GGS provides the personnel and necessary equipment for work in the offshore/onshore oil industry.
The national leader in supplying equipment and personnel for well services and maintenance by forming diverse and talented teams who work with integrity, communicate openly, serve the community, and protect the environment.
My Dear Colleagues at GGS,
Welcome to Gabon General Services’ (GGS) Code of Conduct and Professional Ethics, where you’ll find practical advice to help you conduct business the right way, every day. Since GGS’s establishment in 2019, we have been fully committed to providing personnel and equipment for well services and maintenance to our clients while also delivering excellent service, never compromising our values or integrity. GGS’s values are essential to the success of our business and our identity as a company. Our values help us provide the best products and services, attract the best business partners, and take pride in our work. We all represent GGS in every action we take on behalf of GGS, and we must always commit to upholding the values that have defined GGS as a company and a global citizen since its foundation.
But it’s not always easy to know how to act in accordance with our Values. That’s why we have a charter to help us do what’s right. However, the charter cannot provide guidance for every scenario, so it’s important that you seek help when you have questions or concerns. By reading the charter, you’ll find references to GGS’s policies and procedures and information on who to contact if you have any questions.
One of our most important responsibilities when working for GGS is to speak up when we become aware of potential ethical or legal issues. If you find yourself in such a situation, you can contact one of the resources listed in the charter or our Ethics Helpline, where you can report it anonymously. You will never face retaliation for making a good faith report.
Our company conducts its business in a manner that reflects our commitment to ethics and doing what’s right. Our Mission, Vision, and Values represent our daily commitments to all stakeholders and our sincere commitment to strive to meet these commitments at every level of our company.
Thank you for contributing to GGS’s success.
Best regards.
Within GGS, our strength is measured by our commitments to our values: Integrity, People, and Performance. We take pride in demonstrating these values in our work for the GGS company.
Our Code of Conduct and Professional Ethics is here to help us do just that. The guidance from our Charter assists us in making wise decisions that uphold GGS’s commitment to acting with integrity, aligning with our values, safeguarding our reputation, and enabling us to thrive in today’s complex and competitive local business environment.
This charter has been developed to ensure that all directors, executives, and employees working on behalf of GGS (including partners) will adhere to the ethical and legal standards applicable to our work. Furthermore, we expect our business partners acting on behalf of GGS—such as suppliers, contractors, consultants, and temporary workers—to adhere to the standards outlined in our charter.
In addition to following the principles outlined in our charter, we must be aware of and comply with the laws and regulations that apply to the work we perform in the locations where we operate, including applicable local laws. Of course, we must also adhere to the requirements of any contracts related to project execution. Sometimes, we may find ourselves in a situation where applicable local laws or regulations seem to conflict with the guidelines provided in our charter. In these situations, we must always seek guidance before taking action.
For GGS to succeed, we must all act with integrity in all our business activities. All of us working on behalf of GGS have the following responsibilities:
- Always act in a professional, honest, and integrity-driven manner.
- Familiarize oneself with this code and GGS policies.
- Complete all required training before the deadline.
- Promptly report any wrongdoing or ethical breaches to your supervisor or any other designated resource listed in this charter.
Those of us acting as Managers, with or without direct subordinates, are integral to GGS’s ethical culture and have additional responsibilities, including:
- Lead by example: demonstrate the highest standards of ethical conduct in business, act as a mentor for others, and help them understand how to conduct business the right way.
- Communicate to direct subordinates and business partners how the charter and policies apply to their daily work.
- Seek opportunities to discuss ethically challenging situations with direct subordinates.
- Create an environment where compliance and ethics are valued, and others feel comfortable asking questions and reporting potential misconduct.
- Promote a safe working environment.
- Take into account ethics and compliance factors in addition to job performance when evaluating direct subordinates.
- Encourage employees to include compliance, safety, and quality objectives in their annual performance goals and business objectives.
This ethics charter establishes the foundation of values and principles of business conduct shared by all partners and employees of GGS.
It complements existing internal procedures in compliance with current regulations.
Making ethical decisions isn’t always easy, and you may find yourself unsure of the right course of action. If you find yourself in this situation, remember that you are not alone. Please refer to the “Seeking Help” section of this Code to find available resources to assist you.
