Advocacy and memberships
At Cenovus, we recognize that it’s important for our stakeholders to understand how we interact with the public policy process. We aim to have our interactions with external groups, such as industry associations or organizations we sponsor, be consistent with our public policy positions and we’re committed to adhering to high ethical standards when communicating with government officials.
We have memberships in numerous industry and business groups and also support a number of organizations through the sponsorship of events or initiatives with varying levels of involvement. These memberships and sponsorships provide us with exposure to new ideas and expertise which can help inform our understanding of issues that are important to Cenovus and its stakeholders. These memberships also help support networking and allow us to provide our perspectives on key issues.
Many of our memberships and sponsorships provide services not considered advocacy, such as data gathering for analysis and publication or the hosting of instructional workshops on topics not related to policy. However, some of our memberships and sponsorships do have aspects that are related to public policy or advocacy. In some cases, such as our membership in the Canadian Association of Petroleum Producers (CAPP), federal and provincial governments will specifically seek industry input through these organizations as part of government-led policy consultation processes.
As of March 1, 2017, our Board of Directors amended Cenovus’s Code of Business Conduct & Ethics to prohibit political contributions by the company.
Governance around memberships and sponsorships
At Cenovus we are committed to maintaining, promoting and enforcing the highest standards of integrity and corporate governance practices in all aspects of our business. Memberships and sponsorships, including those where indirect political advocacy could occur, are managed by teams reporting to the Executive Vice-President, Stakeholder Engagement, Safety, Legal & General Counsel.
Opportunities for membership and sponsorships are reviewed within relevant teams to ensure they align with established criteria. The level of management involvement in the decision-making process for memberships and sponsorships, through either internal consultation or final approval, depends on either the financial cost or potential for reputational impact. In some cases, a sponsorship may include review and approval by members of our Leadership Team. We consider sponsorship opportunities that directly support a Cenovus business objective. Our eligibility requirements specify that sponsorships cannot support political events. While not all initiatives we sponsor have a policy element, some sponsorships may support some type of advocacy such as communicating a policy position broadly or facilitating cross-sector dialogue in which government officials may participate.
Cenovus shall not participate in improper intervention in political processes and, as of March 1, 2017, nor shall it make financial contributions or contributions in kind to political parties, committees or their representatives. Illicit or improper payments to public officials are strictly prohibited. Our employees, contractors and directors may choose to become involved in political activities as long as they undertake these activities on their own behalf and may, on a personal level, give to any political party or candidate. Reimbursement by the company is prohibited.
Cenovus will comply with all applicable lobbying legislation including the Lobbying Act (Canada) and the lobbying acts in Alberta, British Columbia and Saskatchewan which impose reporting requirements on lobbying communications with certain officers and employees of the above federal and provincial governments, also known as “public office holders.” We have rigorous internal policies and procedures for lobbying and comply with all laws requiring companies to record their lobbying activities with federal and provincial registries.
Our employees, contractors and directors are also required to avoid where possible, and otherwise declare to the company and take steps to manage, situations where personal interests could conflict, or appear to conflict, with duties and responsibilities or the interests of Cenovus. This would include any situation involving a public official or individuals employed by any membership or sponsorship organizations we are associated with. Conflict of Interest Declaration forms must be completed and filed on a timely basis and include mitigation approved by a supervisor and Vice-President.
Cenovus directors, employees and contractors are strongly encouraged to report business conduct concerns or violations of the code.