EX-11 9 exhibit11.htm EXHIBIT 11 CODE OF CONDUCT
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- Equinor, Annual Report on Form 20-F 2021
1
Code of
Conduct
Dear Colleague,
Our vision for Equinor is to be recognised as a
company that is shaping the future of energy. Our innovative, open and collaborative
culture is
central to realising this vision. In Equinor, how we deliver is as important
as what we deliver. I strongly believe that an ethical business
culture
is the cornerstone of a sustainable company.
This Code of Conduct is your guide to ethical
business practice. It reflects our values and
our belief that conducting business in an ethical and
transparent manner is not just the
right
way to work, but is the
only
way to work. The Code of Conduct includes
mandatory requirements for
everyone who works on behalf of Equinor. My expectation is that
the Code of Conduct, together with your good
judgment, will lead you to the
right decisions. You should seek guidance from your leader or other internal resources
referred to in the Code of Conduct
if you are uncertain
on how to proceed.
Fundamental changes are happening in our industry
which has a key role in the energy transition
towards a net zero society. From geopolitics
and energy markets to our industry and our climate,
we face new realities. But our commitment
to high ethical standards in our business
operations stays firm. It is more important than
ever to earn the trust of our stakeholders – our people,
our owners, our business partners and
our communities. The Code of Conduct will assist
us in earning and sustaining this trust and in
building a prosperous company for the future.
We must work together to create our future Equinor.
I want Equinor to continue to be a leader
in ethical business conduct. I expect that
you carefully consider your business decisions to ensure
that they are in line with the Code of Conduct. Only
then will we maintain Equinor’s reputation
and continue to earn the trust that allows
the
company to succeed with our vision – the Equinor
Way.
Anders Opedal
President and CEO
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Equinor, Annual Report on Form 20-F 2021
Table of contents
1 The Equinor Way
1.1 Equinor’s Commitment
1.2 Our Code of Conduct
1.3 Your Responsibilities
1.4 Responsibilities for Leaders
1.5 Asking Questions and Reporting Concerns
1.6 Ethics Helpline
1.7 Non-Retaliation Policy
1.8 Consequences of Breaches
1.9 Ethics and Compliance in Equinor
2 Respecting our People
2.1 Equality, Diversity and Inclusion
2.2 Harassment and Intimidation
2.3 Safety and Security
2.4 Privacy and Data Protection
2.5 Drugs and Alcohol
2.6 Purchase of Sexual Services
3 Conducting our Operations
3.1 Anti-Corruption
3.2 Conflict of Interest
3.3 Directorships and Ownership Interests
3.4 International Trade Restrictions
3.5 Anti-Money Laundering and Facilitation of Tax Evasion
3.6 Financial and Business Records and Reporting
3.7 Property and Assets
3.8 IT Systems
3.9 Information Management and Confidentiality
3.10 Inside Information
4 Relating to our Business Partners
4.1 Suppliers and Business Partners
4.2 Intermediaries
4.3 Fair Competition
4.4 Gifts, Hospitality and Expenses
5 Communities and Environment
5.1 Community Engagement
5.2 Environment
5.3 Public Communication
5.4 Public Affairs
5.5 Public Officials
The Code of Conduct will be printed in updated
versions when deemed necessary. However, any changes will be updated in the electronic
version as and when required, and this will always
represent the most recent edition.
English and Norwegian are the official versions.
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- Equinor, Annual Report on Form 20-F 2021
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1 The Equinor way
1.1 Equinor’s Commitment
Our ability to create value is dependent on applying
high ethical standards to create a trust-based relationship
with our people, our owners, our
business partners and our communities.
In our business activities, we will comply with
applicable laws, act in an ethical, sustainable and
socially responsible manner and practice good
corporate governance. We will conduct our business consistently
with the United Nations Guiding Principles on
Business and Human Rights
and the ten Principles of the Global Compact, in
the manner as set out in our Human Rights
Policy. We support the Paris Climate Agreement
and the UN Sustainable Development Goals. We will maintain
an open dialogue on ethical issues,
internally and externally.
1.2 Our Code of Conduct
The Code of Conduct (the Code) sets out our
expectations, commitments and requirements
for ethical conduct. The Code applies to Equinor’s
board members, employees and hired personnel.
The Code reflects our values: Open, Collaborative,
Courageous, and Caring. The Code includes
our most important requirements, provides
references to more detailed requirements in our governing
documents and refers to other helpful resources.
