Approach to Business Ethics
Our collective integrity signifies our reliability as a business partner and trusted neighbor who honors our commitments. Our commitment does not waiver, regardless of the complexity or competiveness of the business environment we face. We always will operate with integrity to protect our reputation, business, and stakeholders.
Our Code of Business Conduct and Ethics (Code) is the foundation for our culture of ethics and integrity. Developed during Equitrans’ corporate establishment in 2018, the Code lays out in detail our approach to everything we do, covering our values, principles, standards, and norms of behavior through six main sections:
- We are all responsible for doing the right thing
- Working together
- Never compromise our integrity
- We speak with one voice
- Protecting our information and assets
- Dealing fairly and honestly with others
The Code guides our actions—how we act and react in different situations—and provides reference points and resources for additional questions or concerns on issues that are not explicitly covered in it.
In 2019, the Code and related policies were modified to better reflect Equitrans’ newly established values and practices. This process involved cross-functional collaboration between our Compliance, Legal, Human Resources, Information Technology, and Senior Management teams to ensure the Code reflects all aspects and requirements of our business. We will continue to evaluate the Code to determine whether additional modifications are necessary as Equitrans’ operations grow and evolve.
Equitrans expects all of our employees and those with whom we do business to follow our Code and uphold our culture of ethics and integrity. Each new Equitrans employee is required to complete a training on the Code soon after starting with us and we deliver a companywide training for all employees biennially. In 2019, 100 percent of employees completed the biennial training, which will next occur in 2021. In addition to the training, all employees must read the Code annually and sign an acknowledgement confirming their understanding. The Code is available in different languages upon request.
If an employee has a question or concern related to any subject covered within the Code, they are encouraged to discuss it with their supervisor or a member of our internal Compliance Network. The Compliance Network is a group of individuals from our Health, Safety, Security, and Environmental (HSSE), Legal, and Human Resources (HR) teams responsible for facilitating compliance with laws, regulations, and the Code. The Compliance Network serves as a resource to answer any questions employees may have and as a place to report alleged misconduct. The Equitrans Compliance Hotline at (844) 513-8109, which is a part of the Compliance Network, is another avenue through which employees and external stakeholders can report alleged misconduct. Available 24 hours a day, seven days a week, the toll-free Compliance Hotline is staffed by an independent third party experienced in handling ethics issues that works with callers to document concerns for review. All calls made to the Compliance Hotline can be completely anonymous, if a caller so chooses, and are not recorded. Information provided in a call is quickly relayed to Equitrans and our internal auditor for investigation and resolution, if possible. Employees can also report alleged misconduct through our third-party operated online reporting portal. Both the Compliance Hotline and the online portal can also be used to convey positive suggestions or experiences related to the Code.
Equitrans’ Deputy General Counsel, Litigation, Risk and Compliance has direct oversight of the Equitrans Compliance Program. The Deputy General Counsel reports to and coordinates with the Senior Vice President and General Counsel on matters involving compliance with the Code. At the Board level, the Board’s Audit Committee assists the Board in overseeing compliance by Equitrans with legal and regulatory requirements, including the Code.