Ethics and Integrity

Why It Matters to Us

In 2022, we continued to build our culture around our company values — Trust, Teamwork, Heart, and Evolution. Each employee has a responsibility to carry out our values and enhance our reputation as a company 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 stakeholders and communities. We continue to follow through with our promises of doing the right thing, keeping ethics and integrity at the core of every decision.

What We Are Doing

Policy Commitments
Embedding policy commitments
SASB EM-EP-510a.2
Description of the management system for prevention of corruption and bribery throughout the value chain
SASB EM-EP-510a.2

We believe that each member of our team is responsible for maintaining and enhancing our reputation by acting with integrity. Our values drive the culture we expect our employees to always maintain.

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  • Always do the right thing.

  • Do what you say you will do.

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  • Work together toward a common goal.
  • Share, respect, and embrace diversity of thought.
  • Understand our customers.
  • Respect the wrench.

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  • 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).

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  • 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 judgement. Our Director of Compliance revises 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, conflicts of interest, communication and cooperation with regulators, political involvement, diversity and inclusion, and honest and ethical dealing. Our General Counsel and applicable executive management, up to and including our Chief Executive Officer, approve any changes to the Code. Depending on the materiality of the changes, the Board of Directors also review revisions. 

Annually, all employees are required to complete Code training and confirm their continued understanding and compliance with the Code. We provide a curriculum of online training relating to the Code and individual topics covered within the Code such as workplace misconduct, bribery and anti-corruption, and insider trading. We also provide a core curriculum of training on the Code, safeguarding personally identifiable information, and incident reporting that is required for every new employee. 

Our suppliers, vendors, agents, contractors, and consultants (collectively, our business partners) are also 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 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.

In 2022, we internally published a Foreign Party Due Diligence Process Document. Third-party due diligence is an independent assessment conducted by internal and external resources to gather vital information and enable leadership teams to make informed decisions about who they do business with and in what capacity. It is also an essential function for organizations to understand their potential liability under anti-corruption laws and other legislation. EQT’s Foreign Party Due Diligence Process Document outlines the processes, materials, and resources available to ensure that EQT’s payments to foreign businesses and government officials are aligned with the Foreign Corrupt Practices Act. This early due diligence provides opportunities for our Compliance team to put mitigation activities in place to reduce our risk of exposure to high-risk individuals or businesses.

Additionally, in 2022 we partnered with Gartner, a leading 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 is being used to help us develop compliance initiatives with the strongest impact and help evolve our compliance program to exceed benchmark maturity during 2023.

communicating concerns

Mechanisms for seeking advice and raising concerns
Process to remediate negative impacts

Although the Code provides strong guidance for our employees and business partners, it cannot be all-inclusive. On an annual basis, we provide in-person and online training to reinforce 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

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 seek guidance regarding ethical and lawful behavior and to report suspected misconduct. 

Our Ethics HelpLine allows our employees to call and report misconduct and obtain resources to help them do the right thing. We also offer an Ethics HelpLine web-intake form as an additional way to report misconduct and ask questions anonymously. The Ethics Helpline web-intake form provides an alternative medium for employees to report misconduct or express concerns, as we realize that some employees may feel more comfortable reporting misconduct electronically and in written form rather than over the phone.

We publicize our Ethics HelpLine phone number and web-intake instructions at all our work locations, including active field sites, 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. 

Additionally, interested parties may communicate directly with our Board of Directors (and with independent directors, individually or as a group) by sending an email to 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 unless the communications are junk mail or mass mailings.

How We Are Doing

We had 17 reports of compliance violations in 2022, an increase from 14 reports in 2021. In 2022, 35% of reports were substantiated as actual violations, compared to 71% in 2021. The total number of workplace misconduct reports has increased year over year; however, the number of substantiated workplace misconduct reports has decreased. This is especially positive given EQT’s total headcount has continued to increase year over year. This trend highlights the importance of an appropriate compliance and ethics communication strategy and training curriculum for our increasing employee population.

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. 

All our employees who were assigned to receive training on our Code in 2022 completed such training. 

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