CODE OF ETHICS

General Principles

SMAPE is an oilfield technology & service company committed to providing services that enhance and optimize our customers’ performance. To deliver this value to our customers, we capitalize on our culture, deep understanding of customer workflows and processes, and extensive experience in developing and deploying innovative technology solutions.

Our work is underpinned by three well-established company values that focus on people, technology and profit:

  •  People thrive on the challenge to excel in any environment and their dedication to safety and customer service local/worldwide is our greatest strength.
  • Technology and quality is the basis for our competitive advantage.
  • Determination to produce superior profits is the cornerstone for independence of action and growth.

 

Everyone in SMAPE must respect and follow local laws and the countries in which operates. But in addition to this, it’s requested dedication in maintaining the trust and confidence of colleagues, customers and shareholders as well as all others stakeholders affected by operations. If it’s clearly seen behaving in an ethical way, we enhance our reputation for integrity, which in turn helps attract and retain both customers and employees.

 

As we work and live around the world, we will come across customs and laws which may vary widely, and which may conflict with one another. Even if you are operating in a country where local laws or common practices do not come up to the same levels as those set out in this Code and our company policies, we always expect you to maintain the high standards of ethical behavior to which SMAPE is committed.

 

  •   SMAPE has essential principle and compliance with laws and regulations in all countries in which it operates.
  •   The rules of this Code shall apply without exception to SMAPE employees and all those who work for the achievement of objectives of SMAPE.
  •   All actions, operations and negotiations carried out, the behavior in general in by SMAPE employees in their work are inspired by the highest translated completeness and transparency of information, legitimacy, in formal terms, in clarity and truth of records and accounting records in accordance with applicable regulations and internal procedures.
  •   SMAPE employees actively cooperates with the authorities.
  •   All business activities must be carried out with the utmost care and professional.
  •   The relationships between employees, at all levels, must be based on fairness, cooperation, loyalty and mutual respect.
  •   All employees must know the rules of this Code.
  •   All employees have an obligation to refrain from conduct contrary to these rules.
  •   All employees are required to promptly report to the Supervisory possible breaches of the Code or any claims of infringement.
  •   Compliance with the provisions of the Code is an essential part of the contractual obligations of the SMAPE employees.

 

Violation of the provisions of the Code may constitute a breach of the obligations of the employment relationship or a disciplinary offense, with all legal consequences, also with regard to the preservation of employment and may lead to compensation for damages arising therefrom.

 

Relationships with each other

One of the strengths of SMAPE is the diversity of workforce, with men and women of many nationalities and backgrounds working together and sharing common objectives. It’s encouraged fair employment practices and it’s offered equal opportunities to all our employees regardless of race, color, age, sex, religion or national origin. Family considerations are also taken into account in any decisions about personnel matters or assignments.

All employees have to treat each other in a professional way, based on mutual respect, trust and individual dignity. This means actions or words that might come across as hostile, improper or offensive must be avoided. SMAPE does not tolerate harassment under any circumstances.

 

Relationships within the community

SMAPE people represent more than one nationality because we live and work in different countries worldwide. As a company, we believe in contributing to community economic development in particular by recruiting and training individuals from the countries in which we operate.

Wherever you come from and wherever you go, you will be seen as a representative of SMAPE, so you are responsible for behaving in a way that maintains the trust and confidence of the people around you. We actively encourage you to contribute to the social development of your community, by sharing your talents and skills, particularly to support young people’s education.

 

Business conduct

Acting ethically is not just about complying with the formal laws and regulations that govern the business. It is also about following the highest standards of quality and personal integrity. This helps to make informed business decisions and avoid inadvertent violations of laws and company policies. It reduces the risk of expensive fines and liability, as well as legal penalties, against the company and individuals. It also protects earnings and shareholder value, and provides a strong foundation to expand services and customer base.

