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Governance

Business Ethics
and Integrity

At Equitrans, we believe honesty and ethics are essential elements of success, and we conduct our operations in a fair, honest, and responsible manner. We believe in operating with integrity. We expect each of our employees and contractors to be someone others can trust and respect, and we take pride in upholding our corporate citizenship and long-standing reputation.

 

Our Approach to Business Ethics

2-24
Embedding policy commitments

2-25
Processes to remediate negative impacts

2-26
Mechanisms for seeking advice and raising concerns

2-27
Compliance with laws and regulations

3-3
Management of material topics

205-1
11.20.2
Operations assessed for risks related to corruption

205-2
11.20.3
Communication and training about anti-corruption policies and procedures

205-3
11.20.4
Confirmed incidents of corruption and actions taken

206-1
11.19.2
Legal actions for anti-competitive behavior, anti-trust, and monopoly practices

406-1
11.11.7
Incidents of discrimination and corrective actions taken

414-1
11.10.8
11.12.3
New suppliers that were screened using social criteria

414-2
11.10.9
Negative social impacts in the supply chain and actions taken

2-24
2-25
2-26
2-27
3-3
205-1
205-2
205-3
206-1
406-1
414-1
414-2

Equitrans’ Core Value of Integrity underpins our promise to establish trust with all our stakeholders. When Equitrans was founded, one of our first priorities was to create a Code of Business Conduct and Ethics (Code of Conduct) to ensure all areas of our business adhere to the same strong ethical standards. We routinely evaluate and update our Code of Conduct as needed to ensure our ethical standards stay relevant while our Company continues to evolve and to uphold promises to our employees and other stakeholders.

Upon request, the Code of Conduct can be translated into a person’s preferred language, which helps to ensure all employees, contractors, and suppliers understand the Company’s expectations. Equitrans’ Code of Conduct defines our approach to everything we do, including how we’ve defined our values, principles, standards, and expectations, and is applicable to all employees, officers, directors, contractors, and suppliers. It outlines our approach to doing business through six key philosophies:

  1. We are all responsible for doing the right thing
  2. Working together
  3. Never compromise our integrity
  4. We speak with one voice
  5. Protecting our information and assets
  6. Dealing fairly and honestly with others

Our Deputy General Counsel for Litigation, Risk, and Compliance directly oversees Equitrans’ compliance program, reports all Code of Conduct compliance matters to the Senior Vice President and General Counsel and assists in finding solutions to relevant concerns. The Audit Committee of the  Board of Directors oversees Equitrans’ compliance matters, as well as overall adherence to applicable legal and regulatory requirements and to the Code of Conduct. On a routine basis, the Audit Committee receives reports on investigations and issues raised from the compliance program. The periodic reporting to the Audit Committee ensures all compliance-related concerns are adequately addressed at the highest levels in the Company.

Equitrans’ Core Value of Integrity underpins our promise to establish trust with all our stakeholders.

Together with our Executive Management and Human Resources (HR) team, our compliance team reviews reported incidents and evaluates policy requirements to determine if further updates to the Code of Conduct or policies are required. These actions improve clarity and help address emerging issues as they arise. In 2022, our corporate compliance team implemented a new policy, the Code and Policy Update Approval Policy, to streamline the review and approval process of updates to our Code of Conduct and Company policies. Training on this new process was made available to those employees who manage and oversee policies related to their functional area. The following is a list of policy updates made in 2022:

  • Incorporated language related to bullying and expanded a list of prohibited activities to clarify expected and appropriate employee behavior and conduct in the workplace. Such details were added to our Weapons Workplace Violence Policy
  • Revised the Corporate Stock Trading Policy, in connection with the roll-out of the Employee Stock Purchase Plan and the freeze of Equitrans’ common stock investment option under the Employee Savings Plan
  • Adopted two new policies: an Environmental Justice Policy, which affirms the Company’s commitment to the fair treatment and meaningful involvement of all people in any public process involving our operations regardless of race, color, national origin, or income; and the Learning Management System (LMS) Guidelines and Training Administration Policy, which establishes training administration guidelines and centralizes recordkeeping for all Company-assigned training.