However, the Code does not
remove the need for you to exercise good judgment.
The Code has been approved by the Equinor’s
Board of Directors and provided for in
The Equinor Book.
Additional requirements and helpful tools
●
Equinor Book - App. G Human Rights policy
1.3 Your Responsibilities
We set high ethical standards for everyone who acts
on Equinor’s behalf. It is your responsibility
to comply with the Code, both in letter and
in
spirit. You are also responsible for complying with other governing documents and
applicable laws relevant to your work.
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Equinor, Annual Report on Form 20-F 2021
What this means to you
●
Familiarise yourself with the Code as well as other
governing documents and applicable laws
relevant to your work.
●
Act comfortably within our ethical standards and within
the law. Operating in a grey zone increases the risk of things
going wrong.
When in doubt, disclose the issue to your leader
and discuss it openly.
●
Spend sufficient time on difficult decisions and raise issues early. The wrong decisions
are often taken when things have not been
thought through properly and you are pressured into
taking a rash decision.
●
If there is a difference between a legal requirement and
the Code, apply the most stringent standard.
●
Participate in required ethics and compliance training and
confirm annually that you have familiarised yourself and
will comply with
the Code.
1.4 Responsibilities for Leaders
We are committed to recruit and continuously develop
the best leaders for our company. We expect our leaders to demonstrate ownership
and
commitment to our ethical standards by what they
say and do. As a leader you must ensure
that activities within your area of responsibility
are
carried out in accordance with the Code, other
governing documents and applicable laws.
What this means to you
●
Be a role model for ethical leadership through
promotion of compliance and ethics. Show
by behaviour what it means to act with
integrity.
●
Communicate the requirements in the Code and provide
advice with respect to its interpretation and
application.
●
Create an environment where people feel comfortable
speaking up and asking questions without risk
of retaliation.
●
Be consistent when enforcing our standards and
holding people accountable for their behaviour
at work.
●
Make sure your team members participate in required
ethics and compliance training.
1.5 Asking Questions and Reporting Concerns
The Code aims at being as clear and
direct as possible, but it cannot address every
situation that may arise. We have an open
communications policy, and you should raise questions or seek advice when
you are uncertain on how to proceed in any given
situation.
If you suspect a possible violation of the Code or other
unethical conduct, it is your duty to
report this immediately. This includes any attempt of
corruption you may become aware of. We recognise that
raising a concern is not always easy and we
have several channels for taking
concerns forward.
What this means to you
●
Inform your leader immediately if you become aware
of any activity that you think is a violation of
the Code. Alternatively, you can
contact your leader’s superior.
●
If you do not feel comfortable with those options,
you can contact your local human resources representative,
your local compliance
officer or the ethics and compliance function.
●
If you are uncomfortable using any of these channels,
you can report your concern to the Ethics
Helpline.
●
You may use the same channels to ask any questions regarding compliance with
the Code.
●
General questions regarding the interpretation of
the Code may also be addressed to Service@Equinor.
1.6 The Ethics Helpline
The Ethics Helpline is a multi-language service available
24 hours a day, 7 days a week and provides a toll-free phone service
and a web
submission portal. It is available for any person
who has a legitimate concern. You may choose to remain anonymous where
allowed by law.
Additional requirements and helpful tools
●
WR1408 Ethics Helpline
1.7 Non-Retaliation Policy
We will not tolerate any form of retaliation against any
person who has raised an ethical or legal
concern in good faith. Acting in good faith
means that you have made a sincere report in a
responsible manner through any of the
channels listed above. This applies even if your
report
does not turn out to be an actual violation.
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- Equinor, Annual Report on Form 20-F 2021
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1.8 Consequences of Breaches
We will not tolerate any breaches of the Code or the
law. Potential misconduct may be investigated by corporate audit
or other relevant
internal or external experts. We will pursue remedial
measures if you breach the Code or laws. The
same applies to leaders who disregard or
tolerate such breaches either through negligence or
actual knowledge. The remedial measures may
include termination of your employment
contract and reporting
to relevant authorities.
Incidents of ethical misconduct shall be registered
and reported in accordance with our governing
documents.
