ETHICS AND COMPLIANCE

CODE OF BUSINESS CONDUCT AND ETHICS AND REPORTING CONCERNS

ONEOK is committed to operating in an ethical manner and in full compliance with all applicable laws and regulations. Learn more about our ethics and compliance policies at oneok.com/about-us/ethics-compliance, including:

  • Code of Business Conduct and Ethics.
  • Non-retaliation Policy.
  • Whistleblower Policy.
  • Anti-corruption Policy.
  • Human Exploitation Policy.

The ONEOK Hotline provides for the submission of complaints or concerns regarding improper or unethical business behavior, questionable accounting or auditing matters or other matters arising under the ONEOK Code of Business Conduct and Ethics. The Non-retaliation Policy within the Code and the ONEOK Whistleblower Policy prohibit any form of retaliation against employees for raising a concern honestly and in good faith, or truthfully participating in a company investigation. Those using the hotline have the option to report anonymously. All reports, including those of retaliation, are investigated.

ANTI-CORRUPTION AND CORPORATE COMPLIANCE

The ONEOK Anti-corruption Policy reinforces our commitment to conducting business in an ethical manner and in full compliance with applicable U.S. and foreign laws. Effective training on the policy is one of the many ways that ONEOK manages corruption risks and potential fraud.

All ONEOK board members complete annual corporate compliance training that covers our Anti-corruption Policy, Code of Business Conduct and Ethics, Securities and Insider Trading Policy, Statement of Policy Regarding Conflict of Interest and Antitrust Guidelines.

Employees directly impacted by the Anti-corruption Policy must acknowledge the policy and complete in-person training every other year. This group is made up of those whose responsibilities may involve international business dealings, including those working in accounting, audit, legal, treasury, finance and commercial roles. During 2018, a total of 106 employees participated in the in-person anti-corruption training. ONEOK’s 2020 training is being conducted online due to precautions regarding COVID-19, with a total of 188 employees enrolled.

HUMAN EXPLOITATION

Human exploitation traps millions of people, including children, in horrific situations around the world, including here in the U.S. Individuals who engage in human exploitation use violence, threats, deception, debt bondage and other manipulative tactics for the purpose of exploiting people, sexually and otherwise, for profit. ONEOK is committed to conducting business in an environment free from human exploitation of any kind and has adopted the ONEOK Human Exploitation Policy to reinforce our commitment.

We expect our employees, suppliers and others with whom we do business, to respect the human rights of all people and engage in ethical labor practices that are free of child labor, forced labor and other forms of exploitation.

To strengthen employee understanding and awareness around human rights and exploitation and to help clarify ONEOK’s expectations for identification and reporting of potential instances, we released a training video to all employees in April 2020. In addition to the training video, policy reminders and information are posted to our website, employee intranet and at common work areas across our operations.

SUPPLIER EXPECTATIONS

Sustainable supply chain management is a priority for ONEOK, with the goal of continuous improvement and risk mitigation. We engage with suppliers annually to communicate expectations and highlight our commitment to sustainability, safety and ethical behaviors. ONEOK’s 2020 supplier expectations letter covered traditional topics (our Code of Business Conduct and Ethics, conflicts of interest and anti-harassment) and included new topics (environmental, safety and health, and human rights). In 2020, we also asked our Tier 1 suppliers to acknowledge receipt, review and understanding of our supplier expectations and received 100% acknowledgement. The Tier 1 category includes service and materials suppliers that make up the top two-thirds of annual expenditures and have been identified as suppliers that will continue to provide for ONEOK in the following calendar year.

Visit oneok.com/sustainability/supply-chain-management to read ONEOK’s supplier expectations letter and find more information about our supply chain management and purchasing practices.