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Our commitment to integrity and ethics is the foundation for our Standards of Business Conduct Code and the company policy guidance and standards that reinforce it.
The code requires strict compliance with legal requirements and sets standards for the ethical conduct of our business, allowing us to maintain the confidence of our customers, colleagues, shareholders, vendors and the governments and communities where we do business globally.
Standards of business conduct code
Our business conduct policy statement articulates our commitment to sound legal and ethical business practices. We meet this commitment through our Standards of Business Conduct Code, which is comprised of a number of detailed policy guidance and standards (PG&S) and a code compliance program.
Under the code, every Suncor director, officer, employee and contract worker is required annually to review the code and certify that he or she:
- has reviewed a summary of the code
- understands the requirements of the code
- has complied with the code, alternatively has disclosed and resolved any non-compliance with the code
Consultants working on our behalf or in our name through outsourcing of services, processes or business activity, are required to abide by the code when representing Suncor.
Topics addressed in the code, and detailed further in various PG&S, include:
- conflict of interest and confidentiality
- trading in shares and securities
- improper payments
- fair dealing in trade relations
- accounting, reporting and business control
- protection and proper use of corporate assets and opportunities
Stewarding to business conduct code
- Our Board of Directors exercises stewardship over the code
- Internal auditors audit the compliance program annually
- The vice president of enterprise risk and 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. 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 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 2015.
Raising ethical concerns
We encourage employees to raise ethical concerns without fear of reprisal with these teams/departments:
- Corporate Security
- Human Resources
- Internal Audit
In addition, we have established an integrity hotline to provide a means for our employees and contractors to report issues of concern anonymously to a third-party service provider.
The integrity hotline is available 24 hours a day, 7 days a week. All serious issues are investigated by Internal Audit or the chief compliance officer. The audit committee receives regular updates on integrity hotline activities.
Download The Way We Do Business Guide (PDF, 24 pp., 1 MB)
Prevention of improper payments
Corruption constrains sustainable economic activity. It hinders the development of fair market structures and distorts competition. More important, corrupt business practices undermines citizens’ trust in political and business systems, institutions and leadership. We strive to act transparently and in the best interests of the communities where we operate.
Our position on bribery and corruption is clear and detailed in the PG&S on the Prevention of Improper Payments. Funds and facilities aren’t 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. Personnel are required to comply with all applicable laws concerning improper payments to foreign officials or other third parties.
Supervisors and managers are expected to promote a working environment consistent with this PG&S and assist all personnel within their supervision to understand and comply with it.
Our Board of Directors reviews compliance with this PG&S as part of its annual review of the Standards of Business Conduct Compliance Program. Our chief compliance officer oversees this PG&S and provides periodic reports to the general counsel and Board of Directors.
Download our PG&S on the Prevention of Improper Payments (PDF, 10 pp., 180 KB)
We collect, use and store personal information about employees, contractors, customers, suppliers, associates and others in the course of business activities. The collection, use and disclosure of personal information is subject to provincial, federal and international laws. We respect privacy rights of all individuals and have policies, procedures and practices to protect those rights.
We strive not to engage in anti-competitive activities. We compete for business vigorously, honestly and in material compliance with all applicable antitrust and competition laws. These laws encourage fair competition in the marketplace for products and services.
Those negotiating or administering agreements, involved in advertising and promotion, or participating in industry associations or similar groups, are required to be familiar with local laws regarding competition and trade practices. We try to identify, select and do business with suppliers who enhance our competitiveness and who have a consistent vision of sustainability and business ethics.
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 of 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 communities where we’re located for many years. We have a clear interest in social and economic development in regions and countries where we work.
As such, we support public accountability by governments and transparency of revenues, as a means to promote political and economic stability in regions where we operate. We acknowledge work that the Extractive Industries Transparency Initiative does in this regard and, while we haven’t formally endorsed the initiative, we consider supporting host countries seeking to implement greater transparency if requested.
Conflict of interest
Our governance committee annually reviews a declaration of interest from each board member to determine if any conflicts of interest exist. In addition, directors are required to maintain with the corporate secretary a current list of all other entities in which they have a material interest or on which they serve as a director, trustee, or in a similar capacity.
As per the Board’s conflict of interest policy, if a director is a party to, or has an interest in any party to, a contract or transaction before the Board of Directors (regardless of the materiality of the contract or transaction), the director must immediately advise the board chair or the particular committee chair. The director’s conflict or potential conflict is recorded in the meeting minutes and the director is required to exit from the meeting for any material discussions or deliberations concerning the subject matter of the contract or transaction. The director is required to abstain from voting on any resolution in respect of such contract or transaction. The corporate secretary also ensures that directors don’t receive board materials in situations where the subject matter of the materials could involve an actual or potential conflict of interest.