When faced with a difficult ethical decision, ask yourself the following questions to help you make the right choice:
- Is it the right thing to do?
- Is it legal?
- Does it align with the mission, vision, and values of GGS?
- Does it adhere to our Code, policies, and procedures?
- Have I considered all the consequences, both for myself and for the company?
- Would I feel comfortable informing others (including my family and my superior) of my decision?
If the answer to any of these questions is “no” or if you still have doubts about whether your decision is ethical or legal, seek advice before acting.
GGS expects its employees, clients, suppliers, and intermediaries to individually and collectively contribute to promoting the values of the company.
It is important that we raise questions or concerns about a situation that doesn’t seem quite right. This may include violations of applicable laws or regulations, the Code, or GGS’s policies and procedures.
By promptly reporting any potential misconduct, we help GGS maintain its culture of honesty, trust, and integrity, which in turn ensures the business success of our company. Early reporting also allows those in authority to address potential issues before they escalate into serious problems.
If you have a question or concern, consider raising the issue with your supervisors. After all, they are the ones who know your work best. If you prefer not to contact your supervisors, you can report your concerns to:
- A compliance representative
- A Human Resources representative
- A legal representative, such as the Legal Counsel
- A member of the Management Team
- GGS's Ethics Hotline
By Phone: Specific phone numbers are displayed in all our locations.
GGS’s ethics helpline is managed by the Legal Department / General Management and is available 24 hours a day, 7 days a week, and 365 days a year. You have the option to report anonymously via our mobile phone numbers/email as follows:
Phone: 074249240 / 066416666
Email: G.G.S.emma@outlook.fr or G.G.S.directeurgeneral@outlook.fr
However, we encourage you to provide your contact information as it enables GGS to better investigate your report. Your contact details will remain confidential to the extent permitted by law. GGS will promptly review all reported concerns, conduct an investigation, and take appropriate action to address them.
Unethical or illegal actions not only expose our company to potential legal consequences but also undermine our ethical culture. For this reason, the company will take disciplinary action against those who violate our charter, policies, or the law, which may include termination of employment or contractual relationship.
Protecting the life, health, and dignity of all individuals without discrimination based on race, ethnicity, color, gender, language, religion, political affiliation, national origin, birth, or any other protected status.
Comply with applicable laws, standards, policies, procedures, and regulations. Act according to the highest standards of honesty, integrity, and fairness at all times. Comply with the letter and spirit of GGS’s standards and policies. Consistently do what is right. Operate transparently at all times.
Keep commitments. Strive to meet commitments and expectations. Share knowledge with peers. Commit to excellence in quality and continuous improvement of oneself, others, and the organization.
Treat others with respect and professionalism at all times with internal and external stakeholders. Be punctual. Consistently reflect the highest standards of behavior. Perform work to the best of one’s abilities. Represent GGS effectively and be a reliable example during business meetings, social activities related to business with clients, suppliers, employees, and any other stakeholders.
Coach, mentor, and develop people. Invest in one’s own development and/or the development of others by preparing them to grow within the organization. Transfer knowledge. Motivate, train, and empower others to achieve common goals and improve the organization and its personnel. Encourage and support fellow employees to reach their maximum potential.
Establish high-quality cooperation and teamwork. Contribute to a positive work environment. Embrace diversity. Seize the opportunity to build diverse teams and value their varied working approaches. Collaborate with others to accomplish tasks and goals that benefit the organization. Promote cooperation and transparency among teams, functions, segments, entities, countries, and regions.
Communicate effectively – Both in written and verbal form. Provide constructive feedback and also receive feedback professionally. Ask questions and ensure appropriate and timely follow-up.
Provide excellent customer service to colleagues and clients in problem-solving according to customer needs and the interests of the organization. Anticipate customer needs and address them in the short and long term. Execute tasks on time and provide updates according to customer expectations.
Manage and respond respectfully to actions, performances, and consequences. Take personal performances, interactions, and accountability responsibly and proactively. Support decisions, actions, and the overall well-being of the organization by completing projects, tasks, and performance expectations. Respond to superiors for their actions with respect and accountability. Accomplish tasks according to the assigned mission and job requirements, be punctual, and achieve or advance the organization’s objectives. Supervise others responsibly and professionally.
