Responsibility

Welltec responsibility

Common values

All employees share a common set of values and objectives. One essential objective is our conviction to uphold ethical standards in all our corporate activities. These standards apply to all Welltec’s activities in every market that we serve.

Our conviction to uphold ethical standards in our activities is a common mindset of all our employees. We strive to do business with customers and suppliers of sound business character and reputation.

We expect all our employees to perform their work with honesty, truthfulness and integrity, hereunder to respect and abide by the governing guidelines.

Objectives

Our paramount concern is the health and safety of our employees, customers and everyone else that involved with our activities. This concern reaches beyond such measures required under applicable law, and we and any of our employees will ensure that any and all reasonable measures are taken to protect any person against personal injury when involved in or related to one of our activities.

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Respect for and preservation of the environment is a key element of our business proposition and as such integral in our mindset. We therefore develop services that minimize negative impacts on the environment. This results in actual reduction of carbon footprint whenever a customer applies our solutions.

Welltec is an equal opportunity employer and we apply equal employment opportunities in conformance with all applicable laws and regulations to individuals who are qualified to perform job requirements irrespective of race, religion, creed or color.

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Responsibility

Business Ethics

Right from the outset integrity and ethical conduct have been guiding principles. Principles which have been developed into the operational policies implemented throughout the organization. 

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Welltec generally encourages, operates and enforce the following management principle: “In Welltec we say what we do and we do what we say”. This general management principle facilitates certainty to all Welltec stakeholders that predictability and reliability is a built-in feature when dealing with a Welltec representative.

Our employees and officers should conduct their business affairs in such a manner that our reputation will not be damaged if the details of their dealings should become a matter of public discussion.

Our conviction to uphold ethical standards in all our corporate activities is a common mindset of all our employees. We strive to do business with customers and suppliers of sound business character and reputation and we do not knowingly support any public or private organization, which supports discriminatory policies or practices. Welltec considers this predictability and reliability as a key driver in our approach to business ethics.

We expect all our employees to perform their work with honesty, truthfulness and integrity, hereunder to respect and abide by the governing guidelines.

The high quality of our employees and officers is our greatest strength. The professionalism and dedication of employees ensure that we are competitive in the short term and well positioned for continued success in the long term.

Our employees and officers are responsible for developing, approving and implementing plans and actions designed to achieve corporate objectives. The methods we employ to attain results are as important as the results themselves.

It is our policy to comply with all governmental laws, rules and regulations applicable to our business. However, even where the law may be permissive, we will follow the course leading to the highest degree of integrity.

Our employees and officers must deal fairly with each other and with Welltec’s suppliers, customers, competitors, and other third parties.

Our directors and officers support, and expect all employees to support, any fellow employee who passes up an opportunity that would sacrifice ethical standards.

All employees are responsible for the immediate and accurate reporting to higher management of work-related information of importance to the governing guidelines.

We strongly encourage dialogue among employees and officers to make each other aware of situations that give rise to ethical questions and to articulate acceptable ways of handling those situations.

Environment

Respect for and preservation of the environment is a key element of our business proposition and as such an integrated way of thinking in the Welltec Corporation.

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One of our core competencies is to provide solutions that minimize negative impacts on the environment. This results in actual reduction of carbon footprint whenever a customer applies our solutions.

Unintentional (potential) discharge into the environment of damaging substances in relation to one of our operations is reported to senior management.

Any near miss environmental incident is reported in our incident reporting system. They are carefully analyzed to ensure implementation and improvement of best practices in order to protect the environment to the benefit of us all.

At any local operation, we will ensure that respect for the environment is applied such that sustainability and recycling is promoted and secured to the greatest extent reasonably possible.

Community

We seek to play our part in offering employment opportunities to all sectors of the community through non-discriminatory policies and promoting opportunities to disadvantaged and vulnerable groups.

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It is one of our core competencies to solicit technologies and solutions that will leapfrog the industry into a new and innovative future. Our solutions deliver an increased recovery rate during the extraction of natural resources at lower cost, reduced impact on the environment and with less risks of health and safety of the people involved. We consider the continued focus on this competence as a vital part of our responsibility towards the community.

We operate from a significant number of properties in a variety of countries and we have responsibility to our employees, to the people living and working nearby as well as the environment. Therefore, we engage with the community at a range of levels in our capacity of customer, neighbor, employee, business, competitor and resident.

