A compliance roadmap for an evolving oil and gas company
Compliance, Governance | read time: 3 min
For more than five years, GoodCorporation has worked with one of the world’s largest independent oil and gas companies, supporting its evolution from a small private equity-backed enterprise into a leading global player focused on further growth through acquisition.
During this period, the company acquired numerous established energy businesses around the world, navigating the complexity of integrating legacy practices inherited from multiple organisations.
The Challenge
Rapid growth through acquisition had created a complex operating environment, with a patchwork of inherited practices embedded across various operating companies. While many of these systems were effective, there was a need to ensure consistent practice across the entire global entity.
This started with establishing a compliance function and programme that could be deployed effectively across the company’s global operations. Legacy systems, policies and procedures needed to be integrated into a coherent single way of working. At the same time, our client needed to provide assurance to the board that the new function would be sustainable, resilient and well-prepared for future growth.
Project scope
To address these challenges, GoodCorporation was engaged to develop and deliver a Compliance Programme Assessment Framework that could be used over time to evaluate and guide the ongoing development of the compliance programme as the company continued to grow and integrate newly acquired businesses.
A four-stage approach
1. Assessment and benchmarking
GoodCorporation conducted an assessment of the existing compliance programme to analyse how effectively it operated day-to-day across the amalgamated businesses and compared it with recognised standards of best practice. The programme was benchmarked against GoodCorporation’s database of more than 100 organisations, providing an objective view of its relative maturity and effectiveness.
From this assessment, GoodCorporation produced a set of recommendations to address identified gaps and areas for improvement.
2. Development of a bespoke framework
Drawing on GoodCorporation’s Integrity Compliance Framework, we developed a bespoke Compliance Programme Assessment Framework tailored to the client’s risk profile and global operations.
The framework covered all key processes related to anti–bribery and corruption, including conflicts of interest, gifts and hospitality, transparent procurement and purchasing, relationships with governments and public officials, whistleblowing and the overall governance structure for compliance matters.
At the client’s request, the scope was expanded to include a high-level review of controls relating to the facilitation of tax evasion and economic sanctions.
3. Stakeholder consultation and evidence gathering
To understand how policies had been designed, as well as how they operated in practice, GoodCorporation consulted with stakeholders across the organisation.
This included nearly 50 interviews with members of the leadership team, managers and employees. We also reviewed more than 120 documents, including policies, procedures, contracts, board materials, bank statements, registers and internal communications.
This evidence-based approach provides a detailed understanding of how compliance systems are operating in practice across different parts of the business based on how they should function.
4. Scored report and recommendations
GoodCorporation provided a scored report evaluating the adequacy of the programme against each element of the framework. The report identified strengths and weaknesses in the compliance programme, setting out clear, prioritised recommendations for action.
GoodCorporation was asked to present the findings to both the leadership team and the board helping to ensure senior– level commitment to the recommendations from the outset.
Outcome
The Compliance Programme Assessment Framework provides the company with a structured, evidence-based tool to continuously evaluate and strengthen its compliance programme as it grows in new markets and businesses. The organisation now has an objective understanding of its current position, a clear roadmap for improvement and enhanced board-l level visibility of compliance risks and controls.
The client continues to work with GoodCorporation to update the assessment as improvements are implemented and new risks emerge. In addition, GoodCorporation has supported the company through several on the ground assessments in high-risk locations, enabling the compliance team to examine critical corruption–related controls and potential vulnerabilities in local operations.
Looking ahead, GoodCorporation is working with the client to develop new ways of gathering compliance data using our digital assessment tool, GCAP. This will provide the organisation with the ability to assess and monitor compliance processes consistently and provide a dashboard-style view of its programme across its global operations.
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