Suncor’s commitment to integrity and ethics is the foundation for our Standards of Business Conduct Code and the other company policy guidance and standards that reinforce it. The Code requires strict compliance with legal requirements and sets Suncor’s standards for the ethical conduct of our business, allowing Suncor to maintain the confidence of our customers, colleagues, shareholders, vendors, and the communities and governments where we do business globally.
Standards of Business Conduct Code
Suncor’s Business Conduct Policy Statement articulates Suncor’s commitment to sound legal and ethical business practices. Suncor meets this commitment through its Standards of Business Conduct Code (the “Code”), with further guidance through detailed policy guidance and standards (“PG&S”), and a Code compliance program.
Under the program, every Suncor director, officer, non-union employee and contract worker is required annually to complete training on the Code and certify that he or she has reviewed the Code, understands the requirements of the Code, and has complied with the Code during the preceding 12-month period. Contractors or consultants who act as Suncor’s agents, or are working on the company’s behalf or in its name through outsourcing of services, processes or any business activity, are required to act consistently with the Code when acting on behalf of Suncor.
Topics addressed in the Code, and detailed further in various PG&S, include:
- competition
- conflict of interest and confidentiality
- trading in shares and securities
- improper payments
- fair dealing in trade relations
- harassment-free and violence-free workplace
- accounting reporting and business control
- protection and proper use of corporate assets, and
- gifts and entertainment.
Suncor’s Board of Directors exercises stewardship over the Code in several respects. Suncor’s internal auditors audit the compliance program annually, and the director of internal audit, who has a direct reporting relationship with the Audit Committee, reports on compliance to that Committee. At least once annually, the Code is reviewed and if appropriate, updated. The code has been updated, since the merger and an online training and testing process has been implemented. In the first quarter of 2010 each Suncor director, officer, non-union employee and contract worker of the new Suncor was required to complete this online training. Management reports to the Governance Committee annually on this process, and any recommended changes are approved by the Governance Committee. Any waivers of Code requirements for Suncor’s executive officers or members of the Board must be approved by the Board or appropriate board committee, and disclosed. No such waivers were granted in 2010.
Suncor encourages employees to raise ethical concerns with management, and legal, corporate security, human resources or internal audit departments, without fear of reprisals. In addition, the company has established an “Integrity Hotline” to provide a means for Suncor’s employees and third parties to report issues of concern anonymously to a third party service provider. The Integrity Hotline is available 24 hours a day, seven days a week. All issues of a serious nature are investigated by internal auditors or corporate security. The Audit Committee receives regular updates on activities relating to the Integrity Hotline.
Download the Code (PDF, 24 pp., 463 KB)
Download the PG&S on the Prevention of Improper Payments (PDF, 10 pp., 97 KB)
Download our PG&S on Competition and Trade Relations (PDF, 2 pp., 27 KB)
Prevention of Improper Payments
Corruption is an obstacle to sustainable economic activity; it hinders the development of fair market structures and distorts competition. More importantly, participation in corrupt business practices undermines citizens’ trust in the political and business system, in its institutions and in its leadership. As a good corporate citizen, Suncor strives to act transparently and in the best interests of the communities where we operate.
Suncor’s position on bribery and corruption is clear, and is set out in detail in the PG&S on Prevention of Improper Payments. Suncor’s funds and facilities are not to be used for any illegal or improper purposes. Bribery, kickbacks or any payment to a person to commit an unlawful act, or to influence a person performing public duties, are prohibited, as is the diversion of assets for personal benefit. Suncor’s personnel shall comply with all applicable laws of jurisdictions where Suncor does business concerning improper payments to foreign officials or other third parties. Supervisors and managers are expected to promote a working environment consistent with this policy guidance and standard, and assist all Suncor personnel within their supervision to understand and comply with this PG&S.
Suncor’s Board of Directors reviews compliance with this PG&S as part of its annual review of Suncor’s Standards of Business Conduct Compliance Program. The Company’s Chief Compliance Officer oversees this PG&S and reports directly to Suncor’s Chief Executive Officer and Board of Directors.
Download the PG&S on the Prevention of Improper Payments (PDF, 10 pp., 97 KB)
Privacy
Suncor collects, uses, and stores personal information about its employees, contractors, customers, suppliers, associates and others in the course of its business activities. This collection, use, and disclosure of personal information is subject to provincial, federal and international laws. We respect the privacy rights of all individuals, and have adopted policies, procedures and practices to protect those rights. Privacy training, including an online course designed specifically for the company, is available for employees, focused on those who are most involved in the handling of employee, customer or others’ personal information.
Competitive Practices
Suncor does not engage in anti-competitive activities. We compete for business vigorously, honestly and in compliance with all applicable antitrust and competition laws. These laws are designed to encourage fair competition in the marketplace for products and services.
Those negotiating or administering agreements, participating in industry associations or similar groups, and those involved in advertising and promotion, are required to be familiar with local laws regarding competition and trade practices. Suncor tries to identify, select and do business with suppliers who enhance our competitiveness and who have a consistent vision of sustainability and business ethics.
Download our PG&S on Competition and Trade Relations (PDF, 2 pp., 27 KB)
Open, honest and transparent relationships support sound corporate governance and high ethical standards. Within the bounds of commercial confidentiality, we commit to transparent relationships with employees, shareholders and stakeholders alike. We encourage transparent transactions and operating agreements with provisions that respect the local laws, wherever we operate around the world.
Many of our investments and projects are long term in nature and we expect to be a corporate citizen in the communities where they are located for many years. We have a clear interest in the social and economic development of the regions and countries where we work. We prefer to invest and work in countries that are tackling corruption, promote good governance and the rule of law, and that are concerned about the health, education and well-being of all of their people.
As such, we support public accountability by governments and the transparency of revenues as a means to promoting political and economic stability in the regions in which we operate. We acknowledge the work that the Extractive Industries Transparency Initiative does in this regard and, while we have not formally endorsed the initiative, if requested, we will support host countries seeking to implement greater transparency.