Sustainability - EagleClaw Midstream

Governance

EagleClaw Midstream strongly values ethics, responsibility and integrity. EagleClaw Midstream’s Code of Conduct sets forth our policies with respect to business ethics and conflicts of interest; it is also intended to ensure that our employees, officers and directors conduct business with the highest standards of integrity and in compliance with all applicable laws and regulations.

Policy in Action

We have selected a third-party, EthicsPoint, to provide an anonymous and confidential method to facilitate the reporting of concerns, misconduct or noncompliance regarding our Code of Conduct.

To Make a Report

You can make a report in one of two ways. EthicsPoint provides a toll-free telephone number, which is staffed 24/7 by an operator to take your report over the telephone. Alternatively, you can submit a written report on-line through the link below. You may choose to remain completely anonymous under either method.

EagleClaw Midstream has a deep, robust and comprehensive governance model that sets clear direction to employees and other stakeholder on how the company operates.

Environment, Social and Governance Policy

  • We will build a deep understanding of our ESG goals among our employees, contractors, suppliers and partners so that we work together in their achievement;
  • We will continuously encourage the efficient use of natural resources in our business operations and promote the protection of the environment;
  • We will incorporate ESG considerations into material capital investment decisions;
  • We will provide safe and healthy working conditions for employees and contractors and ensure adequate training resources are available;
  • We will respect each employee in ways that show respectful, consistent and fair treatment regardless of race, gender, religion or ethnic origin;
  • We will review the impact of our operations on local communities so that activities that may potentially generate occupational health and safety, environmental or social impacts directly associated with our operations that are also based upon credible science are properly identified, monitored and addressed;
  • We will uphold high standards of honesty, transparency and business integrity by complying with local, state and federal laws and regulations while actively participating in the policy and legislative process to share our views and perspectives — using examples from our own operations — to further inform such deliberations;
  • We will implement an ESG performance management system to identify, manage and monitor ESG risks; prioritize them and resolve issues at an early and impactful stage;
  • We will leverage all reporting tools within the organization to ensure incidents are reported timely to allow for immediate evaluation of any impact to our ESG procedures;
  • We will ensure that considerations related to potential material ESG matters (e.g., reputational impact, operational impact, strategic impact, legal impact, financial impact) are considered and concluded so the company decides on matters holistically;
  • We will continually monitor developments around changing expectations involving governance matters and their relevance to our operations from the perspectives of our key stakeholders so that we proactively consider issues and methods to resolve early; and
  • We will err on the side of overcommunication about progress with implementing our ESG program, policy changes, accomplishments and other news to key stakeholders.

The Senior Director of Sustainability and Communications shall be responsible for ensuring daily oversight and enactment of these precepts, in alignment with overarching guidance from the EagleClaw Board.

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Biodiversity Statement:

We recognize the importance of biodiversity conservation and support biodiversity in Reeves County, TX our primary operating area. In this area, the protection of grassland habitat is necessary and important to support the diversity of wildlife and to preserve the little moisture the ground receives annually.

We plan our projects and operations in ways that reduce significant impacts they may have on sensitive species, habitats and ecosystems. This means that we:

  • Integrate biodiversity consideration into our project decision-making and management.
  • Consider the interrelationships between our operations and the natural environment and the functions that ecosystems perform in supporting sustainable development.
  • Recognize that our activities could affect sensitive and valuable biodiversity.
  • Meet or exceed applicable regulatory requirements and have processes in place to mitigate our impact to biodiversity.
  • Engage in planning to avoid or reduce potential risks of our operations to sensitive biological resources and seek ways to make positive contributions to biodiversity conservation in the area.

We also undertake activities to expand education in the importance of biodiversity and conservation and participate in industry associations to share and promote best practices for biodiversity conservation.

We are also committed to facilitating full and open discussions to understand stakeholder concerns and to identifying opportunities to reduce the impact of our operations on the environment.

