Governance

Supply Chain Management and Human Rights

Equitrans credits much of its success to the commitment and performance of our supply chain, which includes all third-party providers involved and connected with our Company, such as contractors, vendors, and suppliers. We believe the perspectives obtained through the inclusion of companies of varying backgrounds in our supply chain position the organization as a more effective business, capable of impacting a wider range of communities, and provide greater opportunity to limit the Company’s exposure to supply chain disruption. We recognize that a sound, sustainable, and ethical supply chain is important to our business operations, as well as our reputation. Equitrans is committed to working with suppliers who share our values and are dedicated to the same high standards for quality, safety, and environmental responsibility.

There are a dozen stacked pipeline segments on an Equitrans outdoor worksite.

Our Approach to Supply Chain Management and Human Rights

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Activities, value chain and other business relationships

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Explanation of the material topic and its Boundary

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11.14.6
Proportion of spending on local suppliers

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

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11.10.9
Negative social impacts in the supply chain and actions taken

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3-3
204-1
406-1
414-1
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Managing a responsible supply chain is critical to our business success. Our core values guide all that we do, from the way we treat our employees to how we interact with the broader community. We believe in being good stewards of the environment, promoting diversity and inclusion, and operating with integrity in everything we do. We expect the same from our supply chain partners.

When selecting providers, Equitrans involves organizations from the local operating area and seeks groups with diverse ownership backgrounds. We strive to give voice and value to minority and locally owned businesses. We select and manage third-party organizations that believe in and abide by Equitrans’ Core Values and demonstrate respect for human rights. We also prioritize suppliers that focus on safety performance and compliance, diversity and inclusion, and environmental stewardship. When we work with businesses that share our values, we are able to build trust and create lasting relationships, which contribute to our long-term success and sustainability goals. Additionally, a diverse supply chain helps to drive innovation, safety, and economic value for the minority and local communities in which we engage.  

Supply Chain Integrity and Ethics

Contracts for new suppliers incorporate Equitrans’ Code of Business Conduct & Ethics (Code) to ensure our standards and expectations are clear. Our Code details Equitrans’ standards on ethical behavior and actions as well as resources to address any Code questions or concerns. Each year, Equitrans sends a compliance letter to refresh select suppliers on Code obligations. In 2021, Equitrans utilized a total of 963 suppliers and 499 of those suppliers received an annual compliance letter from our legal and compliance team. The list of supplier recipients is based on certain criteria, such as excluding suppliers with spend of less than $10,000 and/or law firms that must follow their own Code of Conduct as part of their licensing.

Should an instance of non-compliance with our Code occur, Equitrans’ Compliance Network undertakes an investigation to identify the root cause. Our Compliance Network responsibilities include ensuring conformity with laws, regulations, and our Code in all areas of our business. Suppliers that are non-compliant with Equitrans’ requirements are subject to immediate remedial action or contract termination.  In 2021, Equitrans did not terminate any of its contracts with third parties as a result of non-compliance and, as is our practice, we will continue to have an open-dialogue with our suppliers should an issue arise.

In 2021, Equitrans developed and published more robust supplier-specific Code of Conduct. In addition to echoing the expectations in Equitrans’ Code, suppliers must now confirm their commitment to a broader set of social workforce policies specific to suppliers. Equitrans communicates policy updates to our suppliers and contractors through ISNetworld, as well as through several internal contractor liaisons. During 2021, Equitrans sent the Supplier Code of Conduct to active suppliers who provided $10,000 or more in services. A total of 423 suppliers (more than 90%) provided digital acknowledgement of receipt.  The small number of suppliers who did not acknowledge Equitrans’ Supplier Code of Conduct are each already obligated to comply with similar internal policies, which have been reviewed and determined to meet Equitrans’ standards for suppliers.

Diversity in Our Supply Chain

Equitrans is committed to diversity and inclusiveness throughout our organization, including our supply chain. We recognize that management of a diverse range of suppliers benefits the local community, as well as the viability of the overall economy. As an element of our sourcing practices, Equitrans emphasizes the inclusion of local suppliers, which helps us reduce our environmental footprint and gain valuable insight into the culture of our operating areas. Equitrans defines a local supplier as any materials or service provider that receives payment in one of our primary operating states of Pennsylvania, West Virginia, or Ohio.

Local Suppliers: 59% of our total supply chain budget utilized on local suppliers.

We also include diverse-owned organizations, when feasible. Since 2018, Equitrans’ share of expenditures awarded to minority-, women-, and veteran-owned businesses has been steadily monitored and tracked, and we will continue to seek opportunities to build on our existing supplier base while establishing new relationships with diverse suppliers.

Five Equitrans employees are wearing PPE while assembling a pipeline in a shallow trench at a construction site.

Human Rights

Equitrans Midstream has a zero-tolerance policy for any form of human rights abuse, including forced labor, child labor, and harassment or discrimination. We recognize that the nature of our business activities and existing operational footprint do not generally encounter a significant risk of negatively impacting the basic principles of human rights. Regardless, this does not diminish our commitment to respect human rights in all our actions with employees, local communities, customers, and other stakeholders. We work with our business partners to ensure they share our commitment and have similarly rigorous policies and protection measures in place. Equitrans promotes the preservation of human rights through:

  • Promoting inclusion
  • Having zero tolerance for discrimination
  • Protecting employees’ rights to form unions and collectively bargain
  • Prohibiting the use of modern slavery, human trafficking, forced labor, and child labor
  • Guaranteeing fair work hours, compensation, and benefits

We will conduct appropriate due diligence to ensure we maintain that commitment and strive to create open channels of communication with anyone potentially impacted by our activities. For more details regarding our commitment to human rights, please see our Human Rights Policy.

Evaluating Our Supply Chain Management

Equitrans hires and manages suppliers based on their ability to adhere to Equitrans’ Code, Equitrans’ Supplier Code of Conduct, regulations, safety, and ESG standards. Suppliers must undergo an extensive onboarding process through an online supplier management database. Our supply chain and safety departments partner to determine Equitrans’ scorecard and grading requirements. Suppliers submit questionnaires, safety programs, and insurance documentation for review and are required to achieve a passing grade before we execute a master agreement or issue purchase orders.

We maintain a low-risk supplier base that is 99% domestic and, therefore, are required to comply with U.S. labor laws. During the onboarding process, new suppliers receive the master agreement and Supplier Code of Conduct, outlining Equitrans’ Human Rights Policy to reinforce our expectations for ethical, legal, and socially responsible business practices. Equitrans does not tolerate non-compliant suppliers. Should Equitrans find a compliance issue, we work diligently with the provider to resolve and re-establish compliance. If a resolution cannot be obtained, Equitrans will terminate the supplier contract. We take our Code, Supplier Code, and safety standards seriously and expect all contractors and suppliers to uphold our Core Values. Equitrans tracks, analyzes, and reviews supply chain data on a routine basis to identify gaps and areas of improvement, and we continue to identify ways to increase diversity in our sourcing activities.

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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.

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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.

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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.

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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.

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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.  

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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.

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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. 

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