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Code of Responsible Business

 

Pacific Hunt Energy Pte. Ltd. and all its affiliates (“PHEPL”, “Pacific Hunt Energy”, or the “Company”) are committed to maintaining responsible and fair business conduct in Myanmar, and elsewhere. Remaining credible and honest is a core value to PHEPL and we work every day to achieve these goals in our operations.

We created this Code of Responsible Business as a guide to the ethical, lawful and fair conduct of all our employees, consultants, officers and directors (collectively “Employees”). It shall also serve as a reminder to all our Employees that only collectively we can operate in a responsible manner. The Code will explain how we aim to work responsibly as well as how we will meet our business conduct. PHEPL is also committed to obeying all applicable local and international laws. Remaining lawful is one of our core values. The Code shall also be used to prevent improper, unlawful and any conduct that might be harmful to the Company’s reputation in any country.

The Code was created to guide us through our operations in a successful and responsible way. It is a guideline to make sure that:

  • Together we maintain and promote a safe working environment that is free of any disrespectful behaviour for all our employees. Every Employee should feel respected in our work community.
  • Every Employee holds a personal responsibility of abiding any related laws and regulations. It is recommended that any misbehaviour is reported to the foreman so that the conduct can be changed accordingly.
  • We adopt policies, related to any business activity, that aim to serve as protection against any possible harm, whether physical, financial or other.

This Code is to add value to any other Pacific Hunt Energy policy or guideline, and shall not overrule other company rules. While this Code aims to cover as many scenarios as possible it cannot cover all possible situations. This does not mean that a certain conduct is allowed or promoted even if it is not specifically forbidden in the Code. All employees are encouraged to operate in a safe, fair and best possible manner in any given situation.

Management Responsibilities

The Company’s reputation is dependent especially on the management’s behaviour and actions. We demand the managers to act upon the highest standards of corporate responsibility and business conduct and to show exemplary behaviour to all other employees.  Managers shall encourage employees to commit to the Code in their daily activities.

 

Conflicts Of Interest

All Employees shall have the Company’s best interest in their mind in all situations and their actions must reflect this. All observed conflicts of interest or breaches of the Code should be reported to the closest supervisor. The supervisor is required to take action of after a breach/conflict has been reported to him/her. By taking action we mean bringing the issue to the CEO/the Board’s knowledge who can solve the issue in the best benefit of the company.

No Employee shall accept a position in a board of any company that is or may be a competitor of PHEPL. Exceptions may be made upon the consideration of the Board or Managing Director.

Pacific Hunt Energy does not permit and accept the following activities:

  • Sharing confidential information about PHEPL or its operations with outsiders without a non-disclosure agreement in place or without the authorization of the board/the CEO
  • Using PHEPL property, whether material or non-material, for the employee’s own personal benefit. This includes influencing and trying to influence PHEPL’s partners, contractors and consultants to benefit personally
  • Promoting or making decisions regarding PHEPL and its operations that might benefit an employee, or other people close to an employee (including friends and family) financially now or in the future without the approval of the Board

The above list is not comprehensive and is subject to change.

 

Legal Compliance

Pacific Hunt Energy is committed to complying with all applicable laws, rules and regulations, whether local or international, in Myanmar and any other country where it may have operations. We work tirelessly to conduct all our business affairs and operations with honesty, integrity and fair manner. Each Employee is responsible for making sure their actions and decisions are in compliance with the applicable laws, regulations and rules. Any situation that might result in an unethical or unlawful result or side effects should be avoided. If an Employee reckons he/she does not possess enough knowledge of applicable laws, the employee is encouraged to seek advice from a knowledgeable resource. Employees shall also act in a way that cannot harm PHEPL’s reputation in their free time.

Compliance With Environmental Laws

PHEPL is strongly dedicated to operating in compliance with all environmental and sustainable development laws. Each Employee individually and together is to comply with these laws as well. Any breaches of these laws should be reported to the closest foreman. This applies to both local and international laws that concern environmental and sustainability issues in Myanmar and other countries where the Company may operate.

 

Gifts And Entertainment

Business gifts of a reasonable value can be accepted and given. As a guideline, a gift’s value should exceed 30USD only on special occasions. Gifts valued at more than 30USD should always be approved by the Managing Director. No gift or entertainment should be in breach of good manners or the law. Employees are expected to use their best judgement when choosing gifts and ways of entertainment. Neither receiving nor giving a gift or taking part in entertainment should be regarded as consent or obligation to do business together in the future.

When in doubt, the Employees are advised to talk to their supervisor. 

 

Anti-corruption And Auditing

Pacific Hunt Energy takes a stand against corruption and has committed to work in a transparent manner in Myanmar, and all over the world. Corruption should not be tolerated in any form but business should be conducted in a fair and responsible way by all parties.

All transactions and other relevant information will be reflected in our books accurately and truthfully. Furthermore, we ensure all our financial reports and documents conform to all legal and accounting requirements and procedures.

Employees are strictly forbidden to falsify, destroy or alter documents in any case, whether for personal or company gain.

We abide all local and international laws and regulations, applicable to oil and gas sector in Myanmar.