Compliance Training and Reporting

Compliance Training

We expect all employees and the third parties we do business with to abide by the Company’s business conduct and ethics outlined under Equitrans’ Code of Conduct.

  • All new Equitrans employees must complete a training on our Code of Conduct and sign an acknowledgment form within the first few weeks of employment.
  • Existing employees must review the Code of Conduct and sign an acknowledgment form annually.
  • All employees are required to complete Code of Conduct training every two years.
  • Equitrans’ Board of Directors, the Company’s highest governing body, is required to complete Code of Conduct training every two years, the latest training of which was in the fall of 2022.
  • Suppliers and/or contractors that receive more than $10,000 per year from Equitrans receive an annual compliance letter and are required to acknowledge that all goods and services provided must be delivered in compliance with our Code of Conduct.
 

In addition to our Code of Conduct training, all Equitrans employees must complete biennial training to refresh their knowledge of Company policies. These online and live training sessions ensure all employees understand the Code of Conduct and other Company policies and receive the required core training, including conflicts of interest, preventing workplace violence, sexual harassment, safeguarding personally identifiable information (PII), and insider trading (micro-training). Select employees with specific business knowledge must also complete biennial, comprehensive training related to insider trading and antitrust regulations. Specific information related to anti-corruption training, communications, and incidents for 2022 is outlined below:

Anti-Corruption Policies/Procedures Communications

 2021 2022

Total Number of Employees

 749 766
Total Number of Business Partners 499 787

Anti-Corruption Training

 2021 2022

Total Number of Employees

 749 766

Incidents

 2021 2022

Total Number and Nature of Confirmed Incidents of Corruption

 0 0
Total Number of Confirmed Incidents in Which Employees Were Dismissed or Disciplined for Corruption 0 0
Total Number of Confirmed Incidents When Contracts With Business Partners Were Terminated or Not Renewed 0 0
Public Legal Cases Regarding Corruption Brought Against the Organization 0 0
Number of Legal Actions Pending or Completed 0 0

In 2022, the compliance team launched the new NAVEX training platform and shared fresh and interactive content for all core training areas, as mentioned above. The compliance team supplements this robust, customized online training with several in-person sessions throughout the year. In 2022, live training sessions were conducted on the topic of bullying, as well as the new process for enacting and revising our Code of Conduct and Company policies.

To encourage positive interaction with the corporate compliance team, we developed an incentive program in 2021 to motivate employees to complete their trainings in a timely manner. Through this program, employees have an opportunity to win Equitrans-branded merchandise by completing their training within the first 48 hours of the launch of the training. During live training sessions, we expanded the incentive program by quizzing employees on their knowledge, encouraging their participation in related human resources videos, and providing more chances to win Equitrans merchandise. The videos were then available for viewing on compliance webpage of Equitrans’ intranet, Mainline Connect. To enhance employees' experiences, a new and more interactive compliance page was launched on Mainline Connect in November 2022. Given the higher percentage of webpage interaction, we believe this effort, together with our live trainings and incentive program, has improved employee engagement and increased interest in our corporate compliance program.

Specific to suppliers, Equitrans developed and published a more robust, supplier-specific Code of Conduct in 2021. Mirroring Equitrans’ Code of Conduct, the Supplier Code of Conduct requires our suppliers to confirm their commitment to a broader set of social workforce policies. Equitrans communicates policy updates to our suppliers and contractors through ISNetworld and several internal contractor liaisons. Every three years, the supply chain team ensures our suppliers and contractors receive the most updated Supplier Code of Conduct and sign an electronic acknowledgment form. In addition, on an annual basis, suppliers are reminded of their commitment to honor the Supplier Code of Conduct through receipt of a formal letter. Additional information can be found in the Supply Chain Management and Human Rights section of this report.

Compliance Reporting

Equitrans maintains a system for the reporting of suspected violations of our Code of Conduct and/or policies. Compliance reporting can be done via phone using our toll-free Compliance Hotline (844-513-8109) or online via the EthicsPoint platform, and persons can choose to remain anonymous at the time of reporting. Our compliance reporting system is operated 24 hours a day, seven days a week, and is managed by NAVEX, an independent third-party. Whenever a report is filed, the person receives a report reference number, which allows the person to check the report status at any time. NAVEX representatives then present all relevant information to a member of Equitrans’ legal department or corporate compliance department for investigation and resolution. In addition, persons may directly contact a member of Equitrans’ compliance, legal, or human resources departments, or a member of Equitrans’ Compliance Network to report suspected violations. While it is important to report concerns and misconduct allegations, employees are also encouraged to submit positive feedback and experiences.

