances, without the prior approval of the Chief Executive Officer.
What are my responsibilities?
Every Creswick Petroleum employee is responsible for compliance with this policy. You must ensure that you read, understand and comply with this policy at all times.
Who monitors adherence to the policy?
Adherence to the policy will be subject to regular review by the General Counsel. Creswick Petroleum will also provide appropriate training for relevant employees regarding this policy and general compliance with anti-bribery obligations.
The General Counsel has responsibility for the day-to-day implementation of this policy, monitoring its suitability, adequacy and effectiveness.
How do I report an issue?
All Creswick Petroleum employees are required to assist in tackling fraud, corruption and other malpractice within the organisation. If you are aware of, or suspect that bribery may be taking place within Creswick Petroleum, you should report your suspicions to an appropriate person. If you are in doubt that your concerns have been or will be dealt with properly, you should raise the matter directly with any Executive Director or the General Counsel.
What will be the consequences of reporting?
If you genuinely believe that there is some form of malpractice occurring and raise a concern in good faith and without malicious intent, Creswick Petroleum will ensure that you do not suffer any disadvantage in the workplace as a result of speaking up, whatever the outcome of the investigation.
This Corporate Major Accident Prevention Policy (CMAPP) applies to all Creswick Petroleum’s offshore operated production installations. Creswick Petroleum has offshore onshore operated production installations in Canada and United Kingdom.
Production Installations in the UKCS
This Policy applies to operations undertaken on the Armada Hub, North Everest and Lomond offshore installations. These UK assets are managed by the upstream business unit known as Creswick Petroleum UK Operations, on behalf of the directors of Creswick Petroleum.
The Creswick Petroleum Operations organisation conducts the operated producing activities and provides advice and support to Creswick Petroleum in respect of those companies’ offshore operated production assets in the UKCS. Further support, in relation to wells and pipeline activities associated with those offshore operated production installations in the UKCS is provided by the Creswick Petroleum UK Operations organisation.
Whilst Creswick Petroleum has delegated corporate authority to make certain decisions to personnel within the Creswick Petroleum UK Operations organisation, the Boards of Creswick Petroleum retain ultimate responsibility for ensuring that this project is suitable, implemented and operating as intended.
Creswick Petroleum recognises that the operation and activities associated with the offshore installations, wells and pipelines over which it has operational command and control have the potential to give rise to Major Accident Hazards and is committed to implementing robust controls to systematically identify, evaluate and manage these Major Accident Hazard risks during all phases of the asset lifecycle from design through to construction, operation and ultimately decommissioning, in line with our Business Principle of achieving no harm to people and protecting the natural environment.
1. Creswick Petroleum will build and maintain a strong safety culture, which will ensure a high likelihood of safe operation and maintenance of plant, processes and equipment. This will include:
- Effective inductions to company values and specific worksite hazards;
- Hazard Awareness Courses, including specific courses for Major Accident Hazards;
- Awareness of the Creswick Petroleum Life Saving Rules;
- Encouragement and rewarding the reporting of incidents and near misses;
- Effective consultation with the workforce and their representatives on Major Accident Hazards.
2. Management of Major Accident Hazards will be reviewed by:
- Scheduled CEO and senior management reviews of the SEMS and the HSEQ performance of the business utilising published leading and lagging indicators;
- The provision of focussed performance data for the Boards, management and the workforce;
- Scheduled audits;
- Incident and accident investigation and analysis.
The frequency of these audits will be of an appropriate extent and intensity commensurate with the associated risks. Significant findings will be escalated to the CEO and senior management and actions will be tracked to closure. The audit programme underpins continuous improvement in the control of Major Accident Hazards.
3. Creswick Petroleum will encourage safe behaviour by recognising good safety performance through programmes such as:
- Intervention card recognition programme for both offshore and onshore;
- Programmes set out in company and asset annual HSEQ improvement plans to drive continuous improvement in safety performance;
- Recognition and Reward through the company annual bonus award scheme.
Personal HSEQ performance and the support of others is a key consideration for promotion to supervisory roles.
4. Creswick Petroleum’s HSEQ policies, procedures, capabilities and goals will be reviewed utilising both external and internal audits undertaken by competent personnel. This CMAPP will also be subject to monitoring arrangements to assure effectiveness and compliance with relevant statutory provisions, the objectives set out by this Policy and the BMS, including the mechanisms for investigating and taking corrective action in the case of incident or non-compliance to ensure that the Creswick Petroleum’s culture and processes remain aligned. The procedures will cover the reporting of major accidents and near misses, particularly those involving failure of protective systems, and their investigation and follow-up including the sharing of any lessons learned.
5. Core to all Creswick Petroleum’s activities is safety and environmental protection. We will not operate if it is unsafe to do so or if there is a major threat to the environment. We will align our management systems to relevant national and international standards to ensure best practice.
6. Incidents will be investigated, root causes established and actions taken to avoid repeats. Crisis management will involve members of the Creswick Petroleum’s leadership team.
