Scope 1 Emissions
2022 Communication on Progress
Oando PLC
Published date
June 30, 2022
No. of questions
70
Supplemental files
CEO Statement
Signed
Governance
Policies and Responsibilities
1. Does the Board / highest governance body or most senior executive of the company:
2. Does the company have a publicly stated commitment regarding the following sustainability topics?
3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Prevention
6. Does the company have a process or processes to assess risk?
Optional commentFeedback from stakeholders is reported to the Board through the formal channels of quarterly risk reporting and daily/weekly/monthly engagements of executive management with members of the Board, constituting a part of the executive management team. The Risk Committee of the Board is charged with reviewing the effectiveness of the Company’s risk management framework and processes. They conduct reviews every quarter and give feedback on oversight actions to be taken by the risk management team and executive management. The risk report is updated and collated throughout the quarter and finalised just before the scheduled board quarterly risk committee and board meetings. The final reports are reviewed by the Group Chief Financial Officer, Chief Operating Offiprotection of human rights and prohibition of all kinds of child or forced labour.ce and the Group Chief Executive Officer and thereafter sent to the Governance Office for onward submission to in the board pack to the members of the Board Risk Committee ahead of their quarterly meetings.6.1. During the assessment of risk, which business relationships are reviewed?
7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?
Optional commentOando is committed to doing business with only reputable, honest and qualified business partners and vendors. We exercise due care and precaution when evaluating business partners and supply chain vendors. We have a Know-Your Customers (KYC) Policy which is implemented across the Group, with a heavy emphasis on due diligence for our new and potential business partners as well as a continuous review of our existing business partners. Our due diligence exercise is a vigorous process which involves extensive collaboration between the Governance Office, relevant business service units, (the Requesting department, Procurement & Services , Tax and Legal Services team), as well as the company’s business partners. All business partners are screened before being engaged to transact any business with the company. Also, Oando has a human rights policy which prohibits engagement with vendors that may engage in child labour. Our agreements with suppliers and business partners also contain commitments to the protection of human rights and prohibition of all kinds of child or forced labour.7.1. During the due diligence process, which business relationships are reviewed?
Concerns and grievance mechanisms
8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?
Optional commentOando has a toll-free whistleblowing hotline as an important means of detecting fraud and wrongdoing and a necessary element of our anti-corruption system. The whistleblowing hotline is managed by KPMG on behalf of the Company, to ensure the anonymity and protection of the identity of all whistleblowers. The whistleblowing hotline is available to employees, vendors, customers, partners and all other external stakeholders. The Company’s management, also encourages the reporting of unethical or unlawful behavior, and matters related to the Company’s integrity. We implement a protection framework that not only shields whistleblowers from retaliation and reprisals, but also makes the fight against corruption and unethical practices, a credible and serious commitment. Issues reported are promptly investigated by the Compliance and Internal Audit Units. Upon completion of the investigation, a formal report is presented to the Audit Committee and senior management with appropriate recommendation / remedial actions. Feedback is also provided to the whistleblower via the KMPG hotline.8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.
Optional commentOando has a blacklisting policy, it provides staff with a practical/standardized guide on how to blacklist, suspend and/or deregister business partners that fail to meet the Company's ethical standards or contravene the Company's Business Partner Code of Conduct. Oando's whistleblowing9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?