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Whistleblower Policy:

The Board of EagleClaw Midstream has adopted this Whistleblower Policy to govern the receipt, retention and treatment of concerns regarding accounting practices, internal accounting controls and auditing matters of the Company, and violations of the Code of Business Conduct and Ethics of the Company, the Employee Handbook of the Company and any other policy of the Company in effect from time to time and to protect the confidential, anonymous reporting of Concerns by directors, officers and employees of the Company and other stakeholders of the Company.

It is the policy of the Company to treat Concerns seriously and expeditiously. Covered Persons may confidentially and anonymously submit Concerns for review by the Company, including:

Concerns regarding the Company’s compliance with accounting and auditing standards, including:

  1. Financial disclosure regarding the Company;
  2. Fraud or deliberate misstatement in the preparation, evaluation, review or audit of any financial statements of the Company;
  3. Fraud or deliberate misstatement in the recording and maintaining of financial records of the Company;
  4. Deficiencies in or non-compliance with the Company’s internal policies and controls;
  5. Misrepresentation or a false statement by or to a Covered Person respecting a matter contained in the financial records or audit reports of the Company; or
  6. Deviation from full and fair reporting of the Company’s financial condition.

Concerns regarding the violation of or non-compliance with the Code of Conduct or other policies of the Company in effect from time to time, including health and safety, environmental and anti-discrimination trading policies.

Chief Compliance Officer
The Company’s General Counsel has been appointed to serve as the Chief Compliance Officer of the Company and is responsible for overseeing the receipt, investigation, resolution, and retention of all Concerns submitted pursuant to this Policy.

Communication of the Policy
To ensure that all Covered Persons are aware of this Policy, a copy of this Policy will be available to all Covered Persons and posted on the Company’s intranet.

All Covered Persons will be informed whenever significant changes are made to this Policy. Any other stakeholders of the Company can refer to Company’s website for the most current version of the Policy.

Procedures Regarding Reporting
Covered Persons should report any violations of the Code of Conduct and other policies of the Company as set forth in the Code of Conduct. Additionally, any person may submit a Concern using any of the methods described below.

Regardless of manner which a Concern is submitted to the Company, a person submitting a Concern should include the following information to enable the Company to verify and investigate such Concern:

  1. Such person’s relationship to the Company;
  2. Any relevant information regarding the subject Concern and the circumstances giving rise to the Concern; and
  3. Name of the caller (unless the caller wishes to remain anonymous).

Concerns may be submitted to the Company using any of the following methods:

  • Telephone Hotline: Any person may submit a Concern by calling the Company’s Ethics & Compliance Hotline at 844-659-5688. The Hotline is operated by Navex, a third party service provided to the Company.

Information from the call will be documented by Navex and forwarded to the Chief Compliance Officer and Director of Human Resources/Benefits and will include, at minimum, a written description of the information received regarding the Concern.

Email or Website: Any person may submit a Concern by emailing tcarpenter@eagleclawmidstream.com or by using an internet-based message interface accessed via eagleclawmidstream.ethicspoint.com. Any emails or submissions via the website will be forwarded to the Chief Compliance Officer and Director of Human Resources/Benefits.

Written Concerns: Written communications may also be submitted confidentiality and anonymously, at the election of the submitting party, to the Chief Compliance Officer via email at tcarpenter@eagleclawmidstream.com or in writing to the following mailing address:

BCP Raptor Holdco, LP
2700 Post Oak Blvd., Suite 300
Houston, TX 77056
Attn: Chief Compliance Officer

If requested by a Covered Person, the Company will protect the confidential and anonymous submission of a Concern to the fullest extent practical, consistent with the need to conduct an adequate review of the Concern and any related matters. Vendors, customers, business partners and other stakeholders external to the Company may also confidentially and/or anonymously submit Concerns as described above.

No Retaliation or Adverse Consequences
The Company will abide by all applicable laws and, if applicable, stock exchange rules that prohibit retaliation against Covered Persons who lawfully submit Concerns under these procedures. No Covered Person who in good faith (a) reports a Concern under this Policy, or (b) provides assistance to the Chief Compliance Officer, the Director of Human Resources, or any other person investigating such Concern shall suffer harassment, retaliation or adverse employment consequence as a result of such report or assistance.

