Our Ethics

Our objective is to conduct our business in an honest and ethical manner. In 2018, key issues in this area included those related to: preventing corruption and payments to host governments.

Preventing corruption

SOCO currently operates in Vietnam, which is allocated a low score on Transparency International’s most recently published Corruption Perception Index (“CPI”), featuring at number 107 out of 180 countries in the 2017 CPI. Egypt, where SOCO expects to operate following completion of the acquisition of Merlon, is ranked at 117 on the same CPI. We recognise that, with both areas of operation having a reputation for a lack of transparency and relatively high risk of corruption, it is vital that the Group’s policies, procedures and working practices are fit for purpose. SOCO maintains internal control systems to guide and ensure that our ethical business standards for relationships with others are achieved.

Bribery is prohibited throughout the organisation, both by our employees and by those performing work on our behalf. The Business Conduct Procedure supports the implementation across the organisation. Our Anti-Bribery and Corruption (“ABC”) programme is designed to prevent corruption and ensure systems are in place to detect, remediate and learn from any potential violations. This includes due diligence on new vendors, annual training for all personnel, requisite compliance declarations from all associated persons and comprehensive ‘whistleblowing’ arrangements.

Our Whistleblowing Policy and Procedure ensures that employees are protected from possible reprisals when raising concerns in the public interest. In addition to internal reporting channels, we have a confidential ethics hotline provided by Expolink with numbers displayed in local offices available 24 hours a day all year round. No calls to the Expolink hotline were logged in 2018, and there were no other whistleblowing reports received or logged within the Group during the year. After the reporting year end, in early 2019, a report was received about one member of staff using company assets for personal use. The staff member has since left the organisation.

100% Employees and relevant contractors undertook anti-bribery and corruption training in 2018.

Payments to host governments

Wealth generated by natural resources plays an important part in the growth and development of countries in which we operate. Revenues to governments become payable by the Group due to oil production entitlements, taxes, royalties, licence fees and infrastructure improvements. SOCO supports the principles of the Extractive Industries Transparency Initiative (“EITI”) and participates in EITI active countries.

During 2018, the total payments to governments for the Group amounted to $202.4m, of which $196.5m or 97% was related to the Vietnam producing licence areas, of which $135.1m was for indirect taxes based on production entitlement. The breakdown of the contributions, including payroll taxes and other taxes will be contained within the additional information in the 2018 Annual Report and Accounts page 135.

Our Code prohibits contributions to political parties, candidates or other political organisations.


Pharos Energy plc is aware of attempts to impersonate the company under its previous name, SOCO International plc, on social media. Pharos does not have a Facebook page.