Lessons
10. How does the company capture lessons regarding each of the following sustainability topics?
Optional commentAll directors and employees within the Group are required to undertake an annual re-certification exercise, which involves a web-based training and recertification on the Group Code of Business Conduct and Ethics. The annual re-certification process is mandatory for all directors and employees to reaffirm their dedication to the Oando's Code of Corporate Governance and Ethics and refresh their understanding and commitment to the Code. After completing the training, individuals are required to undergo a test to ensure that the information has been effectively assimilated. New employees receive training on Oando’s Code of Corporate Governance and Ethics, within the first month of employment as part of their induction programme. Where an individual fails the test, they are required to review the training information before retaking the test until they can attain the minimum standard required for the year. To maintain awareness and promote a compliant culture in the Company, townhalls, on-site training sessions, periodic electronic-based information platforms and in-person meetings and discussions with the Chief Compliance Officer and members of the Governance and Compliance Office are arranged and held throughout the year. Also, Bitesize Compliance Newsletters on topics such as Whistleblowing in the Workplace, Virtual Ettiquette, Confidentiality, etc. are circulated to all employees periodically by the Governance Office. The Governance Office also runs virtual campaigns on Compliance issues, as well as campaigns sensitizing all employees on the Company's core values and educating all employees on the Company's policies, especially on updated policies.Executive Pay
11. Is executive pay linked to performance on one or more of the following sustainability topics?
Board Composition
12. Percentage of individuals within the company’s Board / highest governance body by:
13. Do you produce sustainability reporting according to:
Optional commentOando also aligns its Sustainability Reports with the SDGSs. we recognize that the SDGs are the global priority till the year 2030. Understanding our role as a vital partner in achieving the SDGs nationally and globally, In 2015, we made it our responsibility to begin implementing it as the overarching framework through which we shape, communicate and report our strategies, goals and activities as a business till present.Data Assurance
14. Is the information disclosed in this questionnaire assured by a third-party?
Optional commentThe Company is yet to conduct a third-party external assurance for the reporting year.Human Rights
Materiality / Saliency
1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?
Commitment
2. Does the company have a policy commitment in relation to the following human rights issues?
2.1. For each human rights policy, is it:
Optional commentOando has a Nigerian Local Content Policy which shows commitment to the rights of indigenous people. It was last updated in 2021Prevention
3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?
4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?
Optional commentIn collaboration with our Joint Venture Partners NAOC, Oando has taken steps to provide access to clean water and sanitation in the communities in which we operate. Improved access to clean and safe water, along with improved hygiene practices, are critical to community health and are pivotal elements of our commitment in the communities where we operate. Access to safe water, sanitation and hygiene remains a major problem in the Country especially in the rural areas. It is estimated that over 60 million Nigerians lack access to clean water, and only about 30% of the rural population have improved water coverage. Over the years, the NAOC JV has worked closely with more than 75 communities, across its operational areas, to improve water supply and sanitation facilities. The Company has pursued the objective of ensuring the availability of drinking water in these Niger Delta communities through the provision of various water-related projects. Some of these projects include the construction and realization of boreholes; installation of electric water pumps, storage tanks and standpipes; the realization of water networks; and carrying out of awareness campaigns on water management. Furthermore, as part of Oando PLC’s commitment to achieving the right of every child to secure quality education in Nigeria, Oando Foundation was established as an independent charity to champion the cause of education beyond its host communities to every Nigerian child. Oando Foundation is committed to supporting increased access and improving the quality of teaching and learning outcomes in schools, prioritising the girl child’s needs across all our programme interventions. Our initiatives are designed to strengthen the capacity of the School- Based Management Committee (SBMC) members to reach out to children (especially girls) who are most likely to drop out of school, and their families, and to begin to provide a more protective environment. Through our advocacy efforts, we are increasing the participation and voices of women and children in the SBMC and the school development planning process. We have begun to see our advocacy efforts yield results Oando Foundation is committed to ensuring availability and sustainable management of water and sanitation for the girl child. Lack of privacy for the girl child due to inadequate facilities to support Water, Sanitation, and Hygiene (WASH) needs, especially during their menstrual cycle, is a key challenge in our communities. The Oando Foundation continues to support WASH needs in adopted schools through the provision of portable water supply, wash bays, toilets, as well as education on basic hygiene practices5. Who receives training for the following human rights issues?