We seek to play our part in offering employment opportunities to all sectors of the community through non-discriminatory policies and promoting opportunities to disadvantaged and vulnerable groups. Further, we will actively be promoting engagement between our staff and the community. We encourage the support of local community groups and charities, hereunder support local initiatives for the development and education of young people in the areas where we operate.

We actively care and support measures improving the environment in and around our operations and we are working closely with local law enforcement agencies to address antisocial behavior, crime and vandalism as well as promoting road safety. In addition, our local companies provide support to community based charities and projects in their respective areas including support for employees’ efforts in fund raising and for small-scale projects.

Anti-Corruption

This section describes Welltec’s policy with regards to corruption, transparency and anti-corruption measures.

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Bribery
Bribery is to offer, promise or give any undue monetary or other advantage, whether directly or through intermediaries, to a person (the recipient). A bribe is a gift bestowed to influence the recipient’s conduct or alter the recipient’s behavior in relation to the performance of official duties in order to obtain or retain business or other improper advantage.

In short terms, bribery is where a sum of money or a gift alters the behavior of a recipient whereby the recipient acts in violation of the recipient’s public or legal duty. As such, bribery results in a behavior or decision by the recipient not consistent with the legal duties of that person.

Bribery is a crime and punishable under all legal systems. The purpose of bribery is to result in a commercial or personal advantage not in compliance with the law.

Bribery is strictly prohibited and we will enforce a strict zero-tolerance approach to instances of bribery. This applies irrespective if the recipient is a customer representative, a supplier representative or a government official.

If one of our employees receives a bribe by accepting any funds or other assets (including those provided as preferential treatment to the employee for fulfilling his or her responsibilities) for assisting in obtaining business or for securing special concessions from Welltec, his or her employment will be terminated immediately and criminal proceedings may be initiated.

Facilitation payments
Facilitation payments are ethically questionable payments made by a person (the facilitator) to secure or speed up routine actions such as issuing permits or releasing goods held in customs. A facilitation payment will result in the facilitator receiving only what the law permits, but in a more speedy fashion.
It is also considered a facilitation payment if a government official refuses to perform his or her duty unless a payment is made.

As a company, we are strongly opposed to facilitation payments and such are strongly discouraged. Therefore, every employee shall do his or her outmost to avoid facilitation payments.
However, facilitation payments may be customary in some operational territories to clear goods from customs, to pass immigration or to receive the rightful treatment from governmental officials, which the facilitator is entitled to under law. In such situations, Welltec will reluctantly accept facilitation payments subject to the following 2 conditions:

1) To the extent that facilitation payments are prohibited by local law, compliance with law shall be observed and a zero-tolerance policy towards facilitation payments must be observed.

2) If a facilitation payment is made, such shall be informed to Corporate Legal and the Human Resources Department immediately. Non-compliance herewith will be considered as non-compliance with this policy.

Gifts
Gifts such as merchandise or products as well as personal services or favors may not be offered unless deemed appropriate by special occasion, local custom or traditions and only if the gifts have a nominal value.

The nominal value shall be determined by the head of operations in the relevant territory and shall be in accordance with local custom and tradition; in case no nominal value is set by the head of operations, such gifts may never exceed USD 250.00 in value.

In case local customs mandate that presenting gifts only with nominal value will result in the recipient being offended or affronted, our employees maybe allowed to exceed the nominal value.
However, this is subject to prior approval from the Chief Executive Officer only.

Gifts of cash may never be offered.

Entertainment
Normal business entertainment such as lunches, dinners, theatre visits, sporting events, and the like, is appropriate when of a reasonable nature and when conducted in the course of a meeting or another occasion where the purpose is to hold bona fide business discussions or to foster better business relations.

All such entertainment where the value exceeds USD 500.00 per person should be reported by the employee to his or her supervisor. If practical, this should be reported in advance.

Our employees may offer tickets or invitations to entertainment where they will not be present at the event with the recipient.

Contributions, Donations and Sponsorships
It is our policy to not contribute, donate or sponsor, promote or solicit any specific political or religious agenda or direction. As such, our employees may not contribute to, promote or solicit any political or religious agenda or direction for or on behalf of Welltec, or otherwise act in a way which could be construed to this effect.

Obviously, our employees are free to personally exercise the right to make political or religious contributions, promotions or statements in accordance with law. Such contributions or statements may never be or appear to have been made for or on behalf of Welltec.

We will not reimburse any employee for political or religious contributions, and employees should not attempt to receive or facilitate such reimbursements.

The above does not apply to Welltec membership of industrial conferences, employer’s organizations, confederations or similar organizations working for and on behalf of the industry segment in which we operate. Such memberships are always subject to approval by the Chief Executive Officer.