 

Confidentiality And Sharing Information 

Employees may possess information of confidential nature occasionally or continuously. The information may be in regards to business contracts, operations, partners or other related matters. Such information must always be kept confidential both during their employment and after they have ceased to work for the Company. Confidential and proprietary information must only be used for Pacific Hunt Energy’s purposes, not for personal gain.

Confidential information should only be shared with second or third parties after they have signed and agreed to Pacific Hunt Energy’s non-disclosure terms.

If an Employee is contacted by a governmental entity or legal counsel, they should decline to respond and discuss the matter with the Managing Director before giving any reply. All replies, however, should be truthful and the Employee should not give false information to such requests.

 

Competitor Information 

While information about competitors, customers and suppliers are useful and helpful to the Company, no employee should use illegal or otherwise questionable ways of acquiring such information. Information that the entity in question has shared themselves with the Pacific Hunt Energy or has come to the knowledge of the Company through public channels such as public documents and newspaper articles, can be used to make informative decisions. Employees must not breach or otherwise violate any contractual agreement, such as a non-disclosure agreement, in order to make use of or seek confidential or proprietary information.

 

Document Retention

Pacific Hunt Energy Employees are required to ensure all any applicable laws and regulations are met regarding document retention. The Employees are strictly forbidden from modifying or destroying documents and/or records, also those concerning the Employee personally, when there is an ongoing litigation or investigation. If an Employee has any concerns regarding destroying or modifying a document or record, they should voice their concerns to the Managing Director before acting.

 

Fair Dealing

Employees should manage any contractor and supplier relationships in a fair, ethical and respectful manner that are aligned with all applicable laws as well as with this Code. All purchase decisions, whether products or services, should be made with the Company’s best interest in mind. This means decision making should be based on the potential contractor or supplier’s technical expertise, quality, reliability, price and other significant factors. Purchase decisions should and shall not be based on personal friendships, family relationships, or the opportunity to gain from the situation personally whether financially or otherwise. However, Employees are allowed to accept lunches and dinners as part of business negotiations. Accepting such lunches and dinners should not be considered as an agreement to sign an official contract.

The terms of the contracts and agreements should always be followed and Employees are not allowed to share the information of such documents with those outside of Pacific Hunt Energy without the prior approval of the contractor or supplier.

All contractors and suppliers must sign a Pacific Hunt Energy approved non-disclosure agreement and commit to not sharing confidential information with other parties.

 

Health And Safety

Pacific Hunt Energy is committed to achieving a working environment that is safe for all of its Employees, contractors, and visitors. A safe working environment is one without risks to health and well-being.

We think occupational health and safety is an individual and shared responsibility which depends on the co-operation of all employees, contractors, and visitors.

Pacific Hunt Energy is committed to:

  • Providing a safe working environment to comply with relevant Acts and Regulations within the area
  • Making sure all Employees, contractors and visitors go through a safety induction when first entering the workplace to ensure a safe working place for everyone
  • Assessing identifiable risks before commencing work, regardless of the task or work location. In addition, Pacific Hunt Energy will monitor, manage, and aid in reducing those risks
  • Ensuring health and safety policies and procedures are implemented, reviewed and updated when necessary.

Contractors and visitors are accountable to:

  • Complying with relevant Acts, Regulations and Rules, whether governmental or set by Pacific Hunt Energy
  • Cooperating and acting in a manner to maintain and support safe work practices
  • Reporting any unidentified risks to Pacific Hunt Energy to aid in a safe workplace.

The Company’s objective is to make sure everyone gets to leave Pacific Hunt Energy’s premises safe and in good health.

 

Discrimination And Workplace Harassment

No Employee is allowed to discriminate against or harass other Employees or act in a way that is or could be considered illegal or harassing. Whether verbal, physical or visual, discriminatory or harassing behaviour could include but is not limited to, derogatory comments about one’s racial or ethnic characteristics, sexual or religious orientation, and unwelcome sexual advancements.

Each member of the management is responsible to a reasonable degree to be aware of any behaviour or acts that could be considered harassment or discrimination. If an employee notices any behaviour or conduct that could be regarded discriminatory or harassing, he or she voice their concerns to the Managing Director.

 

Company Logo

Any Pacific Hunt Energy logos are considered the property of the company and must only be used for business purposes. The usage of logos must be approved by the Managing Director in advance. The logos are available from administration and business development departments. Recreation or alteration of the logo is prohibited.

 

Compliance With The Code

This Code does not address all situations that Employees may encounter during their employment with Pacific Hunt Energy. When such situations arise, the employees should base their decisions and actions on their best judgement of fair conduct, or ask their supervisor for advice. 

In case of any breaches of the Code, encouragement to breach the Code, fail to report a breach of the Code, help to hide breaches of the Code, retaliation against an employee who has reported a breach or fail as officer, director manager or supervisor to take appropriate measures to ensure the compliance with the Code.

Employees of Pacific Hunt Energy are required and expected to work in an honest manner. One’s employment with the company depends on the compliance with this Code and it may be ceased in case of a breach of the code. The Managing Director together with the Board is responsible for considering suitable actions when they notice or are reported to about a breach of the Code.

All Employees of the Company must acknowledge compliance with the Code and are required to abide it throughout their employment with Pacific Hunt Energy.
 

© 2014 Pacific Hunt Energy Pte Ltd. All Rights Reserved.