Optional commentIT Security awareness sessions are anchored by the IT Productivity coaches for all departments across the Company with a focus on Social Engineering and Information Security. Also, all IT staff are constantly educated on the importance of security awareness as they represent the first call of defense for the company against hackers in order to prevent the company from being infiltrated. Rights of women and/or girls In 2021, selected employees participated in the UNGC Target Gender program. Target Gender Equality is a gender equality accelerator programme for participating companies of the UN Global Compact. Through facilitated performance analysis, capacity building workshops, peer-to-peer learning and multi-stakeholder dialogue at the country-level, Target Gender Equality will support companies engaged with the UN Global Compact in setting and reaching ambitious corporate targets for women’s representation and leadership.6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?
Response
7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?
Optional commentClean water and sanitation are vital to achieving sustainable development. Having clean water and sanitation means being able to avoid exposure to countless diseases. Oando is committed to increasing the potable water footprint in its host and impacted communities continuously. In the reporting year: We reactivated 20,000 gallons of water for Obrikom community. The provision of the water facility enhanced the people’s good health, free from water-borne diseases, and provided access to affordable water for all in line with SDG6.8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.
Oando has a zero tolerance towards any form of child labor. It is unacceptable. Due to our vendor pre-registration checks, we are able to ensure compliance with the company’s stance against child labour. Where compliance cannot be ensured we do not engage the vendor. Regardless of the urgency, all vendors undergo a high level of scrutiny through our due diligence process which is a rigorous exercise carried out before a vendor is accepted.Labour
Commitment
1. Does the company have a policy commitment in relation to the following labour rights principles?
1.1. For each labour rights policy, is it:
Prevention
2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?
3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?
4. Who receives training for the following labour rights issues?
5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?
Performance
6. What is the percentage of employees covered under collective bargaining agreements?
Optional commentThere are no employees covered under collective bargaining agreements in Oando.7. What is the percentage of employees in a trade union or other workers' organization?
Optional commentThere are no currently no Oando employees in trade unions.8. In the course of the reporting period, what was the percentage of women in:
9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?
Optional commentThe ratio is 1:110. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
Optional commentNo employees were injured whilst working.11. In the course of the reporting period, what was the company’s incident rate?
Optional commentThere were no lost time injuries (LTI) during the reporting year.Response and Reporting
12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?
13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.
During the reporting period, our Human Capital Management related policies were reviewed, presented to the Board for approval and disseminated to ensure that our employees understand our policies, principles and practices and have the requisite information.Environment
Commitment
1. Does the company have a formal policy on the following environmental topics?
1.1. For each environmental policy, is it:
Prevention
2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?
Optional commentWhen carrying out our Environmental Impact Assessment exercise and Environmental Evaluation Studies, the Company is involved in a Public Hearing session with its stakeholders (community representatives, government officials, regulators and partners) to collaborate on how to prevent the risks associated with the above material issues. In addition, the Company, through its subsidiary, Oando Clean Energy Limited (OCEL) has engaged stakeholders for collaboration in the area of climate action, specifically in relation to solar energy solutions, sustainable transport, gas and bio fuels, wind farms, waste to energy and geothermal power plants.3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?
Optional commentYes we conduct an Environmental Evaluation Study (EES) bianually.4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
Optional commentIn regards to out Joint Venture operations, Our Regulators set limits for each parameter, analysis of samples collected will show if we are not in compliance with regulatory limits. In an instance where there is Non- compliance, a clean-up or remediation exercise carried out.4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?
4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?
Optional commentProgress is reported internally to Senior Level Management and externally , through submissions to the regulators on company’s compliance status.5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?