Additional requirements and helpful tools
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FR16 People and leadership
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WR2417 Ethics incident reporting
1.9 Ethics and Compliance in Equinor
We work in a systematic manner to ensure compliance with
the Code and applicable laws. Our ethics
and compliance function, headed by the
Chief Ethics and Compliance Officer, is responsible for supervising Equinor’s
ethics and compliance activities, including
providing guidance on
the Code and following up potential breaches. The Chief
Ethics and Compliance Officer will appoint one compliance
officer to assist in such
work for each business area and for selected
corporate staffs. The business areas and corporate staffs shall
appoint local compliance officers
where required.
The Corporate Executive Committee constitutes
Equinor’s ethics committee. In addition, ethics
committees have been established in the
business areas and most corporate staffs, comprising the respective
management teams. The committees will ensure a
strong focus on,
common understanding of, and compliance with
Equinor’s ethical requirements.
Additional requirements and helpful tools
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Equinor Book - App. D Committees
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WR2595 The compliance officer role
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Equinor, Annual Report on Form 20-F 2021
2 Respecting our people
2.1
Equality, Diversity and Inclusion
Every employee is an important member of the
Equinor team. We are committed to providing an inclusive environment
recognised for its
equality and diversity, and we will treat everyone with fairness, respect and
dignity. We do not tolerate any discrimination of colleagues or
others affected by our operations. Discrimination includes
all unequal treatment, exclusion or preference
based on race, gender, age,
disability, sexual orientation, religion, political views, national or ethnic origin
or any other characteristic that results in compromising
the
principle of equality.
What this means to you
●
Treat everyone with fairness, respect and dignity.
●
Base your work-related decisions on merit and not
on other characteristics that result in compromising
the principle of equality.
Additional requirements and helpful tools
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FR16 People and leadership
2.2 Harassment and Intimidation
Courtesy and respect are important aspects
of a sound working environment and business dealings.
We expect you to treat everyone you
meet through work or work-related activities in
a respectful manner. We will not tolerate any form of harassment or actions
that reasonably can
be considered as offensive or intimidating, including
any form of unwanted attention of a sexual
nature.
What this means to you
●
Take responsibility to create and maintain a good working environment.
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- Equinor, Annual Report on Form 20-F 2021
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Never engage in harassment, bullying, workplace
violence or other behaviour that colleagues or business
partners may regard as
threatening or degrading.
●
Offensive messages, derogatory remarks and inappropriate
jokes are never acceptable.
●
Respect other people’s customs or culture.
●
Speak up if you observe or experience harassment
or intimidating behaviour.
Additional requirements and helpful tools
●
GL0658 Handle harassment/bullying complaint
2.3 Safety and Security
Equinor’s safety and security vision is zero
harm. We are committed to providing a safe, healthy and
secure environment for all personnel at
our facilities and job sites, preventing accidents and
incidents from affecting people, environment and our
assets. To build a culture that is
Always Safe will require consistent use of I am
Safety expectations, Security Rules, Life Saving Rules
and a continued focus on learning and
improvement.
What this means to you
●
Safety and security is everyone’s responsibility. You must understand and act on your responsibilities to contribute
to a healthy, safe
and secure work environment.
●
Stop work immediately if you consider it unsafe.
●
Report any incident or unsafe condition as soon as
possible. If you see something, say something.
●
Know the relevant emergency procedures for your
work.
Additional requirements and helpful tools
●
FR10 Safety and security
2.4 Privacy and Data Protection
Privacy and data protection laws protect the
integrity and confidentiality of a person’s private information.
We are committed to protecting the
privacy rights of our employees and everyone
with whom we do business. We will only use personal
data for appropriate purposes, and
personal data will be processed in accordance with
applicable laws, internal requirements and
Equinor’s Binding Corporate Rules.
What this means to you
●
Respect everyone’s right to privacy. If your job includes handling personal data, ensure
that you are sufficiently familiar with and
comply with our internal requirements on processing
of personal data.
●
If you have permanent or regular access to personal
data, or if you are involved in the collection,
copying, storing, analysing or
disclosing of personal data, take appropriate
training.
Additional requirements and helpful tools
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WR1495 Processing of personal data
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Binding Corporate Rules
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GL0473 Guideline for Processing of Personal Data
2.5 Drugs and Alcohol
Equinor is a drug and alcohol-free workplace. We will
not tolerate anyone being under the influence
of drugs or alcohol while at work for
Equinor. Limited amounts of alcohol may, however, be consumed when local custom and occasion make it appropriate,
and provided the
consumption is not combined with operating machinery, driving or any other
incompatible activity. Tests for drugs and alcohol may be
conducted whenever deemed necessary and in accordance
with applicable laws.