All other stakeholders of the Company who act in good faith in submitting a Concern shall also suffer no consequences for bringing about legitimate matters to the Chief Compliance Officer or the Director of Human Resources for consideration. An employee of the Company who retaliates against someone who has reported a concern or a violation in good faith is subject to discipline up to and including termination of employment.

Acting in Good Faith
This Policy is intended to encourage and enable Covered Persons and other stakeholders of the Company to raise serious and substantive Concerns within the Company rather than seeking resolution outside the Company. Anyone submitting a Concern must act in good faith and have reasonable grounds for submitting such Concern.

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Safe Driving Policy:

This policy shall apply to all company employees and contractors who operate company owned, leased, or rented vehicles as well as employees who drive personal vehicles on company business. This policy also applies to the use of a company or personal cell phone to conduct company business, while driving a company vehicle, rented vehicle, or personal vehicle for business purposes.

Drivers

  • Shall maintain and have in possession a valid and appropriate driver’s license.
  • Shall be physically fit and mentally alert. Drivers who are under the influence of alcohol or drugs are not to operate a vehicle. If prescription medication that affects driving ability is being taken drivers shall not drive.
  • Shall check their vehicles, prior to operation, for proper operating condition and are not to drive if there is reason to believe the vehicle is not safe to drive.
  • Shall comply with all applicable regulations in which their vehicles are to be operated.
  • Shall drive defensively, safely, courteously, and responsibly at all times and in all locations including, but not limited to public roadways, lease roads, plants or booster stations, and pipeline rights-of-way.
  • Shall wear their seat belts during operation.
  • Shall report all traffic citations issued while driving a Company owned, leased, or rented vehicle to their supervisor within 24 hours. Drivers are responsible to pay for all traffic citations.
  • Shall report all vehicle accidents to their supervisor immediately
  • Shall not transport family members or non-business-related personnel in a Company vehicle unless specifically approved by their supervisor.
  • Shall not use Company owned/leased vehicle for personal use. If there is an urgent need, the specific request must be approved by their supervisor.
  • Shall complete a monthly vehicle inspection.
  • Shall avoid backing when a reasonable parking alternative is available.

Supervisors

  • Shall ensure that employees or contractors who drive Company owned, leased, or rented vehicles understand the requirements the Company places on drivers.
  • Shall ensure employee’s and contractors’ driving behavior follows the Safe Driving Policy.
  • Shall coordinate incident investigations for vehicle accidents or ensure incident investigations are conducted.
  • Shall periodically review employees GPS data for proper driving habits
  • If under the Company’s substance policies an employee is to be tested for drugs and alcohol after a vehicle accident, the employee’s supervisor shall ensure they are tested as soon as possible, but no later than 24 hours after a preventable vehicle accident.

Accidents

  • All vehicle accidents are to be reported to your supervisor immediately or as soon as possible.
  • The respective supervisor or manager is responsible for coordinating the investigation of all vehicle accidents under his/her jurisdiction.
  • The vehicle accident investigation team shall document and file all evidence examined during the course of the investigation. The accident investigation team shall consist of the employee’s supervisor and HSE coordinator and they shall determine “Preventability”.

Vehicle Parking
Whenever backing a vehicle, it is the responsibility of the driver and/or passenger to ensure that the vehicle can be backed safely. Backing a vehicle into an area that is likely to contain a collision hazard(s) will require the driver and/or passenger to  exit the vehicle to perform an assessment and/or to serve as a guide. Backing a vehicle must be performed with extreme caution and should be avoided if at all possible.

Distracted Driving

Pre-driving Preparation

  • Plan your trip to allow extra time to arrive at your destination
  • Check your vehicle to make sure it is safe to operate
  • Secure loose items to prevent them from rolling around during movement
  • Make appropriate adjustments to mirrors, seats, windows, etc.
  • Eliminate any distractions before you start your trip

While Driving

  • Do not use electronic devices, except for a cellular phone in hands free mode
  • Do not look for loose items in the vehicle
  •  Do not read books, newspapers, take notes, etc.