Optional commentOur Environmental Evaluation Study (EES) and Post Impact Assessment are exercises used to identify impacted areas as a result of our business activities. The results of these assessments determine whether the impacted areas should be cleaned up or if full remediation will be required to restore area back to its original state. In the event of an oil spill, our NAOC JV performs a series of activities to respond, manage, contain, measure, recover and remediate. After the spill notification, verification and Containment/Recovery actions, a Joint Investigation Visit (JIV) with Government Regulatory Agencies and Communities takes place, followed by Repair, Delimitation survey of impacted area, and Clean up of impacted site. A further visit called Post Clean up Inspection (PCI) takes place with Government Regulatory Agencies and Communities, including Sampling/Analysis for close out. Remediation actions are taken if required. Final Close out Certificate is provided by Government Regulatory Agencies. Also, the NAOC JV remediates contaminated sites (soil) using Remediation by Enhanced Natural Attenuation (RENA), which is an integrated use of Bioremediation and Land-farming techniques. The principle for the application of RENA is based on the fact that the hydrocarbon compounds in the spilled oil undergo biodegradation under suitable bio-physico-chemical conditions. Under RENA, various forms of activities promote these conditions, and the hydrocarbon compounds biodegrade gradually to give rise to CO2, H2O and biomass. The RENA process involves the following: Site assessment: Surface visual inspection of the site, sampling (sample collection and analysis, results of analysis). Site preparation: Clearing of the site is done manually by cutting down and clearing dead logs for easy accessibility. Soil preparation: Tilling and homogenization of impacted soil aimed at exposing the impacted soil to atmospheric aeration. Construction of ridges: Construction of ridges in a windrows fashion to expose deeply contaminated soil to the surface for aeration and eventual attenuation through biodegradation. Soil amendment: Nutrients application to contaminated soil to enhance the biodegradation and the quality of the soil. Monitoring: The area will be monitored for a period of four months after soil amendment and samples collected and analyzed. Project close out: Site to be closed out only when plants and vegetation have regenerated and the Total Petroleum Hydrocarbons (TPH) and other contaminant levels have reduced in line with the Nigerian standards.Climate Action
6. What were the company’s gross global greenhouse gas emissions for the reporting period?
Scope 2 Emissions
Scope 3 Emissions
Optional commentThe volume of gas flared which contributes to GHG emissions is measured but the components are not measured.7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?
Optional commentOando has invested $46, 567 in its renewable energy subsidiary, Oando Clean Energy Limited.8. Has the organization acted to support climate change adaptation and resilience?
Optional commentAs an energy solutions provider, we are constantly re-defining the future of the business. By aligning our sustainability strategy toward achieving a carbon neutral world. Today, petroleum meets over 95% of global transportation demands; however, a sustainable world means the future of energy companies will increasingly be based on a diversified portfolio that must include renewable energy in various forms. In 2021, the Company established Oando Clean Energy Limited (“OCEL”), its renewable energy business subsidiary, with interest in Solar Energy Solutions, Gas and Biofuels, Sustainable Transport, Wind Farms, Geothermal Power Plants, Waste to Energy. Our core areas of interest include Sustainable Transport, Gas Ventures Waste to Energy Power Plants, Hydrogen Production, Bio fuels and Solar Energy Solution Mini Grids , Commercial Units and Home Systems, Wind Farms , Geothermal Energy and other emerging technologies,Energy / Resource Use
9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.
Technology
10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?
Sector-specific Questions
11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.
Sector-specific: Water
12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.
Water withdrawal (volume of water in megaliters):
Water consumption (volume of water in megaliters):
Optional commentA major source of the water used in the office is ground water from bore holes installed by the company. To conserve the water, motion sensor taps are installed in the bathrooms, preventing unnecessary wastage of water. Water dispensers are also made use of in the office, reducing the need for multiple disposable plastic bottles.13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.
Sector-specific: Forest, biodiversity, and land use
14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).
15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?
16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?
Sector-specific: Air pollution
17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.