Likewise, the above does not apply to sponsorships in local communities, participation in charity or similar activities if said sponsorships are non-religious and non-political and if the value of such sponsorship or charity donation does not exceed USD 1,500.00.

Employment

We believe that our employees are our most valuable asset, even if not shown in the balance sheet of the corporation.

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This is defined in the various policies which have been developed over time and made transparent in the way they are exercised.

To this extent, we actively participate in the well being of our employees, beyond what can be expected with regards to protection of the health and safety of employees when performing work.

Substance abuse
We recognize that tobacco, alcohol or drug dependency is a treatable condition. To the extent required, we will offer programs to help employees deal with substance abuse, hereunder programs to quit smoking. Employees who acknowledge or suspect they have such dependency are encouraged to seek advice and to follow appropriate treatment promptly before it results in job performance problems.

An employee who has had or is found to have a substance abuse problem may not be permitted to work in designated positions identified by management as being critical to the safety and wellbeing of employees, the public or the corporation.

No one of our employees with alcohol or drug dependency will be terminated due to the request for help in overcoming that dependency or because of involvement in a rehabilitation effort. All Welltec® sites are drug-free, non-smoking and non-alcohol work places, and any employee may, subject to applicable law, be subjected to random drug and alcohol testing. Welltec® may conduct unannounced searches for drugs and alcohol on properties owned or controlled by Welltec®.

Exercise

We will actively support any reasonable exercise and sports activities involving employees. Where food is being served at Welltec® sites, we will ensure that employees will have a low fat alternative, hereunder that a selection of fruit is available.

Equal opportunities
Welltec®is an equal opportunity employer and we will apply equal employment opportunities in conformance with all applicable laws and regulations to individuals who are qualified to perform job requirements.

We administer our personnel policies, programs and practices in a non-discriminatory manner in all aspects of the employment relationship, including recruitment, work assignment, promotion, transfer, termination, wage and salary administration, and selection for training.

All managers and supervisors are responsible for implementing and administering this policy. Further, such persons are responsible for maintaining a work environment free from any unlawful discrimination, and for promptly identifying and resolving any problem areas regarding equal employment opportunity.

Individuals who believe they have observed or been subjected to prohibited discrimination should immediately report the incident to their supervisors, higher management, or their designated Human Resources Department contacts.

Individuals will not be subjected to harassment, intimidation, discrimination, or retaliation for exercising any of the rights protected by our policies and the various Equal Employer Opportunities legislation.

Harassment
We prohibit and have a zero-tolerance policy towards harassment in any or our workplaces. We believe that a work environment that fosters mutual employee respect and working relationships free of harassment will result in better and more productive employees.

Forms of harassment include, but are not limited to, unwelcome verbal or physical advances and sexually, racially, or otherwise derogatory or discriminatory materials, statements, or remarks.

All employees, including officers and managers, will be subject to disciplinary action up to and including termination for any act of harassment.

Individuals who believe they have been subjected to harassment should immediately report the incident to their supervisors, to higher management, or the Human Resources Department. All complaints will be promptly and thoroughly investigated.

Employees, managers or officers who observe or become aware of harassment should immediately advise their higher management, or the Human Resources Department.

All our officers and managers will ensure that no retaliation will be taken against any employee because he or she reports a problem concerning possible acts of harassment. All employees can raise concerns and make reports without fear of reprisal.

Work environment
We encourage an open door policy such that all employees can ask questions, voice concerns, and make appropriate suggestions regarding business practices.

Compliance with policies
Any employee is expected to report promptly when expecting violations of law, our policies or internal controls so that management can take appropriate corrective actions, hereunder initiate internal or external investigation and control measures.

It should be noted that any employee has access to alternative channels of communication depending on the subject matter, for example financial control functions (performed by Group Finance), internal audit functions (performed by Corporate QHSE) and internal investigations (performed by Corporate Legal & Human Resources).

Any person involved in responding to questions, concerns, complaints, and suggestions are expected to use appropriate discretion regarding anonymity and confidentiality, although the preservation of anonymity and confidentiality may or may not be practical, depending on the circumstances.

Failure to behave honestly and failure to comply with law, our policies, and/or our internal controls may result in disciplinary action, up to and including termination with cause.

Quality

Quality is and has always been deeply ingrained in all processes at Welltec. It is part of the culture and therefore a natural element in the constant evolution of work processes.

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Thus we maintain a service with a built-in system of recording and addressing non-conformities, which incorporates a continuous improvement program allowing a constant review of all processes.

