Corporate Social Responsibility

The Board believes doing business in a responsible and sustainable way is an integral part of doing business successfully.  Emerald is committed to managing its operations and business activities in a responsible manner with due consideration of its shareholders, employees, partners, contractors, and the local communities and environment in which we conduct business.

The Board is responsible for agreeing the corporate social responsibility (“CSR”) policies; senior management monitors performance and ensures appropriate action is taken when and where necessary.  The Board meets periodically to review the CSR policies, performance on CSR objectives and to assess the related opportunities and risks which may affect the company’s business and ultimately the short and long term shareholder value.

Senior management, with their knowledge of the company’s operations identify those CSR objectives that they believe are material in the good conduct of its business.  Once the objectives are evaluated and mitigation actions agreed for any identified risks, the objectives are incorporated into the management performance monitoring programme, the results of which are regularly reviewed by the Board.

BUSINESS ETHICS

Policy:  Emerald manages its operations and business activities in an ethical manner and is committed to conducting our business with integrity, honesty, fairness and not offering or accepting bribes, whether directly or indirectly, to gain business advantage.

Bribery is the giving or receiving of money, a gift or other advantage as an inducement to do something that is dishonest, illegal or a breach of trust in the course of doing business. Gifts and entertainment of a deminimus and infrequent nature are permitted. Facilitation payments are not permitted.  Small value charitable contributions and sponsorship may be made to bone fide organisations only.  Political donations are not permitted.

Persons with a possible real or perceived conflict of interest report such to senior management who determine if that person is permitted to continue to participate in the relevant business process.

A breach of any of the Company’s Business Ethics will result in disciplinary action and in the case of Emerald employees may result in the termination of the individuals’ employment. 

We expect our business partners, contractors and suppliers to abide by our business principles.

Performance:  During the year there were no occasions when poor business ethics were reported to have occurred. Employees were encouraged to report any form of business malpractice under the whistleblowing procedure.

SHAREHOLDERS

Policy:  Emerald is committed to conducting its business activities in a responsible manner with due consideration to shareholders.  Key elements of this policy are to be accountable to shareholders; provide clear communication with shareholders; meet regularly with major shareholders; act with integrity towards all shareholders and prospective shareholders; and treat all shareholders equally and fairly.

Performance:  The Chairman, CEO and Senior Independent Director met with major shareholders on a quarterly basis after the release of annual and half-year results and interim statements.  The senior management responded to ad hoc requests to meet with new and existing shareholders during the year and the Chairman and CEO presented at industry specific conferences.  Copies of all presentations used were made available on the website.

EMPLOYEES

Policy: Emerald Energy is committed to being an equal opportunities employer with recruitment, remuneration and career progression not influenced by race, gender, marital status or disability.  In the implementation of this policy, Emerald is committed to ensuring that all employees are given employment contracts with clear and fair terms; remuneration levels are sufficient to attract, motivate and retain staff; all staff be offered access to relevant training courses and encouraged to take up membership of appropriate professional bodies to enhance competence and career development

Performance: The Company promoted workforce diversity and has continued to build its business unit in Colombia by recruiting staff from the region.  Salary levels were determined with the assistance of salary survey data and all staff who participated in their relevant bonus schemes were awarded bonuses for meeting the pre-determined targets, including HSE KPI’s.

HEALTH, SAFETY AND ENVIRONMENT

Policy: The Company is committed to managing the integrity of its operations and business activities in a responsible manner with due consideration to its stakeholders and the environment in which we conduct business.  In all our activities, we recognise that proper management of HSE is important to the business and we are committed to complying with all local HSE legislation and regulations, and where laws or regulations do not exist, applying responsible standards; maintaining a safe place of work for our staff and contractors and creating a positive HSE culture within which to work; minimising any impact of our operations on the environment; delivering, where possible, benefits to the local communities; and regularly reviewing our HSE performance and introducing improvements where appropriate.

The Chief Executive Officer is accountable for the HSE performance of the Company.  It is the responsibility of all personnel who work for Emerald to ensure that they manage HSE issues in accordance with this policy and supporting management systems at all times.  Health, safety and environmental performance is monitored and regularly reported to the Board of Directors of the company.   Emerald will ensure that the necessary resources are provided to support this policy fully and seek continuous improvement in performance.

Performance - Health: All employees involved in Emerald operated projects received both training and where necessary treatment, in occupational health matters.

