CONFIDENTIAL REPORTING
Pursuant to Article 23 of L. 4409/2016
Employees of operators and owners, as well as any concerned individual, may contact HEREMA at any point with safety concerns or possible irregularities detected, in a fully confidential manner, via telephone or by emailing their concern to the dedicated address (confidential.reporting@herema.gr). HEREMA will fully protect the identity of the reporting person upon receipt of this report, and will ensure their anonymity, keeping also in accordance with the regulations on the protection of personal data.
The report must include the name of the offshore facility and a detailed description of the issue of concern, including the date of a possible event. The amount of detail submitted (possibly including electronic files such as photos, videos etc) will make it easier for HEREMA to assess the issue under consideration.
Following consideration by HEREMA, safety concerns will be addressed in a manner proportionate to the concern raised. HEREMA will firstly ascertain the facts behind the concern and whether they fall within its jurisdiction. It will then assess whether there has been any breach of Greek Offshore Safety legislation, ensure that any necessary remedial action is taken by the owner or the operator and take further enforcement action, if appropriate. Where the confidential report does not refer to an immediate safety concern, the topic may be included for investigation in an upcoming inspection. In any case, HEREMA will promptly notify the reporting person about its intended actions and, in case of an investigation, its findings will be also communicated to them when completed.
Operators and owners are required to communicate the details of this mechanism for confidential reporting of safety concerns to their employees and contractors carrying out offshore oil and gas operations, and to ensure that reference to confidential reporting is included in relevant training sessions. Notices about the confidential reporting mechanism must be displayed on visible places on the offshore installation (bulletin board, computer room etc.).
