The OEG Offshore group (OEG) has built a trustworthy and highly credible reputation as a leader in the provision of equipment and services to the global oil & gas industry. In pursuing legitimate business opportunities, OEG vigorously maintains a commitment to comply with the antitrust and competition laws of all countries which are applicable to the business.

Our reputation, credibility and business ethics are of great importance and is the result of years of hard work by  our Employees. OEG has adopted a Zero Tolerance approach towards any breaches of this Competition Compliance Policy, an approach which is fully supported by the OEG Executive Board.

OEG is committed to ensuring that all of its activities are conducted in accordance with all applicable legal and regulatory requirements and the highest standards of ethical business conduct. It is the responsibility of all OEG employees to ensure that OEG’s businesses do not engage in practices which infringe legal or regulatory requirements or which fall below the highest standards of ethical business conduct.

Introduction to Competition Law

Competition law is also known as anti-trust law in the United States, and as anti-monopoly law in China and Russia. In previous years it has been known as trade practices law in the United Kingdom and Australia. In the European Union, it is referred to as both antitrust and competition law. Anti-competitive conduct constitutes an administrative offence in many jurisdictions for both the individual and their employer. In some jurisdictions, it is subject to criminal prosecution.

Although these laws differ in some respects, they generally address similar kinds of conduct and share a common underlying philosophy. The common theme is that competition benefits consumers by providing the best products at the lowest prices. The antitrust and competition laws operate to prevent competition from being undermined by anti-competitive practices, such as cartels and abuse of market power.

OEG is committed to a competitive market and the prevention, deterrence and detection of any violation of applicable competition laws. In many areas of competition law there is a fine line between remaining within the bounds of the law and overstepping it. Some practices often require scrutiny before being implemented. OEG cannot relieve its employees from the responsibility of carrying out this assessment, as it is often necessary to review the circumstances of each particular scenario. In case of doubt, employees must always consult their immediate line manager and/or regional director.

Additional Resources
Wikipedia : US Anti-Trust Law https://en.wikipedia.org/wiki/United_States_antitrust_law
Wikipedia : EU Competition Law https://en.wikipedia.org/wiki/Competition_law
UK Government : https://www.gov.uk/cartels-price-fixing
Consequences of a breach

Competition law protects free and open competition from restrictions that may be brought about by companies. Competition law makes sure it also protects OEG against anti-competitive practices of other companies & countries.

The basic two core prohibitions of EU competition law are:

  • Restrictive agreements and concerted practices - agreements which may affect trade and have, as their object or effect, the prevention, restriction or distortion of competition; and
  • Abuse of a dominant position – anti-competitive conduct by companies that hold a significant share of the market.

Comparable provisions can also be found in the national laws of all EU Member States and over one hundred other countries. The application of competition law is primarily based on the economic effects of conduct in the market place, and the prohibitions will only apply (subject to exceptions) if the activity at issue has an “appreciable effect” on competition. However, there are certain “hard core” infringements – such as price fixing, bid rigging, limiting capacity, or market sharing, which are always capable of having an appreciable effect on competition and will therefore breach competition law. We have covered these points in more detail in the Competition Law Compliance Guide for all employees.

Competition law is designed to ensure that companies compete fairly with each other and that there is ‘a level playing field’ and transparency. Failure to comply with competition law can have serious implications for a business, including large fines. Certain serious breaches of competition law may also expose an individual to the risk of criminal prosecution.  

How to comply with competition rules in practice

OEG employees must comply with applicable local competition laws. It is imperative not only to comply with competition law, but also to take the necessary measures to avoid any situation that might erroneously lead others to suspect incorrect behaviour. In this respect, tight control over internal and external communication is essential. It is a common error to think that oral communication cannot be traced or that totally informal or personal notes (handwritten notes in the margin of a document, post-it, agendas, e-mail, instant messages) are devoid of any possible legal consequences.

We have incorporated a "DO's & DONT's guide within our Competition Law Compliance Guide to increase awareness and ensure that the rules of competition law are complied with in order to avoid any risks of sanctions on the company or on individuals.

Every employee is personally responsible for complying with the applicable provisions of competition law and OEG's Policy. In general, employees shall:

  • Refrain from any agreements or coordination with a competitor that could reduce competitive pressure between OEG and the competitor;
  • Refrain from any exchange of information that would make it possible to draw conclusions about the current or future market conduct of OEG or the competitor.
  • It is particularly unacceptable for Employees to:
  • Enter into an agreement with a competitor on or otherwise coordinate price related issues, sales quantities or quotas, market shares, the allocation of sales territories or customers or the handling of customer or supplier claims;
  • Exchange information with a competitor on banned or critical topics. 

More details on OEG expectations are included in our Competition Law Compliance Guide.

By doing business with integrity

Our reputation, credibility and business ethics are of great importance and is the result of years of hard work by all our Employees. OEG has adopted a Zero Tolerance approach towards any breaches of this Competition Compliance Policy, an approach which is fully supported by the OEG Executive Board. It is the responsibility of all OEG employees to ensure that they report any infringement or suspected infringement of legal or regulatory requirements or the highest standards of ethical business conduct involving OEG to their line manager or otherwise in accordance with the OEG ‘Whistle Blowing’ Policy.

Our Competition Law Compliance Policy applies to all entities and businesses within OEG and each business entity will seek to adopt and promote practices that are consistent with the principles set out in the policy. Within OEG, the responsibility to reduce the risk of anti-competitive conduct resides at all levels of the organisation.

Other Relevant OEG Information 
Supplier Code of Ethics Policy - OEG-Global-Pol-005
Employee Code of Conduct - OEG-Global-Pol-009
Anti Bribery and Corruption Policy - OEG-Global-Pol-001 
Competition Compliance Policy - OEG-Global-Procd-012