Anti-Bribery & Corruption Policy
Integrity, which is a core part of Cheniere’s TRAINS values, calls for holding each of our employees, management and Board to the “highest standards of honesty and transparency.” The Chief Compliance & Ethics officer leads the ethics and compliance program to ensure our mission of delivering a “reliable, competitive, and integrated source of LNG in a safe and rewarding work environment” is realized.
Cheniere has established executive and Board-level oversight of the Anti-Bribery and Corruption Program. Cheniere’s Code of Business Conduct and Ethics and Anti-Corruption and Economic Sanctions Policy govern the Anti-Bribery and Corruption Program. The Chief Compliance & Ethics officer is responsible for developing these policies, which are reviewed by the Audit Committee of the Board, as well as approved by the Chief Executive Officer (CEO) and General Counsel. Further, the Chief Compliance & Ethics Officer provides monthly updates to the Global Risk Committee and quarterly updates to the Audit Committee of the Board and Cheniere’s Leadership Team, including the CEO, on the Anti-Bribery and Corruption Program.
Cheniere has a robust due diligence process for the Anti-Bribery and Corruption Program and closely monitors compliance. Each director, officer, and employee are required to certify annually to the Company that he or she acknowledges receipt of, understands and agrees to be bound by, and comply in full with, the Code of Business Conduct. All new employees must sign a statement of agreement to be bound by this Code.
Cheniere’s Anti-Bribery and Corruption Program is independently audited on an annual basis.
All employees are required to undergo anti-bribery and corruption compliance training at the start of their employment and, at a minimum, annually thereafter. Completion of all required training by the given deadline is included in the 2018 performance goals of all employees.
A director, officer or employee may not personally benefit from their relationship or employment with the Company except through compensation received directly from the Company. Directors, officers and employees are strictly forbidden from offering, promising, or giving money, gifts, loans, rewards, favors or anything of value to any governmental official, employee, agent or other intermediary (either inside or outside the United States) that is prohibited by law. Those paying a bribe may subject the Company and themselves to civil and criminal penalties. When dealing with government customers or officials, no improper payments will be tolerated. The Company prohibits improper payments in all of its activities, whether these activities are with governments or in the private sector.
Our Anti-Corruption and Economic Sanctions Policy establishes the necessary requirements to comply with applicable laws on anti-corruption, anti-bribery, and economic sanctions. It prohibits facilitation payments and establishes guidelines for ethical behavior.
If an employee observes a violation of our Code or policies, they have been trained to contact their supervisor, human resources representative, or the Compliance and Ethics team. Employees may also report concerns confidentially with the option to remain anonymous, via email or thorough our hotline. Once we receive a report, our compliance and ethics team assigns it to the appropriate person for investigation. Suppliers, customers, and other third parties can also use our hotline to report concerns. As part of our annual compliance and ethics training, we inform employees on methods to report ethics concerns.
Cheniere has a whistleblower protection program and hotline in place. The Company prohibits retaliation of any kind against individuals who have made good faith reports or complaints of violations of the Code of Business Conduct or other known or suspected illegal or unethical conduct. Any reprisal or retaliation against personnel (including employees, temporary or contingent workers, contractors, and consultants), because the individual, in good faith, sought help or filed a report will be subject to disciplinary action, including potential termination of employment.
The Company has a system for the anonymous reporting of violations of the Code of Business Conduct. This includes a United States Tip Line at 866-207-4751, a United Kingdom Tip Line at 0808-234-1127, and internet access at cheniere.ethicspoint.com. The hotline is managed by a third party
The full Code of Business Conduct and Ethics is available for download on our company website by clicking here.