Understanding the causes of safety and environmental incidents, and implementing controls to prevent their recurrence. Taking all proactive and corrective actions related to HSSEQ. Monitoring the quality of work performance and products that adhere to standards and performance requirements. Finding ways to continuously improve the quality of products and services.
Supporting continuous improvements in procedure safety. Adhering to safety programs and procedures to ensure facilities are secure, equipment is maintained, and appropriate operating procedures are in place.
Effectively lead and enhance the vitality of the company. Define, establish, monitor, and be effective in adding value for customers, employees, and the community. Demonstrate business acumen (in terms of finances, budgets, etc.). Find ways to reduce costs and increase profitability appropriately. Show initiative, creativity, and entrepreneurship to help GGS improve and succeed at all times in all areas of operation.
GGS and its employees consistently comply with all applicable laws and regulations of the Gabonese Republic. Any activity that may lead the company into illicit practices is strictly prohibited. Regarding taxation, GGS commits to providing all necessary information to tax authorities and to publishing transparent reports on its tax payments.
GGS and its employees promote respect for the physical, cultural, and moral integrity of its collaborators and partners. The company prohibits all forms of discrimination based on illicit grounds such as gender, age, customs, actual or perceived belonging to a specific ethnicity or nation, health status, disability, religion, political beliefs, or union activities. Any form of psychological, physical, or sexual harassment is prohibited.
GGS and its employees strive to cultivate a culture of health and safety for workers in their workplace. The company promotes – by ensuring stakeholder buy-in and commitment – the implementation of best practices based on compliance with both internal and regulatory requirements. This corporate culture is founded on the concept of continuous improvement and aims to identify and manage risks optimally.
GGS encourages its clients, suppliers, and intermediaries to adopt its principles or equivalent principles in this regard.
GGS and its employees ensure uniformity and consistency of management wherever the company is present, while respecting local cultures and legislation. The company contributes to local employment development in the countries where it operates. Additionally, it commits, either contractually or voluntarily, to programs of development that address the needs of local communities. GGS adheres, in the conduct of its activities, to the respect of local and national communities, by fostering dialogue with local trade unions or other associations.
GGS and its employees strive to preserve natural areas that may be affected by its activities. To this end, a system aimed at reducing costs and working towards long-term sustainable development and waste reduction is implemented across our various sites.
Therefore, each project is carried out in compliance with local regulations and undergoes an impact assessment resulting in the implementation of risk management plans. The company raises awareness among its staff as well as local communities regarding environmental protection and sustainable development. It encourages its clients, suppliers, and intermediaries to adopt its principles or equivalent ones.
It is vital for GGS to be perceived as independent and capable of identifying and managing conflicts of interest. Besides legal and regulatory concerns, conflicts of interest can also impact the company’s reputation and its relationships with clients, suppliers, and partners.
Therefore, GGS attaches great importance to identifying, avoiding, and appropriately managing conflicts of interest, whether they are actual or potential.
The awarding, negotiation, and execution of public or private contracts must not give rise to behaviors or actions that could be deemed as active or passive corruption, or complicity in trafficking of influence or favoritism. The corruption of foreign public officials in international commercial transactions is prohibited. Any financial transaction involving assets, funds, or monetary instruments promoting or directly or indirectly resulting from criminal or terrorist activities is prohibited.
The resources of the company are intended to enable GGS employees to achieve the company’s objectives. Misuse or waste of such resources, including working time, harms the entire company and adversely affects GGS’s financial and industrial performance. Employees are committed to preserving and protecting these resources and keep in mind that all assets and documents of the company belong to GGS.
No illicit infringement on fair competition is tolerated within GGS. By violating these rules, companies, their executives, or employees expose themselves to severe civil or criminal penalties, in addition to potential sanctions that GGS may impose.
GGS is committed to full, fair, and transparent disclosure of information to the market, auditors, and regulators. The company operates, in terms of accounting, in strict compliance with applicable laws and regulations concerning financial statements preparation, as well as mandatory administrative and accounting documentation. The recording of management actions, information, and data of GGS are conducted according to criteria of transparency, accuracy, precision, and completeness.
In order to more effectively address transportation issues, including driving on various sites, GGS allows its personnel to assess risks and resolve them by providing training in defensive and preventive driving.
