To address the significant risks inherent to its activity, CGG, a leading Geoscience company primarily involved in the Oil & Gas industry and operating in over 40 countries, has carried out a campaign to strengthen anti-corruption efforts. To obtain formal recognition of the significant progress made in this field, to benchmark its Anti-Corruption Program and to identify areas for further improvement, Mazars and ADIT were called upon to review their Anti-Corruption Program.
Over several months, the Mazars team analyzed the Group practices, intervening on several continents. At the headquarter level, more than fifteen interviews were conducted with high-level executives and almost 200 inspection points related to on-site control; operations and flow analysis were controlled within the Group’s subsidiaries according to Mazars-ADIT Anti-Corruption Certification framework. The review encompassed key issues related to corruption prevention and examined compliance with applicable statutory and regulatory provisions (FCPA, French Law, UK Bribery Act). The review, based on industry best practices, focused on five key areas:
- Control Environment: corporate culture, tone at the top, ownership, awareness and commitment related to the anticorruption effort.
- Risk Management: identifying and assessing corruption risks and communicating the results of those assessments.
- Control Activities: preventing and detecting potential corruption related to commercial consultants, gifts and hospitality, sponsorships and charity and to supplier relationships.
- Monitoring: regular monitoring of incidents and the functioning of corruption controls.
- Communication and Training: company-wide communication of policies and guidelines; training and awareness programs to support anti-corruption policies.
The Anti-Corruption Program review provided CGG with a solid benchmark for its Program. If no blocking point was identified during this review, several areas of improvement were identified related to organization, procedure and documentation to further strengthen the Program. In May 2014, CGG received the sought-after assurance report, “the Anti-Corruption Certificate”, in which no major discrepancies have been noted between the CGG Anti-Corruption Program and the Mazars-ADIT Anti-Corruption Framework®. This assignment has also allowed our client to telegraph a strong and clear signal to its clients and shareholders.