Based on the NAVEX data records, the number of reports made during 2022 doubled compared to the previous year, with a total of eight allegations reported. This increase in reporting indicates our employees are becoming more comfortable in reporting suspected violations of our Code of Conduct and related Company policies.

Evaluating Our Approach to Business Ethics

Equitrans encourages all employees with questions, concerns, and feedback related to Equitrans’ Code of Conduct to contact their supervisors and/or a member of Equitrans’ corporate compliance department. In addition, we have an internal Compliance Network, which consists of employees from our environmental, legal, and human resources teams. Members of the Compliance Network are responsible for facilitating compliance with laws, regulations, the Code of Conduct, and Company policies.

Equitrans’ Board of Directors, the Company’s highest governing body, is required to complete Code of Conduct training every two years, the latest training of which was in the fall of 2022.

The Compliance Network is also available to answer employee and stakeholder questions on the Code of Conduct or Company policies, and members often assist in managing misconduct reports. Employees can contact a member of the Compliance Network by calling, emailing, or texting a member; setting up in-person meetings; calling the toll-free Compliance Hotline at (844) 513-8109; or making a request online via the EthicsPoint platform.

To enhance recordkeeping and streamline Equitrans’ compliance program activities, we have been working on the implementation of a comprehensive compliance management software platform, phase one of which included a tool for compiling and tracking disclosures and allegations. Phase two of the platform was launched in 2022 and included tools for managing the policy approval process, conducting PII surveys, tracking Code of Conduct certifications, and organizing third-party risk management.

Highlight Stories

Renewable Electricity and Scope 2 Emissions

With the publication of the Company’s Climate Policy in 2021, Equitrans established targets that include a 50% reduction in Scope 1 and 2 methane emissions by 2030 and a 50% reduction in Scope 1 and 2 total greenhouse gas (GHG) emissions by 2040. Since this time, Equitrans has aggressively focused on reducing its direct Scope 1 emissions, which included the replacement of pneumatic devices and the installation of vent gas recovery units during 2022. These activities are expected to directly contribute to a reduction in methane emissions from operations. Additional information and details on the Company’s reduction efforts can be found in the GHG Emissions and Climate Change section of this report.

Equitrans is also working to reduce its indirect Scope 2 emissions, which are emissions related to purchased utilities, such as electric generation and heat. One method of aiding in the overall reduction of indirect Scope 2 emissions is through the purchase of certified renewable energy credits or RECs. Each REC is a certificate that corresponds to the environmental attributes of electricity that is generated from a zero-emissions renewable source and delivered to the electricity grid.

For the year-ended 2022, Equitrans purchased and retired 35,000 Green-e Energy certified RECs for its operations. These purchased RECs represent 35,000 megawatt hours (MWh) of generated renewable energy, which in this case was from wind energy generated in Oklahoma and delivered to the corresponding regional electric grid. By purchasing and retiring these RECs, Equitrans is taking credit for the renewable energy generated and ensuring that it is not accounted for elsewhere in the country. By purchasing these certified RECs, Equitrans was able to account for 100% of its purchased electricity through the supply of zero-carbon renewable energy, as related to its indirect Scope 2 GHG emissions.  

Employee Generosity — Giving Back To Our Communities

Equitrans Midstream is committed to making a difference in our communities, and the United Way is just one way we can join together to support those in need. For our 2022 campaign, we selected the United Way of Washington County as our primary United Way affiliate, which aligns with our Company headquarters’ location. Employees also had the opportunity to donate to the United Way of their choice by selecting from other United Way affiliates located in our primary operating states of Ohio, Pennsylvania, or West Virginia.

To jump start our 2022 United Way campaign, we held a basket raffle during our all-employee meeting and holiday celebration in Morgantown, WV. Employee teams donated 27 individual baskets, with raffle ticket sales raising more than $11,000 in donations. This was matched dollar-for-dollar by our Corporate Local Giving Program, jump-starting our 2022 campaign with a contribution of more than $22,000 to the United Way.