Cell Phones & Electronic Devices

  • The use of electronic devices (except with the use of “Bluetooth” or “Hands Free” devices) to place or respond to calls, pages, text messages, e-mails, etc. by drivers in moving vehicles is prohibited unless the vehicle is properly parked in a rest area, designated parking area, or other safe location. Note: The side or shoulder of the road may not be considered a safe location in all instances.
  • Navigation systems such as “X-Map”, and portable GPS direction systems (i.e. Garmin, TomTom, etc.) must be programmed while safely stopped and may be operational during travel.

General Safety Rules

  • Operation of a Company owned, leased, or rented vehicle while under the influence of intoxicating beverages or drugs is prohibited.
  • The possession, transportation, or sale of illegal drugs, alcoholic beverages, or firearms while in Company vehicles is prohibited.
  • Seat belts must be worn by the driver and all passengers in Company owned, leased, or rented vehicles while the vehicle is in motion.
  • The use of radar detectors while operating a Company owned, leased, or rented vehicle is prohibited.
  • All vehicle engines shall be shut off while refueling the vehicle.
  • Drivers are responsible for knowing the payload and towing capacities of the vehicle per the owner’s manual and ensuring that it is not overloaded.

Recommended Safety Equipment for Company Vehicles
All Company trucks that are used in field operations and maintenance of oil and gas gathering systems and gas processing facilities shall be equipped with the following: A dry chemical fire extinguisher, mounted according to the manufacturer’s recommendations and in a location that would not obstruct the driver’s view, but allow ready access.

  • A first aid kit, with a bloodborne pathogen kit.
  • A Water Jel brand mini-wrap blankets for treatment of burns is highly recommended.

Drug and Alcohol Testing
If under the Company’s substance policies an employee is to be tested for drugs and alcohol after a preventable motor vehicle accident, they are to be tested as soon as possible, but no later than 24-hours after the accident. Both a quick cup rapid result drug test and alcohol testing are required for any PMVA and for any vehicle accident that cannot be immediately ruled as an NPMVA, except PMVA’s classified as insignificant.

Vehicle Accident Tracking
All Preventable and non-Preventable Vehicle Accidents will be tracked by Corporate HSE using the following descriptors:

  • Insignificant Accident – Any vehicle accident that does not result in any employee or 3rd party injury. Total cumulative damage to the vehicle and other property does not exceed $1,000.
  • Minor Accident – Any vehicle accident that does not result in any employee or 3rd party injury beyond first aid.
  • Significant Accident – Any vehicle accident that requires hospitalization of any employee or 3rd party, or results in an employee or 3rd party fatality, or total loss of any vehicle.

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Environmental Management Policy:

As we continue to grow our business, we coordinate closely with regulatory representatives, permitting experts and landowners where appropriate prior to the construction or expansion of a project. EagleClaw accounts for the overall impact of a project with particular attention paid to (1) end-to-end environmental impact assessments (2) sensitive habitats and conservation areas for threatened or endangered species (3) areas with high biodiversity value (4) restoration strategies and (5) project-specific spill prevention and response procedures.

Our Operations and Construction Management teams work with our design contractors to ensure that our facility and pipeline assets are built to minimize distressing environmental impacts not only during construction, but also throughout operations and maintenance. They oversee the regulatory and permitting requirements tied to pipelines, compressor stations, and facilities. Should an incident occur during construction, our tracking system database is used to collect, analyze, and assign actions around immediate remediation efforts and communications.

Management of Environmentally Sensitive Areas
In the event environmentally sensitive areas, such as sensitive habitats, conservation areas for threatened or endangered species, or areas with high biodiversity value are in the vicinity of a construction project, we would employ additional mitigation measures during construction to protect those areas. If an existing asset is determined to be in an environmentally sensitive area, we subject the asset to additional integrity inspection.

