governance
Ethics and Integrity

Why It Matters to Us

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Explanation of the material topic and its Boundary

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In 2019, we introduced our new company values — Trust, Teamwork, Heart and Evolution. Each EQT employee has a responsibility to carry out our values and enhance our reputation as a company with integrity. It is imperative that we do what we say and do the right thing, as all EQT stakeholders expect this of us. Trust from our communities and other stakeholders is imperative to our ability to operate.

What We Are Doing

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The management approach and its components

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Values, principles, standards and norms of behavior

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Communication and training about anti-corruption policies and procedures

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Description of the management system for prevention of corruption and bribery throughout the value chain

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SASB EM-EP-510a.2

At EQT, we firmly believe that each of us is responsible for maintaining and enhancing our reputation by always acting with integrity. Our values drive the culture we expect employees to maintain at all times.

TRUST

Always doing the right thing.

 

Doing what you say you will do.

TEAMWORK

Working together toward a common goal.

 

Sharing, respecting and embracing diversity of thought.

 

Understanding customers.

 

Respecting the wrench.

HEART

Caring about what
you do (actions).

 

Caring about the relationships you
form (impact).

 

Bringing passion and drive to be the best at what you do (attitude).

EVOLUTION

Driving to get better every day.

 

Understanding your environment to prioritize any needed adaption.

 

Being 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 judgement. Our Compliance and Ethics Program Manager revises the Code and other ethics-related policies when needed, in collaboration with subject matter experts, to ensure our policies reflect the ever-changing work environment and legal and regulatory landscape across the many topics covered: environment, health and safety, human rights, avoiding conflicts of interest, communicating and cooperating with regulators, political involvement, diversity and inclusion, honest and ethical dealing and other topics. Our General Counsel and applicable executive management, up to and including the Chief Executive Officer, approve any changes to the Code. Depending on the materiality of the changes, revisions are also reported to the Board of Directors.

Annually, all employees must confirm their continued understanding and compliance with the Code. We provide a core curriculum of online training on the Code and individual topics covered within the Code such as bribery and anti-corruption. This core curriculum is required for every new employee and biennially for all employees, and supplemented with additional courses depending on job responsibilities.

Our suppliers, vendors, agents, contractors and consultants (collectively, our business partners) are expected to provide services or goods in compliance with the Code or their own written code of conduct, if it complies with the U.S. Federal Sentencing Guidelines and all applicable laws and regulations. We annually remind the majority of our business partners of their obligation to comply with the Code and, specifically, their responsibilities related to conflicts of interest.

communicating concerns

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Mechanisms for advice and concerns about ethics

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Although the Code provides strong guidance for our employees and business partners, it cannot be all-inclusive. We annually provide a combination of in-person and online training to reinforce the message that employees are encouraged to communicate concerns of misconduct to their supervisors, the EQT Compliance Network or the Ethics HelpLine.

Ethics HelpLine: 1-800-242-3109

www.eqt.ethicspoint.com

The EQT Compliance Network, which consists of a group of senior-level employees from Internal Audit, Human Resources, Compliance and Ethics, Legal and Environmental, Health and Safety, is another resource available to employees to seek guidance regarding ethical and lawful behavior and report suspected misconduct.

We have historically maintained a Compliance Hotline for employees to be able to call and report misconduct anonymously. In December 2019, we rebranded the Compliance Hotline as the Ethics HelpLine. The name was changed in an effort to be more welcoming to employees and to remind them that the Ethics Helpline is a resource available to help them to do the right thing.

In the beginning of 2020, we introduced our Ethics HelpLine web-intake form as an additional way to report misconduct and ask questions anonymously. We wanted to establish a new medium for employees to feel safe speaking up, and we realized that some employees may feel more comfortable reporting misconduct electronically and in written form as opposed to over the phone.

We publicize our Ethics HelpLine phone number and instructions for how to access our web-intake form at all of our work locations and provide it to our business partners so they may anonymously ask questions or report suspected misconduct. The Ethics HelpLine is operated by a nationally recognized, independent service provider and is available 24 hours a day, seven days a week by phone and web form. We maintain a zero tolerance policy concerning retaliation for anyone who makes a good faith report of an alleged Code violation.

We had 26 reports of compliance violations in 2019, a decrease from 92 reports of violations in 2018. In 2019, 46% of reports were substantiated as actual violations, compared to 53% in 2018. Two factors likely drove the decrease in reports and violations in 2019. First, our number of employees decreased by approximately 50% following the separation and spin-off of our midstream business to Equitrans Midstream Corporation in November 2018. Second, 2019 was a year of evolution at EQT. Significant changes were made — to personnel, processes, procedures and culture. While we believe that our new operational and cultural approach, and our focus on becoming a values driven organization, helped lead to the decrease in violations, we cannot ignore that some employees also experienced confusion and uncertainty about what their role would be or if they had a future at EQT, which could have led to fear of speaking up during our period of transition. As noted above, we have attempted to alleviate any such reservations by increasing the publication of the Ethics Helpline phone number and instructions for accessing the web-intake form, providing new ways to anonymously report violations, and generally better educating employees as to the accessibility and ease of reporting through the Ethics Helpline.

How We Are Doing

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Evaluation of the management approach

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We utilize a variety of surveys, scoring systems and data sources to benchmark our performance alongside peers and other businesses. This enables us to identify training opportunities, policy improvements and improve 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.

In 2019, 100% of our employees assigned to receive training on our Code completed the training.

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