 

  •   SMAPE business relationships is driven by principles of loyalty, fairness, transparency, efficiency and an open market.
  •   Employees and external collaborators will have to adapt these principles in all business dealings, and in those with the Public Administration.
  •   Bribes, illegitimate favors, collusion, requests for direct or indirect personal benefits for themselves or others are prohibited.
  •   It is not permitted to pay or offer, directly or indirectly, money or material benefits of any kind to third parties, public officials or private individuals, to influence or remunerate the actions of their office. Acts of normal business courtesy, such as gifts or hospitality are allowed when of reasonable value and never aimed at obtaining undue advantages; such acts and expenses arising therefrom must still be approved by the upper position and fully documented and recorded.
  •   Documentation and information produced in business relations with any other party must be accurate and truthful.
  •   External collaborators are asked to follow the rules of this Code.
  •   Professional and / or qualified external Companies with good reputations are chosen.

 

Relationship with Customers

SMAPE is committed to excellence and aims to do business in a consistent and transparent way with all Customers. Customers have to place a great deal of trust in SMAPE, particularly when it comes to handling sensitive and confidential information. A solid reputation for integrity and fair dealing is vitally important in winning and retaining this trust.

  •  SMAPE is committed to provide business relationship and services with efficiency and courtesy, within the limits of contractual provisions; these services have to meet or exceed reasonable expectations and needs of customer.
  •  SMAPE is committed to provide accurate and complete information about services that enable the customer to engage decision.
  •  SMAPE is committed to conducting all business negotiations in respect of the interest of the customer and with the utmost transparency.
  •   SMAPE is committed to respect the terms of the agreements in place with its customers.

 

Relations with Suppliers

  •   SMAPE is committed to select and manage their suppliers based on the principles of transparency, efficiency and right cost.
  •   SMAPE provides services to any appropriate provider.
  •   SMAPE is committed to obtain the cooperation of suppliers for continuous improvement of its customers relationships in terms of quality, efficiency and cost.

 

Transparency and transaction records

  •   All operations and transactions must be correctly recorded, authorized, verifiable, legitimate, consistent and appropriate.
  •   The supporting documentation of the activity should enable the easy accounting, identification of levels of responsibility, the reconstruction operation.

 

Personnel

  • SMAPE HR Office (PERS) and General Manager recognizesan are indispensable roles for the existence of the company because dedication and professionalism of employees are crucial to the achievement of corporate objectives.
  •   SMAPE recognizes to all employees the same opportunities, so that everyone can enjoy equal treatment based on merit and without discrimination.
  •   Behavior towards staff and between staff at all levels that are prejudicial to the dignity and reputation as well as insulting or defamatory are prohibited.

 

Health, Safety and Environment

  •   All activities must be performed in compliance with health and safety local laws as well as in terms of environmental awareness
  •   All employees of Smape Ltd., as part of their duties, participate in the process of risk prevention, environmental protection and protection of health and its third party.

 

Confidentiality

  •   SMAPE is committed to protect information of their employees or third parties, whether generated or obtained as part of employment or business relationships, and to avoid any misuse of such information.
  •   All employees who have come into contact as part of their job with this information must preserve confidentiality.
  •   Any dealings with the media are reserved exclusively to corporate functions delegated. Employees cannot provide information related to its work to the media themselves.

 

Relations with the Public Administration

SMAPE may deal with local Public Administration for:

  •  competitions, contests, public procurement
  •  disputes out of court
  •  requests for licenses or permits required for its activities with relevant government organizations.
  •  practices, inspections, audits related to safety and hygiene at work
  •  practices, inspections, audits related to social security issues for staff
  • practices, inspections, audits related to waste
  •  practices, inspections, audits related to grants, subsidies, loans provided by public entities.
  •  practices, inspections, audits related to tax matters

 

  •   It is not allowed to offer money or gifts to managers, officers or employees of the Public Administration or their relatives, except in the case of gifts or items of little value and never aimed at obtaining undue advantages.
  •   It is forbidden to offer or accept objects, services, benefit or favor in order to obtain a more favorable treatment in relation to any deals with Public Administration.
  •   In case of any business negotiations, application or contact with public administration, it’s forbidden to improperly influence the decisions of the party, including those of officials acting or making decisions on behalf of the Public Administration.
  •   In the specific case of a tender with public administration, it’s mandatory to operate within the law and proper business practice.
  •   Documents and information produced in connection with any activity held with the Public Administration must be accurate and truthful.
  •   Any violation (actual or potential) committed or attempted by SMAPE personnel must be reported promptly to the competent internal office/manager.
  •   SMAPE does not deliver direct or indirect contributions to political parties, movements, committees and political or trade union, except those due according to specific rules.