7. Competency requirements of key roles performing safety and environmentally critical tasks will be assured by the Creswick Petroleum competence assurance management system which details necessary training and experience and ensures compliance. Assurance processes are also established to confirm the competence of individuals engaged through contracting companies.
8. Creswick Petroleum will identify all safety and environmental critical elements (SECEs) and ensure that they are maintained to the requisite level to complete their function and achieve desired reliability. They shall also be designed to survive any incident they are controlling/mitigating or fail in a state which achieves the desired objective. All SECEs will have performance standards with defined Functionality, Availability, Reliability, Survivability and Interdependence.
9. Major Accident Hazards (MAH) will be managed primarily through prevention. Asset Integrity will be ensured by a thorough risk based inspection and maintenance programme.
10. To assess risks a Barrier Model will be used to ensure that at least two barriers are in place for each MAH.
11. Creswick Petroleum will conduct periodic thorough reviews of all safety cases and supporting studies to ensure compliance with company standards and legislation relating to MAH management.
12. Creswick Petroleum has a safety representative and whistle-blower scheme designed to encourage reporting in an anonymous and protected way. Tripartite discussions between the competent authority, Creswick Petroleum and the workforce and their Safety Representatives will be held for any changes relating to the management of MAH and Creswick Petroleum will implement appropriate actions arising from such discussions.
13. All instrument data and alarms from the Distributed Control System are recorded and securely stored on an independently managed read-only logging system to facilitate objective post-event incident investigation.
14. Creswick Petroleum will maintain systems to prepare, test and review incident and crisis management plans to enable effective Command and Control of the consequences of any foreseeable MAE. The company and each installation utilises published Incident Response Plans and resources made available to manage such incidents. All personnel, including senior management, with a role in the management of a MAE are trained and provided with scenario based exercises to become competent and confident in their roles.
15. This policy will be reviewed as required and as a minimum at the annual HSEQ management review facilitated by an independent third party and attended by the Creswick Petroleum Chief Executive Officer, HSEQ Director and Senior Management Team. The Chief Executive Officer has overall responsibility to ensure this CMAPP is suitable, implemented and operated as intended to drive continuous improvement.
Signed on behalf of Creswick Petroleum Limited and Creswick Petroleum North Sea Limited:
CEO and Director
Creswick Petroleum is the leading UK North Sea independent E&P Company with a portfolio of assets balancing:
- near-term development with production growth, with
- significant gearing to appraisal and exploration success.
We aim to generate superior equity returns by developing and commercialising incremental oil and gas resources in a safe and responsible manner.
Creswick Petroleum’s core values are integrity, passion, innovation and safety. Our approach to tax is fully aligned with Creswick Petroleum’s core values and business principles, which are published in full on our website.
In making this strategy available, Creswick Petroleum is fulfilling its responsibilities under Schedule 19 of the Finance Act 2016.
Creswick Petroleum was incorporated in Alberta, Canada to facilitate US inward investment and increase flexibility around dividend distribution. However, it is and has always been tax resident in the UK and has not sought nor obtained any UK tax advantage by virtue of being incorporated in the Canada. All the subsidiary companies in the Creswick Petroleum Group are incorporated in Canada and are also all tax resident in the UK.
Interaction with Tax Authorities
Our activities are subject to a significant number of different taxes including:
- corporation tax
- supplementary charge
- employment taxes
- customs duties
- stamp duties
We aim for an open and constructive relationship with HM Revenue & Customs and stakeholders so that we can comply with both the letter and the spirit of the applicable tax laws and regulations.
We also engage with both HM Treasury and HM Revenue & Customs on the development and interpretation of tax laws through the various trade associations of which we are a member.
We arrange our tax processes to ensure that we comply with the relevant tax laws and we pay all taxes as they arise. At the same time, we engage in efficient tax planning to support the commercial and economic goals of our various investments.
In so doing, we regularly seek external tax advice prior to making use of the various tax concessions, exemptions, incentives and reliefs that are made available by the tax authorities.
Tax Risk Management
The Creswick Petroleum Board of Directors retains ultimate responsibility for the Group’s tax-related policies, practices, procedures and principles and, within this, the Chief Executive and Chief Financial Officer have accountability to them for the management of the business’ tax risks. In addition, where appropriate, the Board uses independent third-party professional advisors to monitor, check and confirm the tax-related aspects of all plans and proposals presented to them.
The management of tax risks forms part of our overall internal control framework with potential weaknesses being identified, assessed and managed on an ongoing basis. Where appropriate, this will include the use of external third-party professional advisers to ensure that we correctly consider the facts, risks and conclusions in support of our decision-making processes. The following considerations are key within our management of tax risk:
- Our core values and business principles;
- Our reputation with our stakeholders including the tax authorities, the industry as a whole, and our employees;
- The legal and fiduciary duties of our directors and officers; and
- Our reported post-tax results, cashflow and the associated generation of equity returns.