What this means to you
●
Never work under the influence of drugs or alcohol.
●
Be conscious about work-related events where alcohol
is served and show moderation.
Additional requirements and helpful tools
●
FR16 People and leadership
2.6 Purchase of Sexual Services
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Equinor, Annual Report on Form 20-F 2021
Purchase of sexual services may be illegal, support
human trafficking and pose a security risk. Human
trafficking is a violation of human rights.
Regardless of local rules, regulations and customs,
Equinor prohibits the purchase of sexual services
when on assignments or business trips
for Equinor. This also includes any contribution to the purchase of
such services.
What this means to you
●
Never purchase sexual services when you are on
business trips or other assignments, including
long-term assignments.
●
Never influence others to purchase sexual services and
never accept to receive sexual services others
have paid for.
3 Conducting our operations
3.1 Anti-Corruption
Corruption undermines legitimate business activities, distorts
competition, ruins reputations and exposes companies
and individuals to
risk. We have zero tolerance for corruption in any form,
including bribery, facilitation payments and trading in influence. We will comply
with all applicable anti-corruption laws and regulations
and take active steps to ensure that
corruption does not occur in relation to
Equinor’s business activities.
Transparency is vital in the combat of corruption. We are committed to
conducting our business activities in an open
and transparent
manner, promoting transparency in our industry and supporting efforts to combat
corruption worldwide.
What this means to you
●
Never engage in, authorise or tolerate corruption
at any time for any reason.
●
Never offer or accept an improper advantage. An improper
advantage is an advantage that has no
legitimate business purpose and
is given to influence the recipient’s decision making.
●
Payment extorted from you under threat of life,
health, safety or illegal detention is allowed and
will not result in any form of
retaliation, but you must report the payment immediately.
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- Equinor, Annual Report on Form 20-F 2021
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●
Know your business partner, follow our integrity due diligence requirements
and never engage others to do something we
cannot
ethically or legally do ourselves.
●
Participate in required anti-corruption training and understand
the risks you face in your work.
Additional requirements and helpful tools
●
Anti-corruption compliance manual
●
Anti-Corruption Compliance Program
3.2 Conflict of Interest
Equinor respects your right to manage your personal
affairs and investments. However, a conflict of interest may occur when
your personal
interests and Equinor’s interests are
different and this may interfere with your ability to make
the right decision for Equinor. We expect you to
always act in the best interest of Equinor
when you are representing the company. You should avoid situations with actual, potential or
perceived conflict of interest.
What this means to you
●
Do not work in connection with any Equinor or
Equinor related transaction, procurement, contract award
or other matter in which you
have, or a related party has a financial interest.
A related party means your partner, close relative or any other
person with whom
you or they have close relations.
●
The same restriction applies where there are other
circumstances that undermine trust in your ability
to act in the best interest of
Equinor.
●
Be open, disclose and discuss with your leader
any actual, potential or perceived conflict
of interest. The leader will then decide
whether any measures should be taken, for instance
stepping back from the situation that caused
the conflict of interest.
3.3 Directorships and Ownership Interests
We expect you to spend your full working day on Equinor
matters. Before accepting external directorships or other
material assignments, you
must obtain prior written consent from your senior
vice president or, for any employees above this level, your leader. If you hold directorships
on behalf of Equinor, you are not entitled to board remuneration, but if
you hold directorships in a private capacity, you may retain any
remuneration paid. Elected employee representatives
on the board of Equinor ASA may receive
the remuneration decided by the corporate
assembly.
There are certain specific requirements for registering
directorships for the following group of employees:
(1) The CEO, executive vice
presidents and senior vice presidents; (2) employee representatives
on the board of Equinor ASA and (3)
employees exerting influence on
Equinor’s procurement or other contract awards.
These categories of employees must register
all directorships, except directorships in
Equinor subsidiaries or when representing Equinor
in non-controlled companies, in our personnel data
system. This information must be
updated on a continuous basis and verified once
a year.
Furthermore, employees in groups (1) and (2) cannot
hold ownership interests, or options to ownership
interests, directly or indirectly, in any
company that does or seeks to do business with
Equinor if the employee can exert influence on business
decisions related to such company.
The same applies to companies that are competitors
to Equinor. This prohibition does not apply to ownership interests
in securities funds or
shares in Equinor ASA.