Restoration of Rights of Way
Following construction of a new project, or maintenance construction on existing assets, we restore the disturbed area in accordance with regulatory requirements and in coordination with the landowner, if applicable.  We grade rights of way to pre-construction elevations, condition soils for planting, stabilize creek banks, drainage ways and steep slopes to provide erosion control and re-vegetate with a seed mix appropriate for the area considering regional conservation requirements and landowner wishes.

Pipeline Inspections
EagleClaw pipeline systems must be monitored regularly to ensure they operate safely and efficiently. Several factors are considered in setting inspection schedules including potential for internal and external corrosion, weather, soil erosion and construction by others in the vicinity of our pipelines.

The pipelines are regularly patrolled by operations personnel on the ground and periodically reviewed by air, as well as monitored through Gas Control data monitoring systems. EagleClaw tracks and reports on the percentage of operated pipeline assets that are inspected annually.

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Air Quality & Emissions Policy:

The purpose of this policy is to detail the company’s air quality and greenhouse gas emissions management policies and practices. We are committed to meeting or exceeding applicable federal, state and local regulations and engage in voluntary actions that improve operational efficiency and reduction of greenhouse gas emissions, including methane.

Responsibilities
At EagleClaw Midstream, we are dedicated to operating safely, responsibly and sustainably.  We actively manage the impact of our operations on the environment with a dedication to excellence and attention to details, particularly as it applies to our emissions management policies and practices. We are committed to meeting or exceeding applicable federal, state and local regulations and engage in voluntary actions that improve operational efficiency and reduce greenhouse gas emissions, including methane.

Emissions Management
EagleClaw manages its operational emissions by monitoring for and repairing leaks, tracking and investigating incidents to determine the root cause(s) and corrective actions, and quantifying facility annual emissions in permit applications with documented basis.

In 2020, we implemented a policy to require voluntary monitoring of all our processing facilities with an optical gas imaging (OGI) camera. EagleClaw performs leak detection surveys through an independent third party to maintain thorough, unbiased inspections. We have, at times, found minor leaks following new construction. For this reason, we monitor new construction closely in our inspections. EagleClaw owns the OGI camera and maintains qualified operators who perform periodic inspections in our facilities, as well as pipelines when needed.

We utilize a computer-based maintenance management system to track key emissions controls and permit requirements to ensure timely maintenance and task completion, as well as to track and confirm actions taken on reports of fugitive emissions. This allows EagleClaw to quickly react to any potential equipment malfunctions or issues. Our online management of change (MOC) system is used to track engine moves for permitting.

Where possible, we have implemented lower emitting equipment[1], including electrically driven pumps, and over the next several years plan to determine how to further implement these assets to minimize our emission footprint. EagleClaw has made it a priority to only utilize low-bleed or electrically driven controllers for new construction, and we swap out any high-bleed pneumatic controllers when we acquire assets. We engage each of our operators in ongoing training programs that prioritize AVO (audio, visual and olfactory) detection and quick response to track, react, and stop any leaks. Training is mandatory and tracked in our training system to manage attendance and training records.

Emissions Reporting
At EagleClaw, all discovered unauthorized emissions are recorded and reported, if a reportable quantity is met, per applicable federal, state and local laws. These emissions are quantified with a documented basis and tracked in our emissions event database, along with spills, to facilitate the analysis of data and reporting of environmental KPIs to operations and management.

Actual annual emissions for applicable facilities are reported per federal and state laws, including criteria pollutants, along with our required annual U.S. Environmental Protection Agency (US EPA) Greenhouse Gas Reporting Program (GHGRP) reports to the EPA.

GHG
Greenhouse gas emissions generally result from the combustion of natural gas while operating compressor engines and process heaters, methane and carbon dioxide that is released during various routine operational procedures and flaring and venting. We prepare an annual greenhouse gas inventory report that follows the GHGRP. The inventory includes our natural gas gathering and processing and crude operations, in accordance with the requirements of federal standards. As part of EagleClaw’s efforts to reduce our emissions footprint, we are members of both Our Nation’s Energy Future (ONE Future) and The Environmental Partnership.