We believe that a combination of individual responsibility and accountability within the organization forms the framework which avoids non-conformities.

We believe that superior competences, dedication and communication create the organization that delivers the performance necessary for us to achieve our objectives.

Therefore we continuously develop our organization through individual communication, education and training as well as recruitment of competent employees.

Welltec is ISO 9001 certified by DNV-GL.

Health and Safety

Our paramount concern is the health and safety of our employees, customers and everyone else that comes into contact with our activities.

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This concern reaches far beyond such measures required under applicable law, and we and any of our employees will ensure that any and all reasonable measures are taken to protect any person against personal injury when involved in or related to one of our activities.

Health and safety underpins all our operations and our corporate Health & Safety motto “I’m working safe – are you? Innovation today for a safer tomorrow” underlines that even if we may be focused on future developments in technology, all our employees are aware that safety is not an issue of the future, but an imminent element of every second.

Any situation where a person (being employee or non-employed) is injured in relation to one of our activities is reported to senior management.

Any injury or near miss incident is reported in our incident reporting system. Statistics of performance in health and safety are kept and analyzed to ensure implementation and improvement of best practices protecting the health and safety of individuals.

Customers

It is our policy to provide solutions that excel in quality and reliability and – at any time – conform to industry best practices and responsible standards of performance.

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This includes taking due care and consideration to protection of the environment and the health and safety of all people involved in our activities.

We consider all our customers as business partners and will ensure an open and transparent partnership with our customers. Frequent, relevant and informative communication with the representatives of our customers on how we best can – and cannot – serve the best interests of them, is considered a short term and long term asset to the benefit of the partnership and the parties involved in it.

To the extent that our solutions do not excel in quality, reliability, industry best practices and responsible standards of performance, we will ensure an open dialogue with our customers in the best interest of the partnership.

We operate an open door policy in relation to situations where a customer or regulatory body wishes to investigate a non-successful operation or an issue of regulatory non-compliance. In such situations, all non-optimal or non-compliant findings from the internal Welltec investigation is openly disclosed to the customer or regulatory body. This is done to achieve maximum transparency and optimal lessons learned, enabling hindrance of repetition of any such issues.

At any time, we will strive to furnish correct, accurate, truthful and sufficient information about our solutions, including all details, terms and conditions of sale, such that our customers can make informed purchasing decisions with full transparency.

We shall at any time seek to communicate truthfully, accurately and objectively in our advertising and other communications.

All interactions with our customers are considered confidential of nature. All our employees and officers are under duty to maintain confidentiality and keep full secrecy with regards to any dealings with our customers.

Reporting Whistleblower

The Welltec Reporting System enables you to report possible violations of laws or company policies in relation to companies of the Welltec Group – anonymously if desired.

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The Reporting System, which is an electronic reporting application, is open to all Welltec employees as well as third parties such as customers, suppliers, etc.

All reports received are reviewed and handled by Welltec Legal Department officers. It is possible to set up a line – anonymously if desired – to enable communication between the Legal Department and the reporting person.

Welltec safeguards the interests of the reporting person not only through this secure Reporting System, but also by providing assurances that all information received by the Legal Department at Welltec will be treated in confidence, and that all means at our disposal will be used to protect reporting persons acting in good faith from any disadvantages as a result of their disclosures. Welltec will apply appropriate measures against employees who violate this commitment.

During its investigations, Welltec will also strive to protect the legitimate interests of other persons affected by a disclosure. Casting suspicion on another person can have serious consequences for that person. It is essential that the Reporting System is used responsibly.

For employees of the Welltec Group reports submitted via this system is one way of providing us with information about possible compliance violations. However, in the spirit of a corporate culture based on openness, we encourage all employees to first turn to contacts within the company, e.g. their line managers or the Legal Department.

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Signatory to the UN Global Compact

Welltec has signed up for the UN Global Compact, the world’s largest corporate sustainability initiative. It requires companies to align their operations and report progress annually on ten universally accepted principles in the areas of environment, anti-corruption, human rights and labor. As a member, Welltec has joined many other esteemed businesses, including key customers, in adopting a common, internationally-recognized framework for addressing sustainability issues.

Well service responsibility
Welltec responsibility

Implementing CSR policies

The Welltec Academy also strives to provide courses which support our corporate social responsibility policy and thereby also our employees on a more personal level. These courses may include; basic IT, ergonomics and language skills.

We create new courses continuously to ensure we take our employees further and equip them with the necessary skills to perform optimally.