Leadership Commitment
Our commitment to ethical business practices begins at the highest level of the organization. Our Board of Directors and Board Audit Committee actively oversee policies and procedures governing ethics and compliance, and are kept up-to-date on emerging ethics issues and the status of the company’s various ethics and compliance programs. Our Ethics and Compliance Committee, consisting of the company’s senior leadership, provides additional guidance and direction. We also have a dedicated Ethics and Compliance Office charged with the day-to-day accountability for ethics program design, training, consulting, and investigations. The Ethics and Compliance Office is led by the director, Ethics & Compliance, who briefs the Board Audit Committee.
We also ask every member of Team El Paso to be a leader in applying the highest ethical standards to their individual areas of our business. As such, we ask each employee to certify annually that they have read and understood El Paso’s Code of Conduct, which details the standards of ethical conduct and compliance with the law expected of directors, employees, contractors, and other individuals who work on the company’s behalf. Additionally, we ask all employees to read our Conflicts of Interest Policy and disclose any potential conflicts on a yearly or as-needed basis. Further, employees must complete ethics and compliance training tailored for their job duties to qualify for annual incentive compensation.
Ethics Resources
We believe in equipping our employees with the tools and resources they need to make the right decisions in their areas of our business and engage with ethics on an individual basis. Available resources include:
- Our Code of Conduct is provided to every employee and many of our vendors and business partners. In 2010, we refreshed our Code of Conduct to address new risks and issues that companies are facing, such as appropriate use of social networking and next-generation communication tools. The new Code of Conduct is centered on a theme of trust throughout the organization and is aligned with El Paso’s vision to be the Place to Work, the Neighbor to Have, and the Company to Own. It outlines a principles-based system that shapes how we conduct ourselves and our business, including our expectations for complying with both the spirit and the letter of all applicable laws, El Paso’s values, and ethical principles.
- Our Ethics and Compliance Office actively communicates throughout the year with employees, highlighting key ethics themes and practices through ethics features on El Paso Today, our company intranet site. These pieces focus on the importance of ethics and values, frequently feature senior executives, and remind employees of our ethics and compliance policies.
- Since 2009, the Ethics and Compliance Office has published an annual Capabilities & Commitments report to provide employees with a transparent view into ethics and compliance programs at El Paso. The report highlights resources available to employees for bringing forward concerns, an explanation of ethics case activity, a recap of training activities and communications, and forward-looking goals for the Ethics and Compliance Office.
- We provide training courses on ethics and compliance matters throughout the year. All employees received between two and eight hours of ethics and compliance training depending on the compliance risks specific to their job function. These courses are available in the native language of each country in which we operate. There is also specialized training in key areas affecting our employees.
- All leaders have access to an online Ethical Leader Toolkit that helps integrate the company’s integrity program into the leader’s daily activities. The toolkit provides guidelines and resources to help leaders enhance employee interactions, while driving productivity, reinforcing corporate standards and values, and integrating compliance and ethics into daily operations.
- To help us more thoroughly evaluate the effectiveness of El Paso’s ethics and compliance programs, the Ethics and Compliance Office conducts a companywide survey every three years. We ask all employees to complete the survey and provide feedback to help us improve our Ethics & Compliance programs. The most recent survey was completed during the spring of 2011, with nearly 85 percent of employees participating.
- In addition, employees have a number of tools and resources available for asking questions, voicing complaints, or raising issues. Options include contacting the Ethics and Compliance Office directly; calling a 24-hour, toll-free helpline on an anonymous basis; or submitting an anonymous Web form, if they prefer.
When ethical issues arise, we have a process for addressing them that is applied consistently and fairly across the organization. That process begins with a full review of the facts for each reported incident. In 2010, we opened 180 cases to investigate various allegations, complaints, and inquiries. These matters varied widely, including such areas as business integrity, misappropriation of company assets, conflicts of interest, diversity, workplace harassment, and work environment issues. We take these investigations seriously and follow through with appropriate and immediate action, when warranted. Depending on the severity of the issue, actions taken during 2010 ranged from reprimand to termination.1
Houston Makeover
During 2010, significant progress was made on the Houston Makeover, our major initiative to renovate our downtown Houston headquarters. As of May 2011, we have completed the renovation and re-occupancy of 27 floors and the podium level of the building, which encompasses the tunnel level and the first and second floors. The final three floors are on target for completion in fall 2011. As part of the Houston Makeover, we are seeking Silver Certification of the building through the LEED Green Building Rating System in the category of commercial interiors.
To help us reach our goal of LEED certification, we resold or donated all wall panels, glass and lighting fixtures, and furnishings; installed new carpet created from recycled materials and selected to ensure minimal, if any, emissions; and prepped the furniture and wall systems prior to installation, preventing introduction of emissions that would compromise indoor air quality.
To lower electricity consumption, the new design takes advantage of natural lighting, lighting controls, and variable speed drives in air conditioners and chillers. For 2010, in the LEED recycle category, we have achieved 84 percent recycling of construction waste, including carpet, concrete, wood, and office furniture.
