Petroleum Geo-Services ASA (PGS) Compliance Team Conceal Illicit and Non-Compliant Acts through Stonewalling – 2016

How a Dysfunctional and Non-Responsive Compliance Program Harms the Reputation of PGS

Revised 22 October 2018.  Publication of unanswered Petroleum Geo-Services ASA Compliance Hotline e-mails documenting PGS Legal Compliance Inaction and Apathy.  

When I felt that my own professional and personal reputation had been defamed, I submitted a thorough formal grievance challenging the management of my employer, PGS Exploration UK Limited (PGSUK), directly to substantiate their orally and written aspersions.  I am now a former employee of PGS PGSUK.  I am a USA citizen who was sponsored to live and work in England on a Tier 2 visa, along with my wife and dependent children.  PGSUK is an affiliate of Norwegian based marine seismic service company, Petroleum Geo-Services ASA (PGS).  When I tried to find redress through practicing my legal right under employment and contract law to initiate the grievance procedures outlined within the PGSUK Policy Handbook, this right was impeded through managements conscious efforts to bypass the processes and  laws governing my employment as a foreign worker.  My rights were manipulated and denied and the health and safety of my family placed in danger through these same consciously violent acts by negligent management.  As a foreign worker with no ties to the community, I was employed within a toxic and dehumanizing workplace.  But, I would not leave without defending my rights, dignity and reputation as a professional.  I tried to follow the rules.  Within my written grievance, I write:

A main motivation for my response in the form of a grievance is that one should never allow a defamatory statement to go unchallenged. Silence is perceived as acceptance. If one does not respond about what has been said and written about them – especially at a professional level – then it must be true.  

Employer personnel files contain the documentation that is needed to provide an accurate view of an employee’s employment history.  The documentation supports the employer’s decisions and must be of a legal standard to protect the employer in a potential lawsuit.  Most employee personnel files will never be tested in this way.  But, this is the standard for and basis for maintaining such records at all.  The personnel file contents demonstrate the employer’s rationale behind hiring, promotions, transfer, rewards and recognition, and termination decisions.  Outcomes are the derivative of processes and are only valid to the extent that the processes followed best practices as prescribed in policy which is guided by employment law.  My grievance was grounded in the belief that my personnel file data was intentionally defamatory and the byproduct non-compliant processes.

Ten months after I left England, I submitted a subject access request to PGSUK citing the UK Data Protection Act 1998.  I discovered that defamatory and inaccurate personnel records populated my personnel file contents.  This was done intentionally by PGSUK to create a false history of my employment which would obviously would harm me for future opportunities.  This was the basis for my filing a grievance in the first place and why defamation was specifically an issue that was brought up.  Another key issue brought up within my grievance document was that PGS Core Values were being ignored.  PGS Core Values and PGS Code of Conduct are specifically mentioned within the terms and conditions of my original employment contract.  I felt that management had breached these terms and conditions through their deliberate and destructive decisions focused on me.  I was a target of workplace gang-bullying and harassment.

The best way for an individual or company to maintain a stellar reputation, first and foremost, is to be proactive and ensure that one’s decisions are guided by ethical values.   Enterprises must be principled and resolute about following such guidance.  The UK Companies Act 2006 clearly establishes that directors and secretary (“directors”) have the fiduciary duty to protect the reputation of the company that they direct.  Employee’s, present and former, are bound by Confidentiality conditions, such that they will not engage in activities and public disclosures that will negatively impact the business.  This, of course, includes its reputation.  The exception to any such public disclosures are protected disclosures, or whistleblowing.  Such protected public disclosure is provided through the UK Public Interest Disclosure Act (PIDA) and is specifically referenced within the PGSUK Policy Handbook.

Most people when accused of a crime that they are innocent of will vehemently deny it and take action in the moment and not wait over three years to be outraged and file criminal defamation charges in a foreign country.  We must concede that the reaction of PGSUK directors, Rune Olav Pedersen, Gottfred Langseth, Christin Steen-Nilsen, and former secretary Carl Richards is not normal.  At what point are such publications the fault of those charged with guarding the company reputation?  Where was the proverbial “line in the sand” in terms of what disparaging commentary would be tolerated?  The first and only official condemnation of my postings came in the form of a criminal complaint made by PGSUK directors.  However, prior to being President and CEO of PGS, Pedersen was General Counsel and Legal Compliance.  He also ascended to be an Executive Vice President of Marketing.  As a member of the legal compliance team of PGS, in 2016 several e-mails were directed to him and his team.  All e-mails directed to Pedersen were not answered at all.  I did have some exchange with other compliance team members.  Between April to September 2016, I complained to the PGS compliance team on several occasions.  I provided published blog article content and links for their consideration.  The final blog article sent specifically to Pedersen’s attention was titled The Crimes of Petroleum Geo-Services (PGS) CEO Jon Erik Reinhardsen. 

Many of the same claims that were directed to Pedersen within my 2016 blog publications are repeated within future blog post articles.  My intention was to make sure that the same base complaints were true and continued to be considered relevant.  I continued publishing content and expanding the recipients of my complaints because the many issues important to me were never acknowledged or resolved by PGS, most notably the directors of PGSUK.   I have always requested a thorough third party (police) investigation.  In fact, if the directors of PGSUK were truly confident of their innocence, they would invite such an investigation to exonerate themselves.  Currently, an updated report submitted to UK ActionFraud (police) accusing the directors of criminal behavior has been published on my website for some time.  No one from PGSUK has ever addressed or clarified the accusations made or asked for the reports removal.  Current publications implicate the same people as the articles published and forwarded to PGS compliance in 2016.  Pedersen reneged on his duty to defend the reputation of PGS in 2016, as the e-mails below clearly show.  So, who bares responsibility for damage to that reputation in 2018?

• An American, the UK Data Protection Act, Petroleum Geo-Services and the Tyranny of “Accurate Data” (3 July 2015)
• When Human Resources is Corrupt – Why it Matters in the Seismic Industry (10 August 2015)
• Petroleum Geo-Services CEO Jon Erik Reinhardsen Should Resign (6 September 2015)
• Petroleum Geo-Services CEO Jon Erik Reinhardsen Should Resign II (20 September 2015)
• The SEG Should Expel PGS CEO Jon Erik Reinhardsen (11 October 2015)
• Workplace Bullying is an Agency Problem and Often a Crime (1 February 2016)
• Petroleum Geo-Services (PGS) Markets and the Anonymous Executive (9 February 2016)

• 20160508_PGS and the Veneer of Governance

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