.

- 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

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.

.

- 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

●

 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. 

4 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. 

.

- 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

●

 FR16 People and leadership 

●

 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

●

 Equinor Book - App. D Committees

●

 WR2595 The compliance officer role

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 

●

 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

●

 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. 

.

- Equinor, Annual Report on Form 20-F 2021 7

●

 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

●

 WR1495 Processing of personal data 

●

 Binding Corporate Rules 

●

 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

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 

●

 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.

.

- Equinor, Annual Report on Form 20-F 2021 9

●

 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. 

10 Equinor, Annual Report on Form 20-F 2021 

●

 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. 

.

- Equinor, Annual Report on Form 20-F 2021 11

●

 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

12 Equinor, Annual Report on Form 20-F 2021 

●

 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

.

- Equinor, Annual Report on Form 20-F 2021 13

●

 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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