ONE Future
In 2020, EagleClaw joined Our Nation’s Energy Future (ONE Future), a coalition of over thirty (30) companies in the natural gas industry committed to achieving meaningful methane emissions reductions. The coalition members are working together to voluntarily reduce methane emissions across the natural gas value chain to 1% (or less) by 2025. Through our participation in ONE Future, EagleClaw is committed to achieving the methane intensity targets set by ONE Future for the natural gas gathering and processing segments in which we operate, by 2025.

[1] *When making CAPEX equipment expenditures, the company weighs a series of material considerations. EagleClaw Midstream considers technical and financial feasibility; magnitude of potential air emission reduction; potential customer impacts; eligibility under regulatory permitting; and other factors.

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Supplier Code of Conduct:

The purpose of this policy is to detail our expectations for our suppliers, contractors, service providers and vendors to adhere to EagleClaw Midstream’s fundamental values, policies and procedures and apply these components to how they do business.

EagleClaw Midstream is committed to operating in an economically, environmentally and socially responsible manner, and we extend this commitment to suppliers, contractors, service providers and vendors working on our behalf.

Our Code details our expectations for our Suppliers regarding the safety of people, protection of property, and respectful and responsible stewardship of the environment.

EagleClaw Midstream believes the health and safety of our employees, Suppliers and the communities where we live and operate is fundamental to how we do business.

As a company, we aim to achieve zero incidents and to build a culture in which safety is everyone’s responsibility.

We expect our Suppliers to have a systematic approach to safety designed to adhere to all applicable local, state and federal regulations and deliver continuous performance improvement. While working at any of our facilities, our Suppliers are required to report any safety issues to EagleClaw Midstream immediately.

It is our expectation that our Suppliers maintain and comply with the same environmental health and safety (EHS) protocols and standards as our full-time employees. As such, when applicable, we expect Suppliers to strictly comply with and be subject to the EagleClaw Midstream Environmental, Health and Safety manual.

EagleClaw Midstream is committed to environmental stewardship and minimizing the impact of our operations on the environment.  EagleClaw Midstream expects that its suppliers will minimize impact on biodiversity, climate change and water scarcity.

Work Environment:
EagleClaw Midstream is committed to the protection of human rights for all employees, Suppliers and community members. Human rights belong to each individual and we expect all Suppliers to treat individuals with respect and tolerance.

We expect Suppliers to support an environment that values diversity and provides equal employment to their workforce with no distinction or preference made on the basis of gender, race, religion or social origin.

Our dedication and commitment to human rights unquestionably applies to the communities in which we operate. Our engagement and interaction reflect on our company and our brand—each Supplier associated with EagleClaw should act in accordance with our values, respecting and protecting people to foster a safe and engaged working environment.

Suppliers must conduct all their operations in a non-discriminatory manner and in full compliance with all applicable laws, including, but not limited to, laws and regulations relating minimum wage requirements, working conditions, child labor, human trafficking, and collective bargaining.

Conflict of interest:
EagleClaw Midstream expressly prohibits Suppliers from engaging in activities in which the Company may conclude constitutes a conflict of interest.

A conflict of interest occurs when personal interests interfere with a party’s ability to exercise its judgment objectively, or to perform the party’s job in a way that is certain to be in the best interests of EagleClaw Midstream.

Suppliers, their employees or their families cannot receive improper benefits through the relationship with EagleClaw Midstream or allow other activities to conflict with acting in the best interests of EagleClaw Midstream.

A conflict may arise with Suppliers that employ or are partially or fully controlled by an EagleClaw Midstream employee or family member.

Any and all conflicts of interest in any business dealing with EagleClaw Midstream, of which the Supplier is aware, must be declared to EagleClaw Midstream to provide EagleClaw the opportunity to take appropriate action prior to entering into any business transaction.

Brand and Trademarks: 
We expect Suppliers to conduct themselves at all times in ways that reinforce and strengthen the EagleClaw Midstream brand.

Use of EagleClaw Midstream’s brand is not permitted without express written permission of the Corporate Communications Department of EagleClaw Midstream.