What this means to you
●
Ensure you have the required approval before accepting
a directorship or material assignment for another
company.
●
Note the special requirements for registration of
directorships for certain employees.
●
Note the special prohibition of ownership interests
in other companies for certain employees.
Additional requirements and helpful tools
●
GL0548 Equinor Board of directors handbook
3.4 International Trade Restrictions
Countries can impose various economic sanctions restrictions
targeting business dealings with specific countries,
economic sectors, entities or
individuals of concern. Export controls on the export
or in-country transfer of certain restricted items,
technology and software are also
common. We will comply with all applicable economic
sanctions as well as export and import control
laws. We will assess whether government
authorisation is required before engaging in activities
involving restricted items, sanctioned parties or
countries and will obtain and comply with
all required authorisations.
What this means to you
●
Screen your business partners, suppliers and other
parties (including any ownership of the same)
against relevant restricted parties’
lists.
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Equinor, Annual Report on Form 20-F 2021
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Obtain and comply with necessary governmental licences
where cross-border export or import activity involves
restricted items,
technology or software.
●
Be mindful that both sanctions and export control regulations
are complex and subject to frequent changes.
Stay updated on the
rules applicable to your business activity.
●
Seek advice from the legal department if asked
to deal with
a sanctioned party, market or country.
Additional requirements and helpful tools
●
WR2988 Integrity due diligence
●
GL0358 Legal recommendations for compliance with
EU/Norway sanctions related to certain countries
●
Sanctions search tool on the integrity due diligence
portal
3.5 Anti-Money Laundering and Facilitation of Tax Evasion
Money laundering is illegal and supports other
criminal activities, including drug trafficking, terrorism,
corruption, human rights violations and
tax evasion. Money laundering is the processes
of disguising the proceeds of crime in order
to hide its illegal origins or otherwise dealing
with
the proceeds of crime. Criminal proceeds include
not only money, but all forms of assets, real estate and intangible
property that are derived
from criminal activity. We will comply with all applicable anti-money laundering
laws.
Tax evasion is an illegal practice where a person or entity evades paying their
actual tax liability. We do not tolerate the facilitation of tax
evasion by persons who act for or on behalf
of Equinor.
What this means to you
●
Be attentive to unusual payments, invoicing and banking
arrangement as well as unusual tax
status of suppliers.
●
Seek advice from the legal department if you need
a better understanding of money laundering or tax
evasion and how to mitigate
such risk to Equinor.
●
Know your business partners and make sure you
follow our integrity due diligence requirements.
3.6 Financial and Business Records and Reporting
Recording and reporting financial or non-financial information
completely, accurately and objectively is essential for Equinor’s credibility
and
reputation. It is also a prerequisite for meeting legal
and regulatory obligations and standards. We are
committed to transparency and
accuracy in all our dealings, and we will provide
full, fair, accurate and understandable disclosures in our financial
reports, documents filed
with regulatory authorities and in other public
communications.
What this means to you
●
The data and information you submit in our books
and records must be accurate, complete and
reliable. This includes both financial
and non- financial information, such as environmental
data and operations reports.
●
Any accounting information you provide must be correct
and registered in accordance with applicable
laws and relevant accounting
standards.
●
Never enter false, misleading or artificial entries in
our books and records. Any such intentional act
may be treated as fraud.
●
Always exercise the highest standard of care
when preparing business, operations and financial
records to ensure full, fair, accurate
and understandable information in all our reporting
and public communications.
●
If you suspect or become aware of any indications
of fraud, improper financial business records and
reporting or allegations of such,
you shall report it to your leader or the Ethics Helpline
immediately.
Additional requirements and helpful tools
●
FR14 Finance and control
●
WR1366 Accounting manual
3.7 Property and Assets
We trust you with Equinor’s assets so that you
can effectively do your work. You are responsible for safeguarding those assets
against loss,
theft and misuse. Equinor’s assets include
facilities, equipment, computers, software, information,
intangible property rights and financial
assets. We will not tolerate any misuse of our assets
for personal benefit.
What this means to you
●
Any use of Equinor’s assets for purposes not
directly related to our business, unless specifically
provided for in this Code, requires
permission from your leader.
●
Ensure that documents used to obtain company funds
and property are accurate and complete. This
includes time sheets, invoices,
benefit claims and travel and expense reimbursement
reports and underlying documentation. Inaccurate
or unsubstantiated records
may be treated as fraud.