- The act of promising, offering, or consenting (active corruption) to a third party, as well as the act of soliciting or accepting (passive corruption) from a third party.
- Directly or through another person,
- An undue advantage (gifts, presents, favorable decision, etc.),
- For oneself or for another
- To facilitate, accomplish, or refrain from carrying out an act.
- The act of promising, offering, or consenting to a third party (active influence trafficking), as well as the act of compromising oneself by soliciting or accepting (passive influence trafficking),
- An undue advantage (money, payment disguised as consultancy fees, favor, gifts, etc.),
- So that the third party uses their influence with an authority.
- Pour faciliter, accomplir ou s’abstenir d’accomplir un acte.
- Be capable at all times of being able to justify acting in good faith, prudence, and transparency (subject to trade secrets).
- We must ensure that the remunerations and sums paid to suppliers and intermediaries for supplies and services are in accordance with market conditions and adequately documented.
- Inform our business partners of our standards so that they commit to respecting them, especially when they are expected to assist or represent us in countries where the risk of corruption is high.
- Ensure strict compliance with internal control procedures and other applicable internal and international accounting standards in order to detect any possible acts of corruption that may be concealed.
- Reflect in the accounts a faithful and sincere record of the operations carried out by GGS.
- Offering, accepting, or promising any illicit advantage or payment to influence the outcomes of a business decision.
- Accepting cash payment or any sum of money that is not justified and not traceable.
- Using donations made to a foundation or association for purposes of corruption.
- Engaging a third party to perform a task that we cannot legally perform ourselves.
- Making a facilitation payment, meaning an unofficial payment, made to execute or expedite certain administrative procedures (permit requests, customs clearances, etc.).
1) I need to urgently obtain the delivery of materials to intervene on a damaged drilling rig. Customs clearance may take too long. The situation is urgent, and the customs agent suggests bypassing the procedure in exchange for a small payment.
THE BEHAVIOR TO ADOPT
I refuse the proposition and inform my immediate superior. Making a facilitation payment or an unofficial payment to execute or expedite an administrative procedure is strictly prohibited by GGS, regardless of the circumstances. Any payment to a third party must be justified by a legitimate reason (contract, tax, etc.).
2) A consultant who claims to be capable of assisting GGS in “resolving certain difficult situations” contacts me, while we are struggling to obtain certain authorizations from the Ministry of the Environment.
THE BEHAVIOR TO ADOPT
As with any new contract, I conduct necessary checks to ensure his reputation and any potential links to politically exposed persons, in accordance with the applicable third-party evaluation procedure. The consultant’s mission could involve indirect payments to a public official, for example, to obtain a desired decision. Therefore, the utmost vigilance must be exercised.
- Any material benefit offered or received in the context of a social or professional relationship, intended to elicit sympathy or interest.
- Any intangible benefit offered or received in the context of a social or professional relationship, intended to elicit sympathy or interest.
- Adhere to the guiding principles outlined in the "Gifts and Invitations" policy of GGS.
- Ensure that the gift or invitation complies with local and international legal standards.
- Be mindful of the context and the interpretation that a gift or invitation may carry. It should not imply any expectation of reciprocity.
- Offer a gift or invitation that does not exceed a value that the recipient would not be expected to repay.
- Offering or receiving a gift or invitation with the intention of obtaining an undue advantage.
- Offering or receiving a gift or invitation with the intention of securing a contract or decision in our favor in the context of a tender process or public decision.
- Offering or receiving a gift or invitation with the intent to influence a decision or action of the recipient.
- Offering or accepting gifts in secret.
- Offering or accepting any sum of money.
A government official is presenting a new public policy to one of our subsidiaries. I wish to continue the discussion with him on this topic and invite him to lunch to thank him for his time.
THE BEHAVIOR TO ADOPT
As with any gift or invitation to a public official, I request prior authorization from my immediate superior, copying the compliance reference of my entity, or if unavailable, the Compliance Department of GGS.
- A personal interest or the interest of individuals to whom we are connected,
- interferes, is likely to interfere, or may give the impression of interfering,
- with the tasks assigned to us as employees.
- Demonstrate loyalty to GGS.
- Refuse any involvement with a competitor, supplier, or client.
