An ethical business culture is critical to our success. At EnLink, our Core Value of “Uncompromising Integrity” underscores our belief in accountability, honesty, and transparency and forms the foundation of our companywide commitment to operating with integrity.
Code of Business Conduct and Ethics
We require that all of our employees, as well as the directors on our Board, follow our Code of Business Conduct and Ethics (Code). The Code requires ethical behavior from all of our employees and Board directors, as well as compliance with all applicable laws and regulations. This commitment from our employees and Board directors is crucial to maintaining a workplace focused on ethical and fair business dealings. Our Code, linked here, can be found on our website. We have also adopted other policies underlying our ethical business values, including an Anti-Corruption Policy.
We require our employees to complete annual training to certify their understanding of key corporate compliance policies including the Code, as well as Anti-Harassment/Discrimination, Corporate Authority and Delegation of Authority, Business Expense and Procurement Card Policy, and Employee Handbook, among others. In 2023, 100% of our employees completed their required annual training.
Robust Reporting Structure
We have a robust reporting structure for any concerns related to business conduct and ethics. This includes an internal reporting structure, as well as a third-party-hosted, anonymous reporting hotline, our "Ethics Line." Internal reporting includes reporting to the employee’s supervisor or functional leader or our Human Resources department.
The Ethics Line, which is available 24/7/365 by calling 833-960-1602 or visiting www.lighthouse-services.com/enlink and is explained in our Code, is available for anonymous reporting of any violations or suspected violations of our Code or any other unethical conduct. Monitored by Lighthouse, an independent, third-party service, the Ethics Line is available to our employees as well as to suppliers, customers, and other third parties. We prominently post information regarding the Ethics Line on our website, our intranet site, and in our Code, so that employees and others are aware of how to contact this resource.
When a call or online report is made to our Ethics Line, Lighthouse creates a report based on information provided over the phone or submitted in the online report. EnLink has a defined, limited list of appropriate personnel who will receive the report from Lighthouse, including representatives from our executive leadership, legal, and internal audit teams. Any reports received are also sent directly to the chair of the Audit Committee of our Board. Upon receiving a report from Lighthouse, our legal team will engage in establishing an investigation protocol appropriate for the specific report, which, depending on the issue, is typically conducted by internal audit, legal, or human resources. We investigate every report that is made to the Ethics Line and treat those reports as confidential. The reporter may choose to remain anonymous throughout the entire process. Lighthouse acts as an intermediary for EnLink to send further requests for information to the reporter, which allows the reporter to remain anonymous. Upon completion of the investigation, the investigator will summarize the results and share with appropriate leadership for further action, if any.
We have a policy prohibiting retaliation against anyone who makes a report in good faith, whether internally to a manager or other leader or to the Ethics Line. In 2023, the Ethics Line received one call, which related to a human resources matter. We investigated and responded to this report; no further action was necessary.
Corporate Policies
We have several key policies that help support our ethics and compliance programs, including but not limited to:
- Code of Business Conduct and Ethics
- Anti-Corruption Policy
- Employee Handbook
- Flexible Work Policy
- Leave of Absence Policy
- Parental Paid Leave Policy
- Regulatory Compliance Policy
- Trading Policy
- Supplier Code of Conduct
- Clawback Policy
- Stock Ownership Guidelines
Industry Regulations and Trade Organizations
The energy industry – and in particular oil and gas – is one of the most heavily regulated industries in the United States, subject to rules and oversight set forth by local, state, and federal governmental bodies. EnLink invests significant time and resources to comply with these important regulations, while delivering oil and gas products that power our daily lives in a safe and responsible manner.
EnLink participates in organizations committed to developing industry standards including:
- The Environmental Partnership
- Carbon Neutral Coalition
- Energy Infrastructure Council
- GPA Midstream Association
- Texas Pipeline Association
- Louisiana Mid-Continent Oil and Gas Association
- Petroleum Alliance of Oklahoma
More in the "Corporate Governance" section:
- Corporate Governance Overview
- Board of Directors
- Executive Compensation and Incentives
- Risk Management and Cybersecurity
Other sections:
The information and data (collectively, “Information”) provided in EnLink’s 2023 Sustainability Report (“Report”) reflects content as of and for the period ending December 31, 2023, unless otherwise indicated. Such Information in this Report is for informational purposes only. EnLink does not make, and hereby expressly disclaims, any representation or warranty as to the accuracy or completeness of the Information contained herein. This Report is being published on August 6, 2024, and EnLink undertakes no obligation or duty to (1) update or correct the Information, (2) provide additional details regarding the Information, or (3) continue to provide the Information, in any form, in the future. EnLink reserves the right, in its sole discretion, to modify, update, change, delete, or supplement the Information from time to time without notice. The Information should not be interpreted as any form of guaranty or assurance of future results or trends. EnLink is expressly not incorporating by reference any of the Information into any filing of EnLink made with the United States Securities and Exchange Commission or in any other filing, report, application, or statement made by EnLink to any federal, state, or local governmental authority. This Report contains information based upon EnLink’s role in the broader economy, environment, and society and is presented for the purpose of responding to issues that are important to a wide range of interested parties. While events, scenarios, and efforts discussed in this report may be significant, any significance should not be read as necessarily rising to the level of materiality pertaining to disclosures required under U.S. federal securities laws, which have distinct and specific concepts of materiality.