
Our Approach to Business Ethics
Equitrans' Core Value of integrity underpins our promise to establish trust with all of our stakeholders. When Equitrans was founded, one of our first priorities was to create a Code of Business Conduct and Ethics (Code) to ensure that all aspects of our business adhere to the same high ethical standards. We routinely evaluate our Code, and update it as necessary, to ensure our ethical standards stay relevant as our Company continues to evolve, upholding our promise to our stakeholders.
Equitrans’ Code defines our approach to everything we do, including all our values, principles, standards, and expectations. The Code applies to employees, officers, directors, contractors, and suppliers, and outlines our approach to doing business in 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
Our Deputy General Counsel, Litigation, Risk, and Compliance directly oversees Equitrans’ Compliance Program and reports all Code compliance matters to the Senior Vice President and General Counsel and assists in finding solutions to relevant concerns. At the Board level, the Audit Committee of Equitrans’ Board of Directors emphasizes ethics and integrity by overseeing Equitrans’ compliance with applicable legal and regulatory requirements and the Code. On a routine basis, the Audit Committee receives reports on compliance investigations and Compliance Program issues to ensure that compliance concerns are adequately addressed at the highest levels in the Company.
Each quarter, our compliance team, with assistance from executive management and human resources, when appropriate, reviews reported incidents and evaluates policy requirements to determine if changes to the Code or our policies are required for improved clarity or to address emerging issues. For example, in 2021, we developed a new Code and Policy Update Approval process that lays the groundwork for adopting new policies or modifying current policies. Recent policy updates include:
- Refreshed the PII (Personally Identifiable Information) Policy to cover COVID-19 data and related medical information
- Revised the "Giving" section of our Gifts and Entertainment Policy to ensure that both giving and receiving gifts/entertainment are emphasized equally
- Replaced our Telecommuting Policy with a new Workplace Modernization Policy, establishing our new workplace structure based on chosen 'workplace personas' (for more information, please see the Workforce Culture section of this report)
In 2021, we made a significant culture shift to encourage all employees to proactively engage with our legal and compliance teams as a resource for questions and guidance, versus solely for conflict resolution. In response, employee requests for policy guidance have increased by more than 100% since 2020. Additionally, this increase does not account for the informal requests for guidance via phone calls, instant messaging, and informal meetings. This mindset shift has proven to be successful and is expected to significantly reduce compliance mistakes through increased team communication and collaboration.
All new Equitrans employees must complete training on our Code and sign an acknowledgement form on our Code within the first few weeks of employment. Existing Equitrans employees must read and sign an acknowledgement form on our Code annually, as well as complete a refresher training course on our Code biennially. Upon request, the Equitrans Code is available in different languages to ensure all employees, contractors, and suppliers understand the Company’s expectations. We expect all employees and third parties with whom we do business to abide by the ethics referenced in Equitrans’ Code. Equitrans’ Board of Directors, the Company’s highest governing body, is required to complete Code of Conduct training every two years. Based on this cycle, our Board will complete this required training in 2022.
In addition to our Code, all Equitrans employees must complete biennial training to refresh their knowledge of Company policies. These online and in-person training sessions ensure an understanding of the Code, as well as other Company policies, including conflicts of interest, preventing workplace violence, sexual harassment, protecting corporate assets, and safeguarding personally identifiable information. Select employees with specific business knowledge must also complete biennial training related to insider trading and antitrust regulations. Specific information related to anti-corruption training, communications, and incidents for 2021 is outlined as follows:
Anti-Corruption Policies/Procedures Communications
|
2021 |
Total Number of Employees
|
749 |
Total Number of Business Partners |
499 |
Anti-Corruption Training
|
2021 |
Total Number of Employees
|
749 |
Incidents
|
2021 |
Total Number and Nature of Confirmed Incidents of Corruption
|
0 |
Total Number of Confirmed Incidents in Which Employees Were Dismissed or Disciplined for Corruption |
0 |
Total Number of Confirmed Incidents When Contracts With Business Partners Were Terminated or Not Renewed |
0 |
Public Legal Cases Regarding Corruption Brought Against the Organization |
0 |
Number of Legal Actions Pending or Completed |
0 |
In 2021, we expanded our training efforts to include mini courses for all employees on the topic of insider trading. Additionally, we developed an incentive program to encourage employees to complete their training(s) in a timely manner. When an employee completes a required business ethics and integrity training within 24 hours, their name is entered into a raffle for a small prize. This initiative has proven to be very effective in ensuring employees take action to complete the Company’s many important training sessions.
For our network of suppliers, Equitrans developed and published a more robust supplier-specific Code of Conduct in 2021. In addition to echoing the expectations within our Code of Conduct, suppliers must also confirm their commitment to a broader set of social workforce policies within our new Supplier Code of Conduct. Equitrans communicates policy updates to our suppliers and contractors through ISNetworld and several internal contractor liaisons.
Evaluating Our Approach to Business Ethics
Equitrans encourages all employees with questions, concerns, and feedback related to Equitrans’ Code to contact their supervisors, Equitrans corporate compliance, or member of our internal compliance network. The compliance network is a group of employees from Equitrans’ health, safety, and environmental (HSE), legal, and human resources (HR) teams.
Members of the compliance network are responsible for facilitating compliance with laws, regulations, and the Code. The compliance network also answers employee and stakeholder questions on the Code and manages misconduct reports.
Employees can reach out to the compliance network through face-to-face meetings or via phone or email. Equitrans also provides a toll-free Compliance Hotline for compliance reporting by phone at (844) 513-8109; or online at equitransmidstream.ethicspoint.com. An independent third-party with expertise in ethics operates our anonymous Compliance Hotline 24 hours a day, seven days a week. If a caller chooses, any call or report made via the Compliance Hotline can be provided anonymously. When an employee calls or reports online, the third-party operator brings any relevant information or concerns to the attention of an internal member of the Equitrans legal department or a corporate compliance department representative for investigation and resolution.
In addition to concerns and misconduct allegations, employees can submit positive feedback and experiences through the Compliance Hotline. In 2021, we upgraded our compliance management software to better manage all compliance processes and operate more efficiently. The new software automates the employee disclosure process (for things like gifts, conflicts, and outside work disclosures) and ensures timely responses to inquiries by tracking disclosed matters from beginning to end.