- Report any potential conflict of interest situation to our hierarchy.
- Avoid any professional activity outside of the company, except with prior written authorization from our hierarchy if we have a full-time employment contract.
- Inform and seek advice from our hierarchy and/or the Compliance Department of GGS before proceeding with any action that presents a potential conflict of interest.
- Participate in decision-making in a conflict of interest situation.
- Retain or contribute to retaining, for a contract, an entity in which we or one of our close relatives have an interest.
- Use or share confidential information about the company for our personal interest or that of a close relative.
- Conceal information about any conflict of interest, even potential ones.
I am responsible for the quality, hygiene, safety, and environment mission within GGS. I recently learned that one of my relatives has been appointed as a labor inspector, and he informs me that he will soon be conducting a visit to one of the sites where GGS operates.
THE BEHAVIOR TO ADOPT
Any situation that could give the impression that my private relationships could interfere with my professional life must be handled with the utmost transparency. Therefore, it is imperative to inform my immediate superior and the management of my connections (family, friends, networks) with public officials or agents so that GGS can take the necessary steps to resolve the potential conflict of interest.
WE ENSURE TO ESTABLISH BALANCED RELATIONSHIPS WITH OUR CLIENTS, SUPPLIERS, AND INTERMEDIARIES. WE MAKE OUR CHOICES BASED ON CRITERIA OF COMPETENCE, PROFESSIONALISM, COST, AND TRANSPARENCY.
- Apply verification measures for third parties, clients, suppliers, partners, or intermediaries before entering into a relationship.
- Ensure that relationships with public authorities are transparent and sincere.
- Monitor activities and expenses related to lobbying efforts or representation of interests, as well as other meetings with public representatives.
- Ensure that clients, suppliers, partners, and/or intermediaries have a good reputation according to the criteria outlined by GGS or our local policy (where applicable).
- Contact the Compliance Department in case of identification of any of the warning signals or red flags outlined by GGS or in our local policy (where applicable).
- Conduct sincere and faithful accounting follow-up of expenses and activities related to lobbying efforts or other meetings with representatives.
- Avoid, to the extent possible, entering into contractual commitments that could create dependence for the client, supplier, partner, intermediary, or for GGS.
- Offering or receiving a gift or invitation with the intention of influencing a favorable decision for the Group from an authority or public administration.
- Engaging in an action that could create suspicion that the action may have been intended to obtain an undue advantage or influence decisions of the relevant individuals or administrations.
- Offering, promising, or granting payments or benefits on behalf of and/or for the account of GGS in favor of political or trade union organizations or their representatives, except when permitted and provided for, and within the limits set by applicable laws and regulations.
- Undermining the traditions or cultures of the country where we operate.
ALL GGS INFORMATION SYSTEMS AND THE DATA STORED THEREIN ARE THE PROPERTY OF THE COMPANY, AS WELL AS ANY OTHER DATA STORED ELSEWHERE.
DATA AND INFORMATION SYSTEMS ARE ESSENTIAL ASSETS, AND EMPLOYEES, CLIENTS, SUPPLIERS, AND INTERMEDIARIES MUST ALWAYS USE THEM RESPONSIBLY. EMAIL AND INTERNET SERVICES ARE PROFESSIONAL RESOURCES.
EMPLOYEES, CLIENTS, SUPPLIERS, AND INTERMEDIARIES ARE ALSO INFORMED THAT DATA STORED OR TRANSITING THROUGH THE COMPANY’S INFORMATION SYSTEMS MAY BE SUBJECT TO AUDIT OPERATIONS CONDUCTED BY THE HUMAN RESOURCES DEPARTMENT, THE IT DEPARTMENT, AND/OR EXTERNAL SERVICE PROVIDERS OF GGS.
- Always respect confidentiality obligations regarding information concerning the company.
- Protect our reputation, the reputation of the company, and its leaders. Use company assets diligently, solely for the purpose of carrying out the missions entrusted to us, in the strict interest of GGS and in compliance with applicable laws.
- Use information systems, email services, and the internet in a measured and appropriate manner, and avoid any misuse.
- Use computer services for personal purposes in limited proportions.
- Ensure moderate use of social networks.
