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SHELL PLC BUSINESS ETHICS AND TRANSPARENCY

Extracted from pages 18 & 19 of Shell Sustainability Report 2020

SHELL PLC BUSINESS ETHICS AND TRANSPARENCY

ETHICAL LEADERSHIP

Our core values of honesty, integrity and respect for people underpin our work with employees, customers, investors, contractors, suppliers, non-governmental organisations and others. The Shell General Business Principles, introduced more than 40 years ago, describe our core values, our responsibilities and the principles and behaviours that guide how we do business.

Ethical leadership during COVID-19

In 2020, we stepped up efforts to support our employees, contractors and those we do business with to make the right ethical choices and adhere to Shell’s compliance expectations in response to challenges from the COVID-19 pandemic.

We developed guidance on COVID-19 to help Shell leaders set the tone for behaving ethically and to promote compliance in their teams. We offered additional practical advice on avoiding potential breaches of our Code of Conduct. This advice covered managing potential conflicts of interest while working at home, where work and family lines may be blurred. We issued reminders to complete mandatory training and emphasised that leaders should ensure people feel comfortable speaking up.

This work built on the ethical leadership expectations programme, which was introduced in 2018 and continues to be rolled out for senior leaders across Shell. The programme was designed to reinforce the level of commitment to ethics and compliance in senior leaders.

In 2020, we also developed a new decision-making framework to ensure that we continue to make ethical decisions in line with our Code of Conduct. The framework, which has been externally reviewed, will help staff to think through, in a structured way, the legal, ethical and external consequences of the various decisions they face in their daily work. We are launching the framework in 2021.

Supply chain

In 2020, we took steps to strengthen and simplify our approach to working with suppliers and contractors amid COVID-19 uncertainties. For example, we adapted our due diligence assessments to ensure partners that look to save costs do not compromise ethical conduct. We also produced additional COVID-19 guidance for employees, highlighting potential corruption and money laundering risks in supply chain and relief donations.

Speaking up

Shell employees, contractors and any third party can report any potential breaches of the Code of Conduct confidentially and anonymously through several channels, including a global helpline, operated by an independent provider.

Shell has specialists who investigate concerns or allegations about a breach of our Code of Conduct. If a breach is substantiated, the relevant Shell company will take appropriate action up to and including a contract termination or dismissal. We maintain a stringent no retaliation policy to protect any person making an allegation in good faith.

ANTI-BRIBERY AND CORRUPTION

Shell has rules on anti-bribery and corruption in our Code of Conduct and Ethics and Compliance Manual. Both are available publicly online. Contractors and consultants are also required to act consistently with our Code of Conduct when acting on our behalf.

In 2020, we also made our Code of Conduct training publicly available, with the aim to ensure contract staff working for Shell understand their personal responsibilities. In addition, using a risk- based approach, we started offering select third parties, such as distributors and suppliers, an online anti-bribery and corruption training course, free of charge and in several languages.

In March 2021, Shell and four former employees were acquitted in a long-running trial in Milan related to a Nigerian oil block called OPL 245. Shell has always maintained that the 2011 settlement with the Federal Government of Nigeria and Eni that was at the heart of this trial was a legal transaction, so we welcome the ruling. This has been a difficult learning experience for Shell. Business integrity is one of our core values and we continue to work hard to raise standards in this area. You can read Shell’s detailed response at www.shell.com/shell- comments-on-the-verdict-from-the-milan-tribunal-over-opl-245

 

PERSONAL DATA

Shell respects the privacy of individuals and recognises that personal data belong to the individual. We take action to manage personal data in a professional, lawful and ethical way.

Our privacy policies, notices and other customer agreements clearly define the data we are collecting, why they are being collected, who has access to them and for how long. We seek to process only the minimum data required, such as when customers participate in loyalty schemes or pay for fuel on their phones without leaving their vehicle. Personal data processed in our systems are secured appropriately and treated with respect to maintain privacy for our employees, partners and millions of customers around the world. The COVID-19 pandemic increased the need to process personal data, for example, when employees, suppliers and others visit our premises.

Our specialists work closely with teams across Shell to maintain compliance with our data privacy standards and to ensure that we use data in an ethical way. In 2020, we continued to evolve our approach. For example, we analysed new data privacy regulations, such as those in Brazil and California, USA, and the advice of regulatory and industry bodies, including the World Federation of Advertisers. We also review our marketing standards, including our apps and websites, to keep them up to date with best practices.

From page 19 of the same report

Cyber security

Shell is subjected to frequent cyber-security attacks, including attacks targeting our customer database, and the COVID-19 pandemic led to an increase in such activity. Data breaches have occurred at Shell. Where systems, customer accounts and data have been compromised, we have notified data privacy regulators and affected customers where appropriate.

We regularly monitor our IT systems for possible vulnerabilities to cyber attacks. Our incident-handling process helps to ensure that we deal effectively with an issue. The process also helps us to meet the most stringent regulatory reporting timelines, for example, the 72-hour requirement under the General Data Protection Regulation.

Read more about our values at www.shell.com/values and our requirements for our businesses and functions to comply with at www.shell.com/shell-ethics-and-compliance-manual

LIVING BY OUR PRINCIPLES

SHELL GLOBAL HELPLINE

1,425 Reports to the helpline

CODE OF CONDUCT

216 Confirmed breaches of the Code of Conduct

TAKING ACTION

252 Employees or contractor staff subject to disciplinary action

TAKING ACTION

54 People dismissed

SOURCE

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