Working responsibly

Ethics, anti-bribery and corruption, and transparency

The trust of our stakeholders is critical to our ability to do business. This means we must always work in an ethical and transparent way.

Ethical business

We seek to demonstrate ethical leadership both throughout our business and in our relationships with others. The way we act, day to day, supports us in realising opportunities, obtaining funding, implementing our plans, delivering value and maintaining our licence to operate.

Our position on ethical matters continues to grow in importance, with interest from investors, funding institutions and other stakeholders. Poor performance could result in negative impacts on people and communities, an inability to access opportunities and funding, and loss of reputation.

Code of Ethics

Together, our values, Business Principles and Code of Business Ethics form our integrated Group Code of Ethics, which underpins the way we work. The Code details our Company position and provides guidance on issues including conflicts of interest, bribery and corruption, political contributions, tax principles, insider trading, and competition and anti-trust. The Code is integrated into our sustainability policies and forms part of our Corporate Responsibility Management System (CRMS).

Every employee is required to sign up to the terms of the Code and abide by them in all their business activities. Internal audits conducted by independent parties regularly assess our compliance with different elements of the Code. In turn, we require contractors and service providers working on our behalf to comply with the Code, and we audit them against it to ensure consistent application.

Click here to view our Code of Ethics

Anti-bribery and corruption

Our robust anti-bribery and corruption (ABC) policies are increasingly important as we start to operate in new areas of the world where standards of transparency may be less developed. We assess our potential partners and contractors to ensure they apply compatible standards, clear expectations, and effective control and reporting mechanisms.

We have a zero-tolerance approach to bribery and corruption, as detailed in our Corporate Social Responsibility (CSR) Policy. Our ABC procedures cover a wide range of risks, ranging from facilitation payments to receipt of gifts and hospitality. Employees are encouraged to report any incident they believe may compromise our Code of Ethics through our whistleblowing procedure. They can:

  • speak directly to their regional director;
  • use a confidential phone line; or
  • contact the charity Protect.

Where appropriate, independent investigations are conducted.

Transparency and reporting
  • As a listed public company, we report transparently and openly on our business activities, in line with UK regulations and other standards, to address the wider interest of all stakeholders.
  • Relevant information and regular announcements to the investment community are provided via the investor area of our website, and through investor meetings and roadshows.
  • We also report against the Global Reporting Initiative (GRI) Sustainability Reporting Standards.


Payments to governments

Capricorn participates in the Extractive Industries Transparency Initiative (EITI), which commits oil and gas companies to transparency about tax contributions and other payments to governments.

We report payments to governments in our Annual Report and Accounts.

Report on payments to governments for the year ended 31 December 2021 – Announcement

Report on payments to governments for the year ended 31 December 2021 – Excel