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.

A sizeable gray pipeline segment sits against a blue sky background.

Our Approach to Business Ethics

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
11.11.6
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

2-26
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 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. 

Highlight Story

Storage Integrity Management

To fulfill specific regulatory obligations by government agencies, Equitrans conducts annual audits and inspections required by the Pipeline and Hazardous Materials Safety Administration (PHMSA) and respective state agencies that oversee pipelines and related facilities. To reinforce the importance of public safety, in recent years PHMSA has conducted focused audits on Storage Integrity Management programs. These very intense, detailed audits emphasize both public safety and the environmental impacts of storage methane release. Among other benefits to the industry, this level of scrutiny provides an opportunity for natural gas pipeline operators to review, improve, and strengthen their programs.

Under PHMSA’s direction, Equitrans conducted numerous storage audits from 2018 through 2021 to gauge the strength of our Storage Integrity Management Plan (SIMP) and its adherence to published code. While there were no penalties assessed as a result of these audit activities, Equitrans did receive varying degrees of citations (i.e., Letters of Concern, Warning Letters, and Notices of Amendment) that required us to update our plans, policies, and procedures to enhance our SIMP.

In addition to addressing all cited deficiencies to improve the SIMP, Equitrans instituted the following enhancements to its storage operations:

  • Mitigation of risk by increasing the frequency of well-surveillance logging to every seven years, versus the previous schedule of every 15 years
  • Utilization of Remote Terminal Units on storage wells for 24-hour monitoring by gas control
  • Development and implementation of storage-specific procedures to standardize storage maintenance and operations activities across the Company
  • Dedicating personnel trained specifically for storage operations

As with all of Equitrans’ pipeline integrity programs, our primary focus is on safety — above all else — for our communities, employees, and pipeline facilities. The continued and enhanced safe operation of our storage assets is merely an extension of Equitrans’ overall commitment to safety.

Highlight Story

Emergency Response and Preparedness

In August 2021, flammable vapors from a tank vent ignited during a late afternoon electrical storm at the Equitrans Twilight Compressor Station, a natural gas gathering facility located in Washington County, Pennsylvania. Upon notification of the incident, the Equitrans crisis team quickly convened — no injuries were reported, and no significant damage occurred. 

As part of our response, Equitrans technicians were immediately dispatched and, once on site, began to implement necessary safety procedures, including the closing of appropriate valves to isolate the tank. In addition, the local volunteer fire department was on site to assist with appropriate fire safety protocols.

Equitrans’ emergency procedures and closing of valves successfully allowed the flame to self-extinguish, and within a short time the tank was fully isolated. The Pennsylvania Department of Environmental Protection was notified, and, as a courtesy, local township officials and the Pennsylvania Public Utility Commission received notification of the incident.

Working together with the crisis team, our operations, safety, and compliance teams determined that the ignition occurred as a result of a lightning strike that ignited vapors from a malfunctioning tank vent. After reviewing and understanding the cause of the incident, operations worked with engineering to identify and inspect similar tank vents, as well as tank grounding, to minimize the risk of similar incidents from occurring in the future.

For more information on Equitrans Emergency Response and Preparedness, please visit: Public Safety and Emergency Response.

Highlight Story

Workplace Modernization

Recognizing the potential benefits of a flexible work model, Equitrans conducted a workplace modernization survey in June 2020, whereby office-based employees were asked to rank their workplace preferences based on a set of three “workplace personas” (anchor, flex, and remote). The next step in the process was for managers to review all positions in their departments and assign a workplace persona, or personas, to each position, based on the defined requirements of role. The final step was for employees to select their workplace persona based on the persona(s) assigned to their role.

Our workplace modernization activities, however, did not end there. As we and other companies prepared for the new normal of a larger remote workforce, E-Train recognized there would be concerns to address and conflicts to resolve — and our goal was to ensure a smooth transition as overall workplace plans were finalized. To replace our previous Telecommuting Policy, we implemented a new Workplace Modernization Policy, which includes topics such as workplace persona guidelines, relocation approval process, business travel expense protocol, and how to formally request a workplace persona assignment change.

Additionally, to assist our employees with changes related to our return-to-office (RTO), we communicated workspace scheduling information and general tax expectations (for remote employees), and created two RTO Guides:

  • The RTO Guide for Managers was intended to help managers prepare for working with their teams in the new era of a “distributed environment.” The guide contains key details for managing successfully in a distributed environment, including tips for utilizing shared workspaces; how to determine when it may be most effective for a manager and their team to work in the office; and how a manager can partner with their team to establish best practices and facilitate a collaborative and engaging working environment — ensuring continued performance in line with our Core Value of Excellence. Managers were asked to maintain an inclusive, forward-thinking environment that values the person as a whole instead of focusing on only the work that they produce and were reminded to always place safety first.
  • The RTO Guide for Employees contained FAQs about workplace personas; tips and recommended etiquette for working in a shared workspace; how to determine when it may be most effective to work in the office; best practices to ensure success; and the importance of keeping safety our top priority.