Under no circumstances are third parties allowed to display the EagleClaw Midstream brand or of any of its affiliated businesses.

Competitive Protocol:
EagleClaw Midstream requires all suppliers to engage in the highest ethical standards during the Supplier selection process.

Suppliers must refrain from discussing or disclosing its pricing, costs and any other contract terms with their competitors specifically during a competitive bidding process.

Supplier Diversity:
EagleClaw Midstream recognizes that a strong, diverse supplier community is essential to economic vitality and we seek opportunities to conduct business with competitive, diverse suppliers.

We expect our business partners to utilize and develop diverse suppliers of their own while performing work on our behalf.

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Stakeholder Engagement Policy:

The purpose of this policy is to define an approach to stakeholder engagement across the EagleClaw Midstream enterprise; identify priority stakeholders (government officials, authorities, local community leaders, current and future employees, landowners, Non-Governmental Organizations, current and future contractors, academic and scientific organizations) and ensure alignment on the need for regular, consistent and comprehensive engagement across the company’s stakeholder network.

Government Relations (State and Federal)
Advocating for the long-term business continuity of our midstream operations requires constant engagement, communication and compliance with multiple government agencies and their regulations. To identify and manage regulations, particularly any new environmental and social initiatives stemming from ESG regulatory risks and opportunities, we have a team among EagleClaw and our JV partners that identify and verify compliance with these requirements.

We provide recommendations for policies and regulation that support safe and efficient operations, with the ability to grow our businesses. We track key policy issues, including topics such as ‘critical infrastructure’, ‘pipeline safety’, ‘climate change’ and ‘personnel health and safety’.

We partner with industry groups such as One Future, The Environmental Partnership, GPA Midstream, and American Petroleum Institute (API) to engage in discussions with both a lens towards our own operations as well as that of the broader industry.  We contribute the EagleClaw Midstream perspective to industry responses concerning regulatory proposals and policy development.

We do not have a corporate sponsored Political Action Committee (PAC), and we do not contribute to political parties nor political candidates.

Ethics and Integrity
In accordance with our Code of Conduct and Anti-Bribery & Anti-Corruption Policy, at EagleClaw our Board, officers, and employees are committed to conducting business ethically and in compliance with applicable laws and regulations. On an annual basis, all employees are required to complete our Code of Conduct training in which the foundational principles for honest, ethical behavior and decision making are communicated. Consistent training ensures alignment and compliance with our standards and are key to the company’s long-term success and the wellbeing of our employees.

Our company has several programs in place to ensure the continuity of ethical business conduct. We have robust anti-bribery and anti-corruption policies that reiterate the company’s zero-tolerance commitment towards corruption, complying with laws and regulations including the U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act.  Our Whistleblower Policy allows for employees and contractors to report ethics violations anonymously without the fear of retribution or adverse consequences.  To preserve anonymity, we developed and closely monitor our Ethics Hotline to facilitate the reporting and management of any issues.

Human Rights
EagleClaw is committed to the protection of human rights for all employees, contractors, suppliers and community members. This is in alignment with our Code of Conduct and our company’s core values of integrity, accountability, safety and excellence.  Human rights belong to each individual and we expect all members of the EagleClaw organization to treat individuals with respect and tolerance. We support an environment that values diversity and provides equal employment to all of our workforce with no distinction or preference made on the basis of gender, race, religion or social origin.

Our dedication and commitment to human rights unquestionably applies to the communities in which we operate. Our engagement and interaction reflect on our company and our brand—each person associated with EagleClaw should act in accordance with our values, respecting and protecting people to foster a safe and engaged working environment.

Employee Attraction and Retention
At EagleClaw we believe our employees are the key to building and maintaining a diverse, inclusive, collaborative and dynamic culture. To attract, develop and retain the best talent, we seek to provide employees continued learning and career development opportunities. EagleClaw Midstream offers programs that address both our technical workforce, as well as our non-technical workforce. To attract high caliber employees and meet the needs of our diverse workforce, we offer a robust benefits package for all employees.

