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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.
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
2 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 3
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
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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.
4 Equinor, Annual Report on Form 20-F 2021
What this means to you
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When in doubt, disclose the issue to your leader and discuss it openly.
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thought through properly and you are pressured into taking a rash decision.
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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
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Be a role model for ethical leadership through promotion of compliance and ethics. Show by behaviour what it means to act with
integrity.
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Communicate the requirements in the Code and provide advice with respect to its interpretation and application.
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Create an environment where people feel comfortable speaking up and asking questions without risk of retaliation.
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Be consistent when enforcing our standards and holding people accountable for their behaviour at work.
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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
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contact your leader’s superior.
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officer or the ethics and compliance function.
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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
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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 5
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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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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6 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
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Additional requirements and helpful tools
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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
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- Equinor, Annual Report on Form 20-F 2021 7
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threatening or degrading.
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Additional requirements and helpful tools
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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
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and secure work environment.
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Additional requirements and helpful tools
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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
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comply with our internal requirements on processing of personal data.
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disclosing of personal data, take appropriate training.
Additional requirements and helpful tools
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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
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Additional requirements and helpful tools
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2.6 Purchase of Sexual Services
8 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
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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
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is given to influence the recipient’s decision making.
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retaliation, but you must report the payment immediately.
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- Equinor, Annual Report on Form 20-F 2021 9
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ethically or legally do ourselves.
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Additional requirements and helpful tools
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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
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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.
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Equinor.
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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
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Additional requirements and helpful tools
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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
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lists.
10 Equinor, Annual Report on Form 20-F 2021
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technology or software.
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rules applicable to your business activity.
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Additional requirements and helpful tools
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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
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such risk to Equinor.
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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
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and non- financial information, such as environmental data and operations reports.
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standards.
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and understandable information in all our reporting and public communications.
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you shall report it to your leader or the Ethics Helpline immediately.
Additional requirements and helpful tools
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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
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permission from your leader.
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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 11
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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
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IT security or productivity. This includes the private use of social media.
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Additional requirements and helpful tools
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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
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company information.
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Additional requirements and helpful tools
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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
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you have access to inside information.
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for Equinor based on authorisation from the information owner.
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savings program.
Additional requirements and helpful tools
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12 Equinor, Annual Report on Form 20-F 2021
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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
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rights due diligence.
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Additional requirements and helpful tools
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- Equinor, Annual Report on Form 20-F 2021 13
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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
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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
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or to allocate markets by territory, by products or by customers.
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information by others to you. Never share such information with competitors.
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department.
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Additional requirements and helpful tools
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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
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unless the hospitality clearly is acceptable.
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perceived as an improper advantage.
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Additional requirements and helpful tools
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14 Equinor, Annual Report on Form 20-F 2021
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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
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making business decisions, including in relation to their use of land, water and other natural resources.
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discriminating to any affected members of the local community.
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in those of our business partners.
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- Equinor, Annual Report on Form 20-F 2021 15
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procurement and capacity development.
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Additional requirements and helpful tools
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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
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technologies.
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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
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communication.
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communities. Be vigilant that participating in social media may represent a security risk.
Additional requirements and helpful tools
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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
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influence any person to make political contributions.
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represents Equinor.
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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
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properly approved by the Chief Ethics and Compliance Officer and the relevant EVP.
Additional requirements and helpful tools
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www.equinor.com
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