With the reopening of our offices in April 2022, roughly 61% of office-based employees are working remotely (remote persona), 37% split their time between remote and at an Equitrans location (flex persona), and 2% are working in the office full-time (anchor persona). We expect our workplace modernization model to improve employee satisfaction and retention, expand our talent pool, and create additional flexibility for our employees, while promoting continued business execution.  

Highlight Story

Culture Change Belongs to All of Us

Our goal is to create a workforce culture that is not only aligned with our values, but also inspires employees to be their best selves. Based on the findings of our initial culture assessment conducted in 2020, we implemented several culture enhancing initiatives that were aligned with our mission, vision, and strategy — including redesigning our employee recognition program, introducing 360-degree management assessments and coaching, and launching an on-demand learning platform.

In 2021, we conducted our second culture survey, which had a 78% participation rate and highlighted significant, double-digit percentile increases across all 48 culture survey questions. In conjunction with our Culture Champions Group, we attribute these culture score improvements to the many action items we implemented since conducting our previous assessment.

The survey platform we utilize measures organizations across four areas: Mission, Consistency, Involvement, and Adaptability. While we were encouraged by the results, we also recognize there are areas that require continued focus to improve our culture. Below are a few key highlights from our recent survey:

Leveraging Our Strengths

  • We are very strong in the areas of teamwork and agreement — illustrating strong coordination across departments, the elimination of silos, and alignment with our Core Values, which highlights a strong sense of right and wrong.
  • We had positive shifts in how we use our Core Values to guide our decisions & the perceptions of leaders who demonstrate these values.
  • We scored near the 95th percentile on most of the safety aspects, something we are very proud of as we continue to elevate our strong safety culture.

Taking Action

Based on the opportunities for improvement, we are implementing several action items that are linked to three primary focus areas:

  • Customer Focus: The best way to define Customer Focus is with a question — “When we get a request from a fellow employee, do we treat that request as if it came from a customer?” The success of our Company depends on all employees — from maintaining safe operations, ensuring system reliability, and designing system enhancements to closing our books, scheduling projects, running payroll, and managing our legal and regulatory concerns. As we strive to be a reliable partner inside and out, in 2022 we added customer service to our Core Value of Collaboration; and we are implementing initiatives to improve our internal customer service and ensure the timely exchange of information requests.
  • Strategic Direction & Intent: Employees understand the importance of connecting the dots between our strategy and their day-to-day work. Based on survey feedback, we will continue to publish our quarterly Strategic Priorities Update and schedule all-employee meetings to communicate progress on our Company’s annual priorities and objectives, which helps employees to align their individual objectives. Achieving our Company goals takes teamwork, collaboration, and individual contributions by everyone.
  • Capability Development: As people leaders, we want to take a more active role in the development of our employees, helping them to understand and explore opportunities for advancement. To support our managers, we rolled out training during 2022 to assist managers in having effective career conversations with employees, encouraging an open dialogue on opportunities for growth and skill development. We also updated our Core Value of Excellence to include employee capability development — reinforcing the importance of helping to improve the capabilities of our employees as a competitive advantage. 

At Equitrans, culture change belongs to all of us, and each employee plays a vital role in achieving our vision of becoming the premier midstream company in North America. Our employees’ continued commitment to E-Train’s success is demonstrated by staying the course — effectively managing our business and running our operations safely, efficiently, and responsibly.

Highlight Story

Distracted Driving Awareness

Distracted driving is an important safety issue — whether we are traveling for work or transporting friends and family during our personal time. The tragic results of distracted driving can happen to any one of us, anywhere, and at any time. Furthermore, these distractions come in many forms and can be caused by a number of factors, such as driving while using a communications device, tending to others who are in the vehicle, using your vehicle’s audio system, or simply observing scenery as we pass it on the road. 

 In response to an increase in preventable vehicle accidents in 2020, Equitrans’ safety team created a Safe Driving Stand-Up, whereby supervisors were tasked with encouraging their teams to focus on changing their driving behaviors to better ensure everyone’s safety. In 2021, we placed additional emphasis on vehicle driving safety through our Companywide Distracted Driving Awareness initiative, which included encouraging employees to sign a distracted driving pledge as a symbol of their commitment to drive safely, be in the moment, and remain focused on the task-at-hand.

