Business Ethics

To sustain and promote our ethical culture, we maintain a robust compliance program rooted in our Code of Business Conduct and Ethics. We provide quarterly compliance training to our board and to all newly hired employees, and company-wide compliance training to all employees biannually. At the beginning of every year, we reinforce our Code of Business Conduct and Ethics and our company policies to all employees and require them to read and acknowledge their compliance with them, along with a disclosure of any actual or potential conflicts of interest. To encourage a speak-up culture, we have a robust Whistleblower Policy and maintain an ethics hotline run by a third party to provide our employees and independent contractors multiple ways to report concerns, including through anonymous channels. Further, we utilize both an internal audit department and external auditors to regularly document and review our internal controls. Our compliance program helps to ensure we remain vigilant and reasonably capable of detecting and reducing the potential for criminal, fraudulent, or other improper conduct.

Finally, as a domestic oil and gas company, we do not face the potential for corruption that exists in many oil-producing regions of the world. We have zero reserves in Transparency International’s 2019 Corruption Perception Index, as all our reserves are all located within the United States (ranked in the top 15% for 2019).