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- Equinor, Annual Report on Form 20-F 2021
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●
As a leader you must ensure proper control before
you approve any time sheets, invoices, benefit claims
and travel and expense
reimbursement reports and underlying documentation
for people in your team.
3.8 IT Systems
The use of our IT systems must be based
on business needs. Information produced and
stored on our IT systems is Equinor’s property
and
may be accessed in accordance with applicable
law. Cyber-attacks and malicious activity are a continuous threat
to Equinor, and use of our IT
solutions and equipment may be monitored to
detect such risk. This includes blocking access
to inappropriate web sites and interception of
any information transmitted by or stored on our
IT systems.
What this means to you
●
Handle and archive documents according to Equinor’s
information management requirements and security
classification system.
●
Never use our IT systems to perform illegal
or unethical
activities, including downloading or sending offensive
material.
●
You must be vigilant of cyber-attacks and malicious activity such as phishing and immediately
report any incidents.
●
Limited personal use of our IT systems is permitted,
but such use should be kept to a minimum
and have no adverse effect on cost,
IT security or productivity. This includes the private use of social media.
●
Respect computer software copyrights and comply with
the terms and conditions of software licences.
Additional requirements and helpful tools
●
WR1211 Information security
3.9 Information Management and Confidentiality
During the course of business, we gain and produce
information that is vital to our financial and business
integrity. Such information may,
however, also be valuable for competitors and others. We will protect information
created by us, or given to us, to ensure
appropriate
confidentiality and integrity. It is important to share information across the organisation
to ensure collaboration, efficiency and experience
transfer, but information transfer and access must take place in accordance
with our security classification system for information
management.
What this means to you
●
Make sure you are familiar with and comply with
our information management and security classification
system when handling
company information.
●
Do not use Equinor’s information acquired through
your work for personal advantage or for the
purpose of competing with Equinor.
●
You have a duty of confidentiality, which applies even after your employment or assignment with Equinor has ended.
Additional requirements and helpful tools
●
WR0158 Information management
3.10 Inside Information
Equinor supports fair and open securities markets wherever
we operate. You may become aware of information about Equinor or other
companies that is not publicly available. Such information
may constitute inside information. Inside information
is precise information likely to
have a significant effect on the price of securities and
which is not publicly available or commonly
known to the market. If you are in
possession of inside information, even if acquired
incidentally, you have a legal duty of confidentiality and due care of
handling to prevent such
information from coming into the possession of unauthorised
persons. Any use of inside information about
Equinor or other publicly traded
companies for personal gain is prohibited.
Certain persons, such as members of the Board of
Directors and Corporate Executive Committee,
are considered primary insiders. Additional
restrictions apply for primary insiders.
What this means to you
●
Never buy or sell Equinor’s or other
companies’ shares or other securities, or provide
advice to others’ investment decisions, when
you have access to inside information.
●
Holders of inside information must treat this
confidentially and can only pass such information
to individuals who need it in their work
for Equinor based on authorisation from the
information owner.
●
Holders of inside information relevant for the Equinor
share price must be listed in Equinor’s insider
listing system.
●
The restriction on buying Equinor shares when you hold
inside information does not prevent you from participating
in our share
savings program.
Additional requirements and helpful tools
●
WR1921 Primary insiders
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Equinor, Annual Report on Form 20-F 2021
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WR2401 Inside information
4 Relating to our business partners
4.1 Suppliers and Business Partners
Business relationships based on trust and transparency
are vital to our business. Our suppliers and
business partners are essential to our
ability to do business but can also cause or contribute
to harm people and expose us to reputational,
operational and legal risk. We expect our
suppliers and business partners to comply with
applicable laws, respect internationally recognised
human rights and adhere to ethical
standards which are consistent with our ethical
requirements when working for or together
with us. We seek to work with others who share
our
commitment to ethics and compliance, and we manage
risk through in-depth knowledge of our
suppliers, business partners and markets.
What this means to you
●
Before you establish or amend any business relationship,
you must follow our procedures for integrity due
diligence and human
rights due diligence.
●
Communicate and follow-up regularly and clearly our
expectations to our suppliers and business partners.
●
Report any misconduct by a supplier or business
partner to your leader or any of the other
reporting channels listed in the Code.