Performance - Safety: The three key performance indicators used to monitor accidents are (a) fatal accidents in the workplace; (b) lost time incident frequency, calculated as the number of lost time incidents divided by the number of million hours worked; and (c) lost time incident severity, calculated as the number of days lost through lost time incidents divided by the number of lost time incidents.  The results for 2008, covering both staff and contractors in the operated Colombia business unit, show no fatalities and a significant reduction in the frequency of lost time incidents, this improvement was due in part to the HSE processes.

During 2008 the Company and its contractors worked 1.1 million hours.

Performance - Environment: In Colombia, the Company undertook environmental studies in accordance with the established local regulatory guidelines prior to conducting operations and complies with all commitments made in the environmental studies and associated permitting process.

The regulatory authorities in Colombia have a well developed environmental permitting and monitoring system which applies to oil and gas exploration and production activities.  An environmental license must be obtained prior to any well drilling activity and maintained through production activities.  Environmental permitting is not required for seismic surveys as they can generally be conducted without significant environmental impact.

The identification and protection of forests comprise one component of the environmental permitting and monitoring system.  Emerald has license areas that contain areas with forests; these areas cover parts and not all of these licenses. The environmental permitting process classifies the areas of forests, and identifies those restricted areas in which drilling will not take place.

Emerald further developed its infrastructure for the disposal of the water produced with oil from its wells in the Company’s fields, meeting or exceeding regulatory requirements.  These developments included an increase in the capacity and performance of the water handling system for the fields within the Campo Rico and Matambo blocks.

SECURITY AND HUMAN RIGHTS

Policy: Emerald is committed to maintaining the integrity of the Company’s reputation and the security of the Company’s personnel and assets through appropriate security arrangements.  The Company supports the Voluntary Principles on Security and Human Rights developed by the governments of the United States and the United Kingdom, companies in the extractive and energy sectors, and non-governmental organisations to guide companies in maintaining the safety and security of their operations within an operating framework that ensures respect for human rights and fundamental freedoms. 

Performance: In Colombia, the security of personnel and assets is achieved through a combination of community programmes, security procedures and the support of State armed forces arranged with the Ministry of Defence.  During 2008, there we no security incidents.

COMMUNITY

Policy: Emerald aims to be a good partner in the communities in which the Company operates and to promote the same awareness in the non-operated projects.  In implementing this policy, the Company structures, where possible, projects that benefit both the Company and the communities in which the projects are located; promotes and supports projects that strengthen the communities, provide sustainable local development, facilitate the improvements in the quality of life of the community and foster self-management in the community to improve its welfare in a conscious, autonomous and responsible manner.

Performance: The Company continued its hiring of Colombian nationals as both staff and field operating personnel with preference to hiring from within the local areas adjacent to its operations.  Emerald gave priority to the local regions, where possible, when procuring goods and services, particularly when fulfilling commitments to the communities and authorities for local development.  Community projects during 2008 have included acquisition of an ambulance jointly with a local hospital in Gigante, supporting a one year training programme in agro-ecology for nine people from our areas of operations, improvement of 150 hectares of grassland, provision of musical instruments for children, and continuation of the campaign Healing the Children that benefited 170 children in 2008. A consultation process was conducted with the indigenous population in the more remote areas of the Maranta and Agerato blocks in the Putumayo basin prior to the acquisition of seismic data and drilling in those areas.

WHISTLEBLOWING

Policy: Emerald is committed to a culture of openness in which employees can report legitimate concerns without fear of penalty or punishment; incidents involving the following should be reported, a criminal offence, miscarriage of justice, failure to comply with a legal obligation, failure to comply with Emerald’s regulations, danger to health or safety, damage to the environment, financial malpractice, and actions likely to harm the reputation of the Company. Concealment of any of these reportable issues should also be reported.  All allegations should be made in good faith and be reported either to a line manager or made anonymously via the whistle blowing procedure.  Any misconduct or malpractice within the workplace is taken extremely seriously. Any knowingly false or malicious allegations will result in disciplinary actions against the individual making them.  The principles and procedure are in line with the Public Interest Disclosure Act 1998 (PIDA) and applies to all part time and full time employees and contractors of Emerald.

Performance: New employees have been briefed on the policy.   An email address has been set up to allow employees to raise concerns anonymously and all reports are forwarded to the Chairman and the Senior Independent Director.  During 2008 there were no material whistleblowing reports received.