Optional commentThe Company, through it's Joint Venture NAOC has developed a number of projects on its operated JV onshore assets to valorize produced gas and increase the amount of gas sold to the domestic market for power generation or to industrial plants. In general, flaring down projects in Nigeria are based on the construction of gas lines from stranded oil plants and on the installation of low-pressure compression trains in order to recover the flared gas and convey it into the existing gas network. Flaring Down Projects Over the years, NAOC has invested substantially to reduce the amount of routine gas flared in its operations. The reduction in gas flaring began at the completion of the main gas trunklines for the marketing of EPCL and NLNG gas (2007-2011). In the following years, NAOC has developed initiatives like the Idu Phase 2 in 2012 and the Ogbainbiri Flow Station Upgrade in 2013. More recently, NAOC focused on Akri and Kwale plants, with an integrated project gathering associated gas from Akri oil wells and all atmospheric and low-pressure flares in Kwale flowstation. Akri gas is transported via a new 18.1 km pipeline to Kwale where it is collected, compressed and transported along with the atmospheric and low-pressure flared gas in Kwale, where new low-pressure compression capacity has been installed. The line from Akri to Kwale has been completed and commissioned in 2018, currently delivering about 15 MMSCFD. The installation of 2 trains of atmospheric and LP compression in Kwale is ongoing, and once completed it will have 20 MMSCFD installed capacity.Overall cost of the project is about 130 million US dollars. NAOC has long been at the forefront in supporting the Federal Government of Nigeria to increase gas production, and is strongly committed towards the domestic gas market, which currently accounts for over 30% of its total supply. This is twice as important if we think that part of this is used as feedstock to power plants, thus generating power. In 2018, because of this trend of consistent investment, flared gas at NAOC was only 3.6 % of gas production. This means that 96.4% of gas produced is being utilized, specifically to generate electricity at Okpai IPP, and to supply the petrol-chemical plant at Eleme and the LNG liquefaction plant in Bonny. NAOC is also pursuing a gas flare monetization strategy through gas sales agreements, strengthening the company’s commitment to the domestic market while at the same time allowing us to leverage our flaring down policy and CO2 emissions reduction.Overall Environment
21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.
The Company has set up a new division/Company known as Oando Clean Energy Limited to explore innovative clean energy alternatives to its current business operations with the key objective to meet the continent’s energy demands by harnessing green and renewable sources, as well as investing in climate friendly and bankable energy projects across the African landscape, starting in our home country, Nigeria. We believe access to energy is the bridge between Africa's underdevelopment and the achievement of its full potential. Our goal is to build that bridge with geothermal, solar, waste, wind, biofuels, and other sustainable ‘bricks’ towards the enhancement of lives and livelihoods. Our core areas of interest include Sustainable Transport, Gas Ventures Waste to Energy Power Plants, Hydrogen Production, Biofuels and Solar Energy Solutions Mini Grids, Commercial Units, and Home Systems, Wind Farms, Geothermal Energy, and other emerging technologies. The electrification of transportation is the new frontier for mobility. Oando Clean Energy is championing the cause for EV adoption; ensuring the availability of affordable and easy to maintain EVs to Africans at large, whilst also ensuring accessibility of excellent charging infrastructure and after sales services. To this end, OCEL recently signed a Memorandum of Understanding (MoU) with the Lagos Metropolitan Area Transport Authority (referred to as “LAMATA”), the Lagos State Government agency tasked with coordinating transport planning, policies, and public transport infrastructure implementation in the Lagos Metropolitan Area., to establish a partnership between OCEL and Lagos State in her journey to becoming a sustainable city via the rollout of electric mass transit buses, supporting charging infrastructure and service centers (EV Infrastructure Ecosystem).Anti-corruption
Commitment
1. Does the company have an anti-corruption compliance programme?
Optional commentOando is opposed to all forms of corruptions. Oando has a company-wide anti-corruption program. Governance and Compliance officers, who are responsible for monitoring and reporting on the extent to which ethics and anti-corruption considerations are integrated into our business activities and implemented constitute an important element of the program. Our anti-corruption program is tailored towards compliance with applicable laws and regulations whilst providing training on relevant issues such as gift and benefits, anti-money laundering, related party transactions, insider trading and other policies are best practice.2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?
