IPIECA: GOV-1, GOV-2, / GRI: 102-15, 102-16

SWN has a strong reputation for ethical behavior and fair dealing; a reputation we have earned by conducting our business and building shareholder value with integrity and character according to the highest ethical standards and values.

SWN’s General Counsel, our Chief Compliance Officer, oversees issues relating to ethics and nonoperational compliance. The Chief Financial Officer oversees Internal Audit Services, which is responsible for reviewing internal compliance with our ethics standards. To ensure that our employees and Board members conduct their work in an ethical manner and meet applicable laws and regulations, we have established detailed Business Conduct Guidelines and hold related employee training. New employees are required to certify that they have read and understand the guidelines.  The guidelines and related employee training cover topics such as conflicts of interest, human rights, sexual harassment, cybersecurity, bribery and corruption, antitrust matters, political matters and insider trading. The interactive, web-based training courses are provided at least annually to test employees and contingent workers on their knowledge of our ethics requirements and provides additional content on any questions that are missed to ensure employees are proficient on key topics. In 2020, 100% of all employees and full-time contingent workers completed the required training courses.

In addition, a SWN ethics hotline enables employees to anonymously submit issues or concerns.  All complaints received are forwarded to both Internal Audit and an investigation lead in the relevant department. The Audit Committee receives a summary of all complaints. Our Internal Audit group also assesses compliance with ethics requirements across departments on a regular basis. In 2020, we received 21 complaints through this hotline. All of which were assessed and resolved.

Our Supplier Code of Conduct requires that all suppliers meet our ethics standards. We review supplier performance against these standards before adding new suppliers, and we audit active suppliers’ ethical performance regularly (see the Contractor Assessment and Selection section for more detail).

IPIECA: GOV-5

Public Advocacy

Southwestern Energy’s senior executives, along with our Regulatory team and Government Affairs team, manage the Company’s engagement in the legislative and regulatory process. In several cases, we have worked proactively with policymakers and other stakeholders to craft recommendations for laws and regulations that will be effective and workable in practice. For example, SWN has voluntarily participated in a number of scientific studies with regulatory agencies, academia and nongovernmental organizations that have informed science-based regulations. Also, SWN is a founding member of the ONE Future coalition, which developed the methane reduction approach that has been endorsed by the U.S. Environmental Protection Agency and is now a component of its Natural Gas STAR Methane Challenge.

Cybersecurity

We recognize that cybersecurity is a critical risk for our Company and the stability of our nation’s energy system. Rapidly evolving cyber techniques and increased threats against energy and “critical infrastructure” have raised the level of risk across the industry in recent years. Greater use of technology and digitization in operations has opened the industry to new vulnerabilities in corporate systems, as well as operational technology (e.g. SCADA). The energy industry remains subject to evolving threats and actors including criminals, terrorists, nation states, and insiders.

Cybersecurity is recognized as a top enterprise risk and given oversight by SWN Management and the Audit Committee of the Board of Directors. Several SWN directors have experience with technology or cybersecurity. During 2020, our Audit Committee conducted a detailed review of the Company’s risk management program and specific identified risks, including cybersecurity. The Audit Committee receives quarterly cybersecurity reports and conducts at least two in depth cybersecurity discussions annually. 

Protection of SWN’s informational assets is managed by a comprehensive, multi-layer strategy modeled after the National Institute of Standards and Technology (NIST) cybersecurity framework and combines technology, services, policies, and user education to mitigate cyber risks. Acceptable Use, Information Security, and Vendor Risk policies and procedures are key to our cyber defense. They protect our employees and contractors while ensuring we partner with responsible vendors who also invest in effective cybersecurity practices. SWN conducts regular, proactive cybersecurity vulnerability assessments to identify opportunities for improvement and reduce exposure to cyberattacks. We participate in industry organizations and engage service providers to monitor the latest cyberthreats. Our employees are key to protecting our assets and participate in cybersecurity awareness campaigns, social engineering tests, and Cybersecurity Awareness month every October. A cybersecurity module was added to our required annual ethics training and is also a topic included under our Health and Safety training program. Select employees participate in annual cybersecurity tabletop exercises to ensure key stakeholders are familiar with our cyber defenses and response plans.