With more than 500 employees in attendance, Equitrans’ Distracted Driving Awareness campaign kicked off with a presentation by Joel Feldman, renowned distracted driver speaker. Mr. Feldman is an attorney from Philadelphia who, despite representing those impacted by distracted driving crashes, frequently drove distracted himself. Following the death of his daughter in an accident caused by a distracted driver, he changed the way he drives and the way he thinks about driving safety. In 2011, he founded EndDD.org (End Distracted Driving) and spends the majority of his professional time working to educate people about this issue — with the goal to reduce distracted driving incidents of all kinds.

Mr. Feldman shared some very powerful and personal messaging, along with several important reminders that focused on how to change driving behaviors to better ensure one’s personal safety, the safety of their passengers, as well as the safety of everyone on the road. In addition, the Equitrans Midstream Foundation expanded these important safe driving messages by partnering with EndDD to bring Mr. Feldman’s presentation to four local high schools in our Pennsylvania operating area.

In 2022, our Foundation is pleased to continue its partnership with EndDD by supporting the creation of a nationwide public service campaign geared toward preventing distracted driving among high school students.

Equitrans believes that having a safe-driving mindset should extend beyond the workplace, and we want our employees to be equipped to prevent distractions while driving for both work and personal travel. With safety as our top priority and number one Core Value, the more we share the importance of learning how to NOT DRIVE DISTRACTED, the safer all of us will be.

Highlight Story

Philanthropy and Volunteerism

Equitrans Midstream supports the development of a sustainable workforce, which we believe is a key element for the long-term success of our Company and our communities. Preparing local students to compete in the workforce is a funding priority of the Equitrans Midstream Foundation — connecting students now with the tools they need to make positive social and economic contributions in the future. Through our E-Train On-Track committee, we also support employee volunteerism and encourage employees to donate their time in support of community-based educational initiatives. 

The Education Partnership is a local non-profit organization that distributes school and classroom supplies at no cost to students and teachers in need. When the organization approached us with an opportunity to provide assistance and support for Pennsylvania schools, ranging from pre-K through grade 12, we enthusiastically volunteered both our funding and time. In 2021, through a $32,000 grant to The Education Partnership’s Adopt-a-School program, the Equitrans Midstream Foundation purchased essential school supplies for students in three southwestern Pennsylvania schools. Using our Volunteer Paid-Time-Off Program, these funds were amplified by Equitrans employees who volunteered their time to assemble more than 1,230 Power Tools Homework Kits for distribution to the students. A team of employees then attended assemblies at one of the participating high schools to conduct mini-educational sessions to discuss jobs and careers in the energy industry.

During the past two years, the Foundation has awarded $50,000 to The Education Partnership. By combining proposed funding opportunities with employee volunteerism, Equitrans can provide a greater level of community support, while at the same time encouraging employee involvement and increasing overall engagement. Our work with The Education Partnership is one example of Equitrans’ commitment to the communities in which we live and work — delivering positive impacts through both financial support and employee volunteerism. 

Highlight Story

Protecting Our Critical Energy Infrastructure

With cyber-attacks on the rise in nearly every industry sector, including those related to oil/gas pipelines, there is a heightened need for teamwork and collaboration to protect our nation’s energy infrastructure. We recognize the important joint efforts of pipeline operators, government agencies, vendors, and industry groups in developing solutions to combat the complex challenges of an ever-changing cybersecurity landscape. The formation of this alliance is based on a common goal: keeping our critical infrastructure safe, secure, and reliable.

To ensure adequate resources and elevate the criticality of our industry’s cyber initiatives, Chief Executive Officers and Chief Information Officers from our nation’s major pipeline operators, as well as top leaders from various government agencies are aligned on this priority. In addition, with this level of attention and focus on cybersecurity, responsibility has gone beyond Information Technology personnel. To be truly effective, cybersecurity requires multi-disciplinary leadership involvement from other business functions, such as physical security, emergency management, facilities, legal, and supply chain.

As a natural gas pipeline operator, Equitrans Midstream transports roughly 10% of U.S. natural gas production every day, making it critical for us to know and understand the latest threat intelligence. With the knowledge gained through these industry and government relationships, we are better prepared to implement leading practices designed to counter evolving attack vectors.

At Equitrans Midstream, we believe forming a cybersecurity partnership has helped raise the security bar across the industry, resulting in a collective benefit that is beyond what any individual pipeline operator could achieve. By working together on cybersecurity initiatives, we are striving to make the natural gas pipeline sector more secure, while at the same time continuing to provide the critical energy resources on which our nation relies.

     – Carmine Fantini, CIO, Equitrans Midstream

The continued evolution of cybersecurity threats demands a holistic response from industry, government, and suppliers. Equitrans recognizes this reality, and we work diligently every day to enhance our strong public/private sector alliance — strengthening our capabilities to protect our critical energy infrastructure.

Close button for share
SHARE