Optional commentOando has a detailed Gift and Benefits Policy which was reviewed and updated in 2020.Prevention
3. Who receives training on anti-corruption and integrity?
Optional commentAll our Directors and Employees are required to undergo a web-based training and recertification on the Oando's Code of Business Conduct and Ethics and other policies. Upon completion of the training, a test in administered leading to the issuance of a certificate of completion. Where any individuals fails the test, they are required to review the training information before re-taking the test until they can show understanding of the information before re-taking the test until they can show understanding of the information being disseminated and consequently attain the minimum required standard to be certified for the year. New employees also receive training on the Company's Code of Business Conduct and Ethics "the Code" within the first month of employment.3.1. How often is such training provided?
Optional commentTown hall, in-person meetings and discussions with the Chief Compliance Officer or any of the other members of the Governance Office. Periodic electronically based information platforms as well as Newsletters and Compliance Campaigns are all used as important ways to further develop and entrench a fully compliant culture within the Company.4. Does the company monitor its anti-corruption compliance programme?
Optional commentThe Company operates a whistleblowing hotline which is managed externally by an independent professional firm, KPMG. The Company also conducts Corporate Governance Evaluations on an annual basis.Response and Reporting
5. Please report the company's total number and nature of incidents of corruption during the reporting year.
6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?
Optional comment(There were no investigations or suspected incidents of corruption in the year under review. However, Oando Plc was investigated by the Securities and Exchange Commission (SEC) based on two petitions filed with SEC by two petitioners (Ansbury Inc. and Alhaji Dahiru Mangal) alleging gross abuse of corporate governance. On May 31, 2019, on the basis of the purported results of the forensic investigation, SEC found serious infractions including: false disclosures, misstatements in financial statements, internal control failures, and corporate governance lapses. Consequently, SEC imposed various fines and sanctions on the Oando Plc and some of its directors, including barring Mr. Tinubu and Mr. Boyo, the Group Chief Executive and Deputy Group Executive of Oando Plc, respectively, from being directors in public companies for 5 years. Oando Plc is of the view that the penalties and allegations are unsubstantiated and that the company was not given the opportunity to defend itself. In a suit for filed by Mr. Tinubu and Mr. Boyo, on June 3, 2019, the court granted an interim injunction restraining SEC from taking any action on its decision against the company dated May 31, 2019. Oando PLC and the SEC on July 15, 2021 concluded the settlement of the dispute and all related suits filed pursuant thereto without accepting or denying any liability in respect of the wrongdoing alleged to have been committed by the Company and certain of its directors. As part of its compliance obligations and continuous improvement on processes and procedures, the Company continues its practice of annual Board and Corporate Governance evaluations, results of which are deliberated at Board meetings and recommendations are followed through for implementation. As part of the implementation plan, the Company filed its Report on Compliance on the SEC Corporate Governance Guideline for 2021 with the SEC (attached herewith). This is a mandatory filing for the Company on the SEC Corporate Governance Guidelines. We have also filed with the Reporting Financial Council (FRC), the mandatory report on the Company’s compliance with the Nigerian Code of Corporate Governance 2018. (Attached) Furthermore, the Company ensures that the Board approved External Quality Assessment of the Internal Audit function is carried out once in 3 years by an external professional services firm to determine the level of conformity, compliance, and quality of Oando’s Internal Audit against globally accepted standards of the Global Institute of Internal Auditors (IIA). The Company further evaluated the effectiveness of its internal control over financial reporting which was externally facilitated based on recognized internal control framework and the Board ensures the integrity of the Company’s financial control and reporting.7. Does your company engage in Collective Action against corruption?
8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.
Continuous review of the Company’s anti-corruption framework, training and internal audit review of processes. Collective action initiatives with the UN Global Compact Network Nigeria, the Convention on Business Integrity and the Governance & Compliance Professionals Nigeria LinkedIn Platform.