Lord Michael Howard of Quindell – assisting a second Serious Fraud Office Investigation – Soma Oil & Gas

Comments

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   My Left Armpit

   1 August 2015, 12:36

   Here you go…

   http://www.somaoilandgas.com/page/anti-bribery-and-corruption-and-risk-management

   Anti-bribery and Corruption and Risk Management

   Soma Oil & Gas has a zero tolerance approach with respect to its Anti-bribery and Corruption policy, procedures and implementation and complies with all applicable laws and regulations of the countries in which it operates.

   “Soma Oil & Gas is committed to upholding high standards of ethics, transparency and accountability in the oil and gas industry and fully supports and promotes an extractive sector free of corruption. We have decided to build a long term sustainable business in Somalia and intend to invest both in its ethical infrastructure and in the communities in which it works. From inception, we will build a corporate culture based on fundamental values including fairness, ethics and integrity in its business dealings, which is compliant with the highest standards of relevant legislation in the world. A zero tolerance policy towards bribery and corruption will form the basis of Soma Oil & Gas compliance framework which will be designed to protect its brand, its employees, its third party business associates and its stakeholders from the risks associated with bribery, corruption and extortion”.

   Lord Howard of Lympne CH, QC, Chairman of Soma Oil & Gas

   All employees of the Company and its affiliates are required to comply with the Group’s Anti-bribery and Corruption policy.

   Presumably he was talking about the Somalians… Cough. Anyway those are his words and you might hope he will stand by them.

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   My Left Armpit

   1 August 2015, 13:46

   Oh…

   http://t.co/rX7qJ6wbFw
   http://www.bbc.co.uk/news/33747169

   Looks like the beeb scooped first and give a more ‘refined’ take on what might be going on.

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   its me

   2 August 2015, 04:25

   In order to get E&P rights in most African and Latin countries a “signature bonus” has to be paid. This is always in cash and paid to the people in charge of issuing the licences at the Ministry. It works in either of two ways, the people who set the company up pay this personally and take the money back post fundraising or it is agreed prior to funding that once the company comes to market and is funded the “cash” is then taken out and paid in return for the permit/s.

   Entries in the management accounts and subsequently the FY audit are as other items not associated as a “signature bonus”. Therefore, generally with E&P in Africa there is nearly always a breach of the UK Bribery Act. The SFO could go on forever. Lastly try and find a NOMAD who could tell you what a signature bonus is? Most will not know because this aspect of the deal never crosses their desk and is kept hidden from them. They are only aware of the cost that the Ministry invoices which is part of the verification and reporting accountant proccess.
   Lastly a teaser!
   Lets assume a QE found out about the signature bonus and the QE needed one more transaction to ensure their continued QE status would he/she
   a) Resign from the transaction or b) Continue?
   Due to the flawed AIM rules for NOMADS I know which my money would be on.