We put our employees first. For example, during COVID-19, it was our priority to keep each and every employee a part of the EagleClaw Midstream team. Our leadership understands a company cannot be resilient and agile if employees do not feel safe and prioritized. This is the culture of EagleClaw Midstream, and it is the foundation for the best employee morale, performance and quality of work.

Local Economic Development and Community Giving
At EagleClaw Midstream we are proud to be an engaged, active partner in the communities in which we live and operate. Social investment and community giving are key pillars of our goal to be a good corporate citizen. Whether it be corporate led events, charitable donations or individual volunteer work, EagleClaw is committed to creating shared value by building strong relationships with our local communities and organizations.

Our pillars of community engagement social investment include: (1) Local Community Economic Development, (2) Health and Safety, (3) Emergency Responders, and (4) Environmental Sustainability.

The Fight Against COVID-19
During the tumultuous, uncertain time of COVID-19, we felt it was crucial to support the front-line workers actively fighting for the safety and health of our employees, communities, family and friends. EagleClaw Midstream made donations to hospitals in Midland and Odessa and the emergency response organization in Reeves county to provide much needed personal protective equipment (PPE) for nurses, doctors and paramedics, as well as fuel to transport critically ill coronavirus patients by ambulance.

Employee Volunteer and Matching Gifts
During the COVID-19 pandemic, we supported efforts to help our communities manage the food shortages that affected several cities and municipalities in our state. Our employee giving effort experienced tremendous participation, surpassing our financial goal and achieving more than $30,000 in donations for the West Texas Food Bank.

Be the Change
We support events such as “Be the Change” in which our employees support under privileged youth in the Permian Basin.

Breast Cancer Awareness
Each year, we host a lunch to raise funds and awareness for breast cancer.

Salvation Army Angel Tree
During the holidays EagleClaw participates in the Salvation Army Angel Tree, providing gifts for dozens of children to nurture little extra holiday cheer.

Landowner and Community Relations
EagleClaw Midstream’s engagements with landowners, community leaders and stakeholders are built on trust, active communications and collaboration. We uphold integrity, honesty and accountability in all operations by providing accurate and timely responses to questions, comments and concerns. While building and operating infrastructure, we are dedicated to the safety and environmental stewardship of our communities. We are continually working to not only comply with laws and regulations, but to also actively engage landowners and community members on industry issues.

We connect to our communities through a variety of methods, including community awareness programs and emergency hotlines. It is our goal to ensure the community has a comfortable knowledge of the regulations for midstream operators, as well as education regarding our emergency preparedness and public safety priorities. This fosters meaningful, productive relationships and promotes a continued, dynamic learning process for EagleClaw to be an engaged and accountable partner.

Management of Contractor Workforce
It is EagleClaw Midstream’s expectation that our contractors maintain and comply with the same environmental health and safety (EHS) protocols and standards as our full-time employees. Our contractor services agreements require contractors to strictly comply with and be subject to the EagleClaw Midstream Environmental, Health and Safety manual.  Contractors are monitored and dismissed should compliance with our EHS expectations be violated.

As contractors play a key role in the management of our operations and assets, we use ISNETWorld® — an industry-recognized platform for monitoring safety metrics and performance — to qualify contractors before they obtain authorization to begin work. ISNETWorld® provides essential information regarding a contractor’s performance in the following key areas: Safety management systems, injury and illness statistics, Department of Transportation (DOT) inspection compliance, DOT motor carrier safety rating, written safety programs and safety training, experience modification rating and fatality history.

If a contractor does not meet our expectations, our employees collaborate with ISNetworld® to work with them to seek improvement. If they do not improve, EagleClaw Midstream terminates the contractor or places the contract on hold — and, in turn, our operations team recommends a safer service provider.

Existing contractors who fail to meet the rules and standards are no longer allowed to work on an EagleClaw Midstream work site. The goal of this program is to ensure our contractors maintain dedicated engagement and respect for our environmental, health and safety standards and for our emergency preparedness objectives.

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