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 (Code) provides a foundation for our values and sets clear expectations for our employees and all individuals who perform business on our behalf.
- We modified our Code to (i) update the table identifying the members of EQT’s Compliance Network, and (ii) add a new “Human Rights” section.
- We evaluated the progression of our compliance program, resulting in a measurable year-over-year increase in our compliance maturity score.
- We conducted training for our Code for over 1,600 employees, including both existing staff and new hires.
What We Are DoingWhat We Are Doing
Our company values — Trust, Teamwork, Heart, and Evolution — support our culture and enhance our reputation as an organization acting with integrity. We aim to build trust through transparency and accountability, and it is imperative that we do what we say we will do to maintain our close relationships with our stakeholders. We strive to follow through with our promises to do the right thing. For more information, see EQT’s Mission and Values.
We believe each member of our team has a responsibility to maintain and enhance our reputation by applying our values and keeping ethics and integrity at the core of their decision-making. Our values drive the culture we expect our employees to uphold.
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 adaptations.
- Be transparent (which enables collaboration that triggers innovation and leads to evolution).
Our 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 subject matter experts, 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 Chief Legal and Policy Officer and applicable executive management, up to and including our Chief Executive Officer, approve any changes to the Code. Given the materiality of the changes, our Board of Directors (Board) also reviews revisions.
In 2024, we updated our Code to account for title changes and the addition of our Director of Compliance to EQT's Compliance Network. Additionally, we added a new "Human Rights" section to provide a summary of our standards and responsibilities, as detailed under the newly adopted EQT Corporation Human Rights Policy (Human Rights Policy), described below.
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 2024, we published our Human Rights Policy. The policy is intended to guide our corporate decision-making while also providing information on the rights of our stakeholders should they have a concern about our operations. 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. These updates were approved by our Chief Legal and Policy Officer and confirmed by our Board in 2024.
Annually, we require each employee to complete Code training and confirm their continued understanding and compliance with the Code. Our online training related to the Code covers individual topics including workplace misconduct, bribery and anti-corruption, and insider trading. Every new employee must complete a core training curriculum that covers the Code, dignity and respect in the workplace, safeguarding personally identifiable information, and incident reporting as part of the onboarding process. In 2024, over 1,600 employees, including both existing staff and new hires, 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 our Code or their own written code of conduct if it complies with U.S. Federal Sentencing Guidelines and other applicable laws and regulations. We provide annual reminders to our business partners regarding their obligation to comply with our 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, such as setting prices or dividing up customers, suppliers, or markets.
In 2024, we continued our partnership with Gartner to reassess the maturity of our compliance program. The 2024 assessment results demonstrate that we have enhanced compliance effectiveness and program maturity beyond industry benchmarks.
Communicating Concerns
Each year we provide in-person and online training to encourage 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 allow employees to report misconduct and obtain resources to help them do the right thing. All employees have the option to report anonymously. We publicize our Ethics HelpLine phone number and web-intake instructions at each work location, including active field sites, and provide them to our business partners. A nationally recognized, independent service provider operates the Ethics Helpline and is available 24 hours a day, 7 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, a group of senior-level employees from Internal Audit, Human Resources (HR), Compliance and Ethics, Legal, and EHS, provides an additional resource for employees to report suspected misconduct and to seek guidance for ethical and lawful behavior.
Additionally, interested parties may communicate directly with our Board (and with independent directors, individually or as a group) via email sent to independentchair@eqt.com. Our Corporate Secretary, or an appropriate individual on their staff, will receive the communications and promptly deliver the communications to the appropriate director or directors, after filtering out the junk mail, spam, or mass mailings.
How We Are Doing
Our total number of workplace misconduct and substantiated reports increased year-over-year to 19 allegations in 2024. The increase in reports was largely driven by the increase in our workforce, as our headcount rose 70%, with more than 600 employees joining EQT by the end of 2024 due to the Equitrans acquisition. With the increase in employees, we enhanced training materials and strengthened awareness of our Code, which were also likely contributing factors to the rise in reporting in 2024. Despite the rise, EQT still sits more than 50% below the 2022 industry average for misconduct reports, which is 44 allegations.
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 with internal and external stakeholders. We share gathered information and insights among Compliance, Internal Audit, and HR staff to ensure we meet our expectation to do the right thing.