Additional requirements and helpful tools
●
Equinor Book, Appendix G: Human rights policy
●
WR2988 Integrity due diligence
●
WR2452 Joint venture management related to anti-corruption
compliance
●
GL0349 Guidance on anti-corruption for non
Equinor operated joint ventures
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- Equinor, Annual Report on Form 20-F 2021
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●
Integrity due diligence portal
4.2 Intermediaries
Intermediaries are a particular type of business
partner and include agents, consultants, lobbyists and
others who act as a link between
Equinor and others. The use of intermediaries
may pose a particular risk to us, and we therefore
have additional requirements for hiring
intermediaries. It is mandatory to perform integrity due
diligence on all intermediaries. The agreed
compensation must be proportionate to the
service rendered and only paid against satisfactory
documentation of work performed, which must
be regularly monitored. The agreement with
the intermediary must be made in writing, describe
the true relationship with Equinor and include
an obligation to follow the Code.
What this means to you
●
Any intermediary you plan to hire must be subject
to integrity due diligence.
●
Monitor regularly the work performed by the intermediary
to ensure it is in line with the Code.
4.3 Fair Competition
We believe in the benefits of competition, and Equinor will
always compete in a fair and ethically justifiable
manner. We will comply with
applicable competition and antitrust laws. We will not engage
in or tolerate anyone who engages in anti-competitive
behaviour, such as price
fixing, bid rigging, market sharing or abuse of market
power.
We participate in legal collaborative projects with other
companies and share information required for
such projects. It may be a violation of
competition and antitrust rules to receive or
share with competitors non-public commercially sensitive
information beyond what is necessary for
a legal cooperation. Commercially sensitive information
includes information which may reduce uncertainty
about future market conduct, such
as prices, competitive bids, commercial strategies,
costs, customers and suppliers.
What this means to you
●
Do not enter into anti-competitive agreements or
engage in anti-competitive conduct, such as agreeing
with competitors to fix prices
or to allocate markets by territory, by products or by customers.
●
Be vigilant of situations where non-public commercially
sensitive information may be exchanged and speak
out against disclosure of
information by others to you. Never share
such information with competitors.
●
Competition laws are complex and often require
a detailed assessment of facts. If you are
in doubt, seek advice from the legal
department.
●
Participate in required competition and antitrust compliance
training.
Additional requirements and helpful tools
●
WR2447 Competition law compliance
●
WR1837 Inspections by authorities
●
Competition compliance manual
4.4 Gifts, Hospitality and Expenses
Relationships with our business partners can be
built and strengthened through legitimate
networking and social interaction. However, giving
or accepting gifts and hospitality may be regarded
as corruption in certain situations, and we have
strict limits for when we allow the giving or
acceptance of gifts and hospitality.
As a general rule, we do not offer or accept gifts,
except for promotional items of minimal value.
In a situation where it would clearly give
offence to refuse, the gift may be accepted if it is of reasonable
value and handed over to Equinor immediately. We only offer or accept
hospitality where there is a clear business reason
for Equinor to participate and the costs involved
are reasonable. We will always pay our own
costs related to travel, accommodation and other related
expenses. Except as otherwise stated in the
Code, we do not pay travel,
accommodation and other related expenses for others.
What this means to you
●
Never offer or accept gifts, except for promotional items
of minimal value.
●
Before accepting or offering hospitality, ensure that it is in line with our requirements.
Written approval from your leader is required
unless the hospitality clearly is acceptable.
●
Ask yourself how the acceptance or offer would be perceived
by others and never offer or accept anything
that is or could be
perceived as an improper advantage.
●
Ensure that all acceptance and offering of hospitality are
open, transparent and properly documented.
Additional requirements and helpful tools
●
GL0537 Offering and accepting gifts, hospitality and expenses
14
Equinor, Annual Report on Form 20-F 2021
●
WR1803 Management of social investment
5 Communities and Environment
5.1 Community Engagement
Stakeholder engagement is a central element of our
commitment to create lasting local value. We aim to
create such value to local
communities through our business activities. In
our dialogue and engagement with them we
seek to understand their expectations and explore
opportunities for mutual benefits. Solutions must be relevant
to our business needs and local conditions and
comply with our values, policies
and local regulations. Our contribution to communities
may include direct and indirect local employment,
local procurement of goods and
services, local infrastructure development and capacity
building as well as social investments.