Through our official United Way campaign, which is conducted annually via individual, online donations, Equitrans employees pledged roughly $57,000 in individual contributions, which was matched dollar-for-dollar through the Equitrans Midstream Foundation for a total of approximately $114,000. Additional donations were made outside of our formal campaign, and, based on totals provided by the United Way of Washington County — Equitrans’ contributions totaled more than $169,000 in 2022 — making us the top contributor in their Chairman’s Award for Top 5 Workplace Giving Campaign Partners program.

Equitrans also received the agency’s Campaign Excellence Award, which is presented to a workplace giving campaign partner that puts forth extra effort in running their annual workplace giving campaign. In addition to our traditional campaign, this award was due in part to the hosting of our special to basket raffle event, which engaged all employees and included matching funds by the Equitrans Midstream Foundation and the Company’s Corporate Local Giving Program.

The United Way of Washington County’s mission is to unite people, resources, and organization to improve lives in Washington County. Through Equitrans’ support, the various programs at United Way will be funded to serve the most pressing needs in vulnerable populations within our local operating areas. Our donation is a powerful force for change, and we thank our employees for their generosity and support!

Proactive Project Outreach

Equitrans Midstream relies on proactive community engagement and feedback to foster a culture of trust, inclusivity, and transparency, and we view our projects and operations through a lens of responsibility and accountability. In keeping with this belief, environmental justice is an important component of our stakeholder outreach activities. Our Environmental Justice Policy lays the foundation of our commitment to provide for the fair treatment and meaningful involvement of all people in any public process involving our operations, regardless of race, color, national origin, or income. 

It is often said that actions speak louder than words, which was the case for the outreach team working on our Ohio Valley Connector Expansion (OVCX) project. As a critical component of the project’s pre-planning phase, our team contracted the services of an outside vendor that specialized in the identification of environmental justice communities located near the project. After consulting with the FERC, the EPA, and our contracted environmental justice specialists, Equitrans extended the OVCX project’s landowner contact radius an additional 0.5 mile to maximize the outreach efforts and ensure all stakeholders were personally aware of and involved with the project details.

In addition to our land team contacting property owners and community members within the expanded radius, the OVCX outreach team conducted multiple pop-up educational meetings and community open houses; solicited pre-paid comment and suggestion cards; distributed various informational mailings; and remained engaged with the community every step of the way by responding to questions and feedback. To better understand the needs and challenges faced by those living near the proposed project, we also met with local organizations and elected officials, as well as other key decision makers. These additional, proactive measures taken by our OVCX outreach team went above and beyond regulatory requirements to ensure consistent communication and transparency throughout the project’s lifecycle.  

Inspiring the World to Reuse

As we broaden our sustainability investments, we are especially proud of our partnership with Fill It Forward, an organization whose mission is “to inspire the world to reuse” by focusing on the elimination of single-use waste, such as plastic bottles and bags. In 2021, Equitrans partnered with Fill it Forward as a means of engaging and educating employees, while at the same time elevating our many ESG (environmental, social, and governance) initiatives.

In late 2021, we launched our Fill It Forward campaign with a custom holiday gift box for employees that included reusable tote bags and bottles with individual ‘scan tags’ that acted as a re-use tracker. When the tags were scanned, the data was automatically uploaded to Equitrans’ custom group on the Fill It Forward app and was used for tracking our collective impact, such as waste diverted, emissions saved, and how much ocean pollution was prevented.

Along with helping to eliminate waste, there was a charitable component to our Fill It Forward campaign. Each employee scan unlocked a $1 donation for every reuse, which contributed funds to our chosen charitable organization — DigDeep’s Appalachia Water Project. The funds collected were used to provide clean drinking water through the installation of meter-to-home water lines for families in southern West Virginia who currently have unsafe, limited, or no water at all. Our goal was to generate 10,000 scans and raise $10,000 for the Appalachia Water Project, and we were thrilled to have reached our goal roughly six months into the campaign. In addition, as part of Equitrans’ annual holiday giving initiatives, we made a separate donation of $20,000 to the Appalachia Water Project.

