Integrity channels

Procedure for reporting of misconduct and improper activities
(Whistleblower procedure)

Why do we have an Integrity channel?

North Atlantic Drilling treasures openness and transparency. Openness is the premises for trust and confidence. We are judged by whom we are and how we act: our reputation is upheld by how we put into practice our core values of safety conscious, accountability, inspirational, loyal and proactive. These values underpin The North Atlantic Drilling Key Principles for Business Conduct and The North Atlantic Drilling Code of Conduct. We have established an integrity channel to allow employees and stakeholders to raise concern and report instances of potential non-compliance with our values and principles.

What is an Integrity channel?

The Integrity channel enables North Atlantic Drilling employees and others to raise concerns about improper activities or misconduct, in full confidence and without fear of retaliation. Improper activities may be:

  • Workplace health, safety or environmental violations
  • Financial misconduct
  • Falsification of accounting records
  • Improper payments
  • Fraud
  • Workplace harassment
  • Bribery and corruption
  • Kick-back arrangements
  • Money laundering
  • Failing to protect intellectual property
  • Failing to protect privacy data
  • Insider trading
  • Other violations of the North Atlantic Drilling Code of Conduct

To raise a concern is beneficial to every single employee, the company and to the society as a whole, because improper conditions can be corrected. There are a number of reasons for reporting your concern. Every employee has a duty to report their knowledge of incidents of misconduct or conditions where life and health is put at risk or incidents or practices in breach of our Code of Conduct. Employees and others who raise their concern is an important asset to North Atlantic Drilling.

Who can use the Integrity channel?

The Integrity channel is for all employees in North Atlantic Drilling and for third parties with whom North Atlantic Drilling has a business relationship (customers, suppliers etc.) However, this facility is not for customer services complaints or enquiries. Please contact your local North Atlantic Drilling office for customer related issues.

How to raise a concern?

North Atlantic Drilling has established a 24 hours a day, 365 days a year Integrity channel. Reports through this channel are received on behalf of North Atlantic Drilling by an independent third party specialist, the Integrity Services unit at the accounting and advisory firm BDO AS. There are three external ways to submit a report:

  1. You can fill in a form to submit your query of concern by clicking this link: English, Norsk
  2. Send an email to BDO Integrity Services: integrity@bdo.no
  3. Send a letter to BDO Integrity Services, P.O. Box 1704 Vika, 0121 Oslo, Norway

BDO Integrity Services will handle all submissions with confidentiality. When raising a concern (whistleblowing) to BDO Integrity Services, you also have the option to remain anonymous. However, it will be easier to conduct an investigation and other follow up activities will more likely be successful if the person reporting gives his/her identity.

North Atlantic Drilling employees may also contact their supervisor or another member of senior management. All employees should feel free to discuss any suspected violation or concern with their supervisor or any other member of senior management or the company's Compliance Officer ph. 00 47 51 30 95 96

What happens with the complaints received?

All complaints received will be taken seriously and will be handled in an appropriate manner. The identity of the person reporting will always be handled with confidentiality. BDO Integrity Services will validate the reported concern and make an initial report to North Atlantic Drilling.

Anonymity

To raise a concern in confidentiality to BDO Integrity Services means that BDO Integrity Services employees have an obligation by law to keep your identity hidden. The exception is if a judge in court demands the identity of the source. To report with complete anonymity means that no one will know who the source is.

Regarding anonymity, you have three different options when you communicate;

  1. Remain completely anonymous to all parties.
  2. Identify yourself to BDO Integrity Services, remaining anonymous to North Atlantic Drilling.
  3. You can provide your name and contact details.

When you send the form, the transmission is handled by and goes through a fourth party supplier (Questback) before it is received by BDO Integrity Services. Questback delivers the electronic solution on secured lines and they remove all electronic evidence making it impossible to trace the source sending the form.

All complaints directed to BDO Integrity Services will result in a report which will be passed to North Atlantic Drilling, respecting and reflecting the degree of anonymity you have chosen.

What happens to a report when received by North Atlantic Drilling?

Your report, when processed by BDO Integrity Services, will be passed to The Compliance Officer in North Atlantic Drilling who will assess the report and allocate to the Audit Committee to decide appropriate action. If the report is in the nature of an allegation that requires careful investigation, an investigation team will be assigned.

If the reported incident requires expertise not available within North Atlantic Drilling, an outside expert may be involved under similar strict confidentiality. The investigation will focus on an objective, factual analysis of the case.

Within reasonable time, the person raising concern and reporting instances of potential non-compliance shall receive a reply. Without revealing any sensitive information this reply shall contain information about how the case has been treated and the outcome. If it becomes clear that the reported instance was within acceptable conduct or based on misunderstandings, the reporting person shall, as far as possible, be given a detailed and thorough explanation.

For every reported instance, it is important to take into consideration the interests of the person being the subject for the reported instance. North Atlantic Drilling gives priority to ensure that each case is treated with fairness. In most cases this means that the person being the subject is informed about the received concerns, is given the opportunity to present his/her version and will also be informed about the outcome of the case. If concluded that nothing improper or no misconduct has taken place, it is important to inform the person being the subject that the case is closed and brought to an end. To know that groundless accusations are raised against you can be a heavy burden.

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