- Be familiar with and adhere to internal procedures regarding authorizations, leaves, and expense reimbursements, providing appropriate documentation in the latter case.
- Not to interfere with the performance of our duties or the interests of the company when using GGS computer services for personal purposes.
- Allowing our use of social networks to interfere with the performance of our duties.
- Using the name and reputation of GGS for personal purposes.
TO ENSURE COMPREHENSIVENESS AND CONSISTENCY OF INFORMATION, GGS’S REPORTS TO PUBLIC INFORMATION BODIES ARE RESERVED FOR THE COMPANY’S APPROPRIATE DEPARTMENTS. THESE OBLIGATIONS REMAIN EVEN AFTER THE EMPLOYEE’S DEPARTURE FROM GGS.
GGS’s insider trading policy is available on the GGS intranet.
- Respect the confidentiality of sensitive information.
- Understand and apply all provisions regarding the security and dissemination of information concerning GGS.
- Adapt our behavior to ensure the highest possible level of confidentiality outside of working hours.
- Backup technical, financial, legal, administrative, and human resource management data and know-how of the company.
- Respect intellectual property and industrial property rules.
- Avoid using or disclosing confidential and privileged information orally, in writing, or electronically, unless expressly delegated or authorized by the hierarchy.
- Refrain from disclosing any confidential information obtained in the course of the company's activities.
- Do not disclose false or biased information related to GGS.
- Do not exert any form of pressure to obtain favorable attitudes from the public communication/information bodies.
A Code of Conduct and Ethics is made available to GGS staff at all our locations. After becoming familiar with its content, awareness sessions are conducted for all personnel working for GGS.
GGS provides employees with an ethics and compliance alert system, allowing each employee to report, in particular, any violation of the rules of this Charter, but also more generally to be a player in risk prevention.
Any employee or occasional external collaborator of GGS (interns, service providers, etc.), as well as its clients, suppliers, or intermediaries.
The employee or partner directly communicates any breach of our code of conduct to the Compliance Department of GGS managed by the legal department at the following email addresses:
– G.G.S.emma@outlook.fr
– G.G.S.directeurgeneral@outlook.fr
GGS garantit la stricte confidentialité de l’identité du lanceur d’alerte, de la ou des personnes mises en cause, ainsi que des informations recueillies, sauf dans le cas de demandes émanant d’autorités judiciaires.
GGS garantit une protection contre toutes représailles ou mesures discriminatoires, à tout alerteur qui signale de manière désintéressée et de bonne foi un fait dont il a eu personnellement connaissance, en respectant les règles inscrites dans la présente Charte.
Tout salarié ayant procédé à un signalement de mauvaise foi est susceptible d’encourir des poursuites pénales et des sanctions disciplinaires de la part de GGS
GGS is committed to informing the whistleblower of the outcome of their report within a reasonable period as provided by law. After assessing its admissibility, the alert is processed within two months. This period may be extended if necessary to finalize the investigation, in agreement with the whistleblower. The whistleblower will be regularly informed of the progress of the processing. In all cases, the handling of the alert is carried out in accordance with the applicable rules for the processing of personal data.
I observed a situation that I suspect may be a violation of GGS’s anti-corruption policy.
BEHAVIOR TO ADOPT
As an employee of GGS, I must contribute to the dissemination of the company’s ethical values and compliance with laws and regulations. I am required to report the observed facts to my supervisor. I can also bring these facts to the attention of GGS through the whistleblowing mechanism, which ensures strict confidentiality of your identity.
Any action taken in violation of this Ethics Charter may result in disciplinary sanctions. It would constitute misconduct justifying the application of disciplinary sanctions, without prejudice to legal actions that may be initiated by the company.
Any action taken in violation of applicable laws and regulations regarding the fight against corruption is also liable to result in disciplinary and criminal sanctions for the involved employee and criminal sanctions for their employer (examples: financial penalty, imprisonment, exclusion from public contracts).
The appropriate sanctions and legal actions will be those provided for by applicable law for the concerned employee and will be taken in accordance with applicable legal procedures, including respect for the rights and guarantees applicable to the concerned employee.
Such sanctions could include, in accordance with applicable law, dismissal for misconduct and claims for damages initiated by Gabon Générale Services (GGS), even if the breach of rules was detected by GGS itself as part of internal control.