Thanks to the efforts of our employees — Equitrans was the proud recipient of Fill It Forward’s Changemaker Award for 2022. This unique ESG-focused campaign was a means of engaging and educating employees, while also elevating our sustainability efforts. Together with Fill It Forward, we believe that the simple act of reusing is the first step towards creating a sustainable mindset for all generations — and as an added benefit — being able to connect families with access to safe water will ensure the health and success of communities for years to come.

Equitrans Midstream’s Impact
 
19,968.42
lbs of emissions saved

 
617.58
lbs of waste diverted from landfill

 
11,734.02
kwH of power saved

 
123.52
lbs of ocean pollution prevented
20,586
total reuses

Source: Statistics calculated by Fill It Forward, as of year-end 2022

Managing and Protecting Pipeline Integrity

Identification and management of landslide risk is a vital aspect of Equitrans’ daily work activities; however, the risk of a landslide is not limited to the midstream industry. Landslides can occur in any type of terrain, including both hills and valleys, and can be associated with any type of ongoing construction or pre-existing land disturbance. Natural factors such as rainfall and surface runoff water can amplify their frequency or severity; and left unmanaged, landslides have the potential to impact our environment. For Equitrans, this impact may include creating unnecessary strain on our underground pipelines, which are typically located in a variety of terrains as compared to our non-linear assets. To avoid unsafe situations and protect the integrity of our pipeline network, our engineering team uses a multi-faceted approach to aggressively identify and manage areas at risk for potential landslides. 

To identify potential land movement near our assets, Equitrans’ engineers utilize aerial patrols, drones with photogrammetry change detection, and routine on-site inspections — or, if required, a combination of these methods may be used. In each case, we monitor our pipeline rights-of-way looking for any indication of unstable soil, such as discoloration, downed trees, or other data that could indicate a change in topography. Following a thorough evaluation of each asset location or suspected slide area by our engineering and compliance teams, we assign a priority ranking to indicate the potential for further movement and any risk to the environment or to the integrity of the pipeline.

As a final step, Equitrans pairs the geographic location data of known and suspected landslides with National Oceanic and Atmospheric Administration (NOAA) information. This analysis is done on a daily basis and allows Equitrans to identify rainfall events that could affect the stability of existing slide-prone areas and to rapidly respond and investigate when conditions change on the ground. In accordance with a defined framework that accounts for slide priority and rain severity, personnel may be deployed to conduct visual, on-site inspections. Beyond rainfall data, we also monitor temperature data to understand freeze thaw cycles and similarly deploy personnel to evaluate sites under changing conditions. Through continued use of these evaluation tools — aerial inspections, drone imaging, and manual site inspections — Equitrans remains committed to environmental and operational safety through its robust process to identify and manage potential landslides.

In addition, Equitrans launched a Light Detection and Ranging (LiDAR) pilot program in 2020 to aid in the enhanced detection of potential landslides along our pipeline rights-of-way. Today, we conduct semi-annual LiDAR flights across thousands of miles of pipeline. The adoption of LiDAR technology and utilization of our enhanced construction standards are collectively designed to improve Equitrans’ ability to mitigate landslide risk for the safety of our employees and communities, and for the benefit of our customers, investors, and the environment. 

Our Bees Are All The Buzzzzz

At Equitrans, there is a clear tone that begins at the top — sustainability is critically important to the world we live in and is also essential to the future growth of our Company. In 2023, E-Train celebrated Earth Day with the kickoff of a two-year sustainability partnership with Alvéole. Alvéole focuses on bee-friendly communities for greener cities by installing honey bee hives at business locations across the world to foster environmental awareness and educate communities on the importance of creating sustainable bee populations. In fact, according to the U.S. Dept. of Agriculture, honey bees help to produce one-third of our food supply by pollinating $15 billion worth of crops in the U.S. each year, including more than 130 types of fruits, nuts, and vegetables. 

Through our new partnership with Alvéole, E-Train is hosting and supporting two honey bee hives at each of our Canonsburg, St. Clairsville, and Waynesburg offices. The hives were installed in late spring, and the bees have begun to collect nectar and pollinate thousands of flowers and plants. With the help of our assigned Alvéole beekeeper, the hives will become established, and the bees will re-emerge every spring to pollinate flora to grow food and produce E-Train’s own locally sourced honey.