Timely and meaningful engagement with members of local
communities is a central element of our commitment
to assess actual and potential
human rights impact from our activities and business
relationships, as appropriate. We will aim to apply
effective prevention and mitigation
actions where needed. Where we have caused or
contributed to adverse human rights impacts, we
will provide or cooperate in providing
appropriate remediation. This includes establishing effective
grievance mechanisms, where relevant.
What this means to you
●
Systematically consider and address the impact
our activities may have on local communities and
take this into account when
making business decisions, including in relation
to their use of land, water and other natural
resources.
●
When seeking to apply effective prevention and mitigation
actions, ensure they are addressing potential impacts
fairly and without
discriminating to any affected members of the local community.
●
Be particularly attentive to those most vulnerable to adverse
impacts, including women, children and indigenous
peoples.
●
Familiarise yourself with our human rights policy and
report any potential negative human rights
impact related to our operations or
in those of our business partners.
.
- Equinor, Annual Report on Form 20-F 2021
15
●
Actively identify opportunities related to our activities
that can contribute to local value creation through local employment,
procurement and capacity development.
●
Ensure that social contributions are made in compliance
with our anti-corruption requirements.
Additional requirements and helpful tools
●
Equinor Book, Appendix G: Human rights policy
●
FR11 Sustainability
●
WR1803 Management of social investment
●
WR2297 The rights of indigenous and tribal people
●
WR2614 Community grievance mechanisms
●
GL0626 Community engagement guidelines
5.2 Environment
We are committed to preventing harm to the environment.
We apply the principle of continuous improvement
when managing impacts and
risks to the environment. We aim for outstanding natural
resource efficiency and work actively to limit greenhouse
gas emissions from our
activities. We will comply with all applicable environmental
laws and regulations.
What this means to you
●
Assess and communicate the impacts our activities
have or may have on the environment.
●
Ensure that relevant measures are taken into account
when making business decisions, including the use of
environmentally friendly
technologies.
●
Contribute actively to efficient use of resources, carbon
efficient operations and prevention of harm to the natural
environment.
●
Assess and follow-up results and contribute to continued
improvement.
5.3 Public Communication
We believe that open, honest and accurate communication
is essential to our integrity and business
success. We will communicate about
Equinor in a consistent manner, and only authorised persons may
talk to the media, members of the investment
community or make
statements on Equinor’s behalf on social
media. Any private use of social media must not
breach confidentiality obligations and should not
compromise Equinor’s reputation or business
interests.
What this means to you
●
Do not speak on Equinor’s behalf unless authorised
to do so. Enquiries from the media shall be
directed to corporate
communication.
●
If you participate in social media, use good judgement
and show respect towards your colleagues,
business partners and
communities. Be vigilant that participating in social
media may represent a security risk.
Additional requirements and helpful tools
●
FR13 Communication
●
Social Media Guidelines
5.4 Public Affairs
We will make Equinor’s position known on important
industry matters through proactive engagement with
government policy makers and other
stakeholders, such as the media, civil society and
international institutions. However, we will not make gifts, donations
or otherwise support
political parties or individual politicians. We may nevertheless
be members of interest organisations relevant
for our industry that support
political parties or certain political issues. Any hiring
of lobbyists will be in accordance with
applicable law and subject to full disclosure to
any
external party they wish to influence that the lobbyist
represents Equinor.
What this means to you
●
Do not use company funds or resources to support any
political candidates or party. Never use your position in Equinor to
try to
influence any person to make political contributions.
●
Ensure that all contracts with lobbyists impose an obligation
to disclose to any external party they wish
to influence that the lobbyist
represents Equinor.
●
If you choose to participate in political activities or
give any public contributions, this must be personal
and not linked to Equinor.
16
Equinor, Annual Report on Form 20-F 2021
5.5 Public Officials
In our business operations or public affairs activities,
we often interact with public officials. Many
countries have rules regarding accepted
conduct when dealing with public officials, such as prohibiting
giving anything of value. We will never offer or authorise
anything of value or
payments to public officials unless specifically provided
for in the Code. We can, however, cover the reasonable and legitimate
travel,
accommodation and other related travel expenses
of public officials when they are related to the promotion
or demonstration of our products
or services or the execution of a contract with
a government.
What this means to you
●
Take particular care when interacting with public officials.
●
Never offer or agree to pay travel or accommodation
for any public official unless a hosting application
has been completed and
properly approved by the Chief Ethics and Compliance
Officer and the relevant EVP.
Additional requirements and helpful tools
●
Hosting form for public officials
www.equinor.com
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