Topic Highlights
We take pride in operating our business with integrity. Integrity is present in each of our corporate values, and it is the foundation of our success. Our Code of Business Conduct and Ethics provides a foundation for our values and sets clear expectations for our employees and all individuals who perform business on our behalf.
In 2023, we:
- Published the EQT Corporation Human Rights Policy, which is intended to guide our corporate decision-making to ensure our actions align with our values while also providing information on the rights of our stakeholders should they have a concern regarding our operations.
- Completed a new assessment to measure the maturity of our compliance program, which showed a successful increase in our compliance maturity score.
- Achieved 100% compliance with training on our Code of Business Conduct and Ethics.
what we Are doingWhat We are Doing
Our company values — Trust, Teamwork, Heart, and Evolution — support our culture and enhance our reputation as a company acting with integrity. At EQT, our goal is to build trust through transparency and accountability. It is imperative that we do what we say we will do to maintain our close relationships with our stakeholders and communities. We strive to follow through with our promises to do the right thing and keep ethics and integrity at the core of every decision. For more information, see EQT’s Mission and Values.
We believe that each member of our team has a responsibility to maintain and enhance our reputation by applying our values and acting with integrity. Our values drive the culture we expect our employees to always maintain.
TRUST
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Always do the right thing.
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Do what you say you will do.
TEAMWORK
- Work together toward a common goal.
- Share, respect, and embrace diversity of thought.
- Understand our customers.
- Respect the wrench.
HEART
- Care about what you do (actions).
- Care about the relationships you form (impact).
- Bring passion and drive to be the best at what you do (attitude).
EVOLUTION
- Drive to get better every day.
- Understand your environment to prioritize any needed adaptions.
- Be transparent (which enables collaboration that triggers innovation and leads to evolution).
Our Code of Business Conduct and Ethics (Code) provides a foundation for our values and sets clear expectations for our employees and all individuals who perform business on our behalf. The Code acts as a guide and resource related to personal responsibilities, compliance with law, and the use of good judgment. Our Director of Compliance periodically reviews and proposes amendments to the Code and other ethics-related policies as needed, in collaboration with SMEs, to ensure our policies reflect the ever-changing work environment and legal and regulatory landscape. The Code covers a variety of topics, including Environmental, Health, and Safety (EHS); human rights; anti-competitive behavior; conflicts of interest; communication and cooperation with regulators; political involvement; diversity and inclusion; and honest and ethical dealing. Our General Counsel approves proposed changes to the Code, and depending on the materiality of the changes, our Board of Directors also reviews revisions.
Annually, each employee is required to complete Code training and confirm their continued understanding and compliance with the Code. Our online training related to the Code covers individual topics within the Code including workplace misconduct, bribery and anti-corruption, and insider trading. Every new employee is required to complete a core training curriculum that covers the Code, dignity and respect in the workplace, safeguarding personally identifiable information, and incident reporting. In 2023, 100% of eligible employees completed training on our Code.
We expect our suppliers, vendors, agents, contractors, and consultants (collectively, our business partners) to provide services or goods in compliance with the Code or their own written code of conduct if it complies with U.S. Federal Sentencing Guidelines and other applicable laws and regulations. We annually remind our business partners of their obligation to comply with the Code and, specifically, their responsibilities related to conflicts of interest.
Additionally, we support full and fair competition, comply with antitrust laws, and avoid improper practices that may limit competition through illegal or unfair means. We do not enter into agreements with competitors to engage in any anti-competitive behavior, including setting prices or dividing up customers, suppliers, or markets.
In 2022 we partnered with Gartner, a top management consulting firm, to conduct a diagnostic maturity assessment of our compliance program. The results provided measures of functional activity and maturity relative to Gartner’s best practice research and benchmark data. This information helped us establish a compliance program charter, develop an annual compliance strategy, and implement metrics to monitor our compliance health and effectiveness. The assessment evaluated over 2,400 regulations and allowed us to complete control strengthening activities for our priority regulations. During 2023, we completed a new assessment to measure our progress, which showed a successful increase in our compliance maturity score.
Additionally, we recognize that operating responsibly and in alignment with human rights expectations is critical to fulfill our mission to be the operator of choice for all stakeholders. To support this objective, at the beginning of 2023, we published the EQT Corporation Human Rights Policy (Human Rights Policy), which is intended to help guide our corporate decision-making to ensure that our actions align with our values while also providing information on the rights of our stakeholders should they have a concern regarding our operations. Make sure to maintain the hyperlink to the HR Policy. Our Human Rights Policy was developed and approved by our ESG Committee, in coordination with our Director of Compliance and the Public Policy and Corporate Responsibility Committee of our Board of Directors.
Communicating Concerns
Each year we provide in-person and online training to reinforce encouragement for employees to communicate concerns of misconduct to their supervisors, the EQT Compliance Network, or our Ethics HelpLine.
Ethics HelpLine: 1-800-242-3109
www.eqt.ethicspoint.com
Our Ethics HelpLine and web-intake form allows employees to report misconduct and obtain resources to help them do the right thing. We publicize our Ethics HelpLine phone number and web-intake instructions at each work location, including active field sites, and provide it to our business partners. A nationally recognized, independent service provider operates the Ethics Helpline and is available 24 hours a day, seven days a week by phone and web form. We maintain a zero-tolerance policy on retaliation for anyone who makes a good faith report of an alleged Code violation.
The EQT Compliance Network, which consists of a group of senior-level employees from Internal Audit, Human Resources, Compliance and Ethics, Legal, and EHS, is an additional resource available for employees to report suspected misconduct and to seek guidance for ethical and lawful behavior.
Additionally, interested parties may communicate directly with our Board of Directors (and with independent directors, individually or as a group) via email sent to independentchair@eqt.com. Our Corporate Secretary, or an appropriate individual on his staff, will receive the communications and promptly deliver the communications to the appropriate director or directors, unless the communications are junk mail, spam, or mass mailings.
How We are Doing
Our total number of workplace misconduct reports decreased year-over-year, while the percentage of substantiated workplace reports increased. We had 14 reports of compliance violations in 2023, a decrease from 17 reports in 2022. In 2023, 43% of reports were substantiated as actual violations, compared to 35% in 2022.
We use a variety of surveys, scoring systems, and data sources to benchmark our performance against peers and other businesses. This enables us to identify training opportunities, improve policies, and enhance communication to internal and external stakeholders. We share gathered information and insights among Compliance, Internal Audit, and Human Resources staff to ensure we meet our expectation to do the right thing.