Equitrans and Alvéole also established “MyHive” microsites for each of E-Train’s office locations. The MyHive sites are located on Equitrans’ intranet, and employees can access the sites at any time to find educational honey bee information and receive updates on our hives. As an added benefit, Alvéole beekeepers will conduct various on-site informational events for employees, such as beeswax candle making and honey extraction sessions. 

As we continue to safely and responsibly operate our network of natural gas pipelines, water lines, and compressor stations, it’s important to remember that the decisions we make today have a lasting and positive impact on future generations. On Earth Day and every day, we must hold ourselves to a higher standard by embracing our responsibility to operate in a manner that minimizes impacts on our natural resources and — above all else — we must keep safety our top priority, always.

Productivity … Redesigned

As the world continues to adapt and evolve, companies are re-evaluating their management approach and taking into consideration the individual needs and circumstances of their employees to create work-life harmonization. With the implementation of person-centric leadership practices, Equitrans took the opportunity to redesign how we operate, improving performance and engagement and increasing our ability to compete for talent.

In early 2020, Equitrans began to recognize the benefits of a flexible workplace model. We initiated a deeper dive into the concept by soliciting survey feedback from office-based employees regarding their preferred ‘workplace persona’ preferences (anchor, flex, and remote). Today, we have fully embraced a ‘person-centric’ work environment, which takes into account the physical, cognitive, and emotional needs of employees and encourages them to find the best integration between their work and personal lives. With this approach, work is no longer about where an employee is located, but about the actual work an employee does. Importantly, employees are evaluated on work produced, without consideration to where or how they worked.

Rather than conforming to legacy practices or location constraints, Equitrans’ person-centric work model is defined by flexible work experiences, intentional collaboration, and empathy-based management. For our field-based employees, who are primarily required to work onsite, we rolled out flexible work guidelines to demonstrate our commitment to our person-centric work approach. Upon implementation of this new work model, roughly 44% of employees are working remotely, 25% split their time between working remotely and at an Equitrans location, 31% work from an Equitrans location full-time, and less than 1% work part-time.

We expect our person-centric model will continue to improve employees’ satisfaction and retention, as well as help to expand our talent pool. Since implementing our workplace personas, the number of employees working in other U.S. locations has increased, and we have been able to improve gender diversity. As part of our new work model, we periodically conduct employee surveys and focus groups to obtain feedback, using the results to adjust our workplace practices, as needed.

Office-Centric vs Person-Centric Work Design
Office-Centric Person-Centric

Provide consistent work experiences to deliver equality of experience

Provide flexible work experiences to deliver equality of opportunity

Enable serendipitous collaboration to deliver innovation by chance

Enable intentional collaboration to deliver innovation by design

Drive visibility-based management to deliver performance by inputs

Drive empathy-based management to deliver performance by outcome

Enhancing Methane Monitoring

In January 2023, Equitrans announced its status as a founding member of the newly formed Appalachian Methane Initiative (AMI), a coalition of regional natural gas operators committed to further enhancing methane monitoring throughout the Appalachia Basin and facilitating additional methane emissions reduction in the region. The AMI coalition was formed ‘for the purpose of establishing and effectuating a methane monitoring, reporting, and mitigation network throughout the geographic area known as the Appalachian Basin.’

AMI’s efforts are intended to promote greater efficiency in the identification and remedy of potential fugitive methane emissions from operations in the Appalachian Basin through coordinated satellite and aerial surveys on a geographic-basis as opposed to an operator-specific basis and taking into account advanced methane monitoring and reporting frameworks. Additionally, the coalition will seek to coordinate and share best practices in mitigating methane emissions from natural gas operations, including production and midstream, and collaborate on activities and monitor results through transparent, publicly available reporting. 

For much of 2023, AMI is focusing on developing and implementing a pilot monitoring program to cover select areas of interest within the Basin’s major operating footprints, with the goal of working to develop and implement a full-Basin monitoring plan in 2024.

As part of AMI’s official launch, a news release was issued by the coalition’s founding members. We believe our membership in AMI will support our ongoing methane reduction efforts and complement our many ESG initiatives, and we look forward to working with other coalition members on advancing AMI’s initiatives.

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