Advocacy and memberships
Cenovus recognizes that it’s important for stakeholders to understand how companies 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 are committed to adhering to high ethical standards when communicating with government officials.
Cenovus has memberships in numerous industry and business groups and also supports a number of organizations through the sponsorship of events or initiatives with varying levels of involvement. These membership and sponsorship opportunities provide Cenovus with exposure to new ideas and expertise which can help inform our understanding of the key issues that exist for Cenovus and its stakeholders. These memberships 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.
In addition, in 2016 and in previous years, Cenovus has provided financial contributions to political parties, in compliance with all federal and provincial regulations, the total value of which has been reported in our annual corporate responsibility report. As of March 1, 2017, our Board amended Cenovus’s Code of Business Conduct & Ethics to prohibit political contributions by the company.
Governance around memberships and sponsorships
Cenovus is committed to maintaining, promoting and enforcing the highest standards of integrity and corporate governance practices in all aspects of our business. Memberships and sponsorships where indirect political advocacy could occur are managed by teams reporting to the Executive Vice-President, Environment, Corporate Affairs, 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 a Leadership team member.
Sponsorships are considered ‘commercial initiatives’ that directly support a Cenovus business objective or promote our commercial interests. All sponsorships are subject to eligibility criteria established under our Community Investment program which specifies that sponsorships cannot support political events. While not all initiatives we sponsor have a policy element, some sponsorships we provide may support some type of advocacy such as communicating a policy position broadly or facilitating cross-sector dialogue in which government officials may participate.
The Code of Business Conduct & Ethics and Corporate Responsibility Policy approved by our Board of Directors reflect Cenovus’s commitment to conducting our business ethically, legally and safely. The code includes a number of aspects that help govern activities involving memberships, sponsorships and/or political donations:
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.
Conflicts of interest
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.
Reporting violations of the code
Cenovus directors, employees and contractors are strongly encouraged to report business conduct concerns or violations of the code.
As part of our commitment to transparency, we have provided a list below of organizations and trade associations that are known to undertake advocacy activities such as meeting or corresponding with government officials in order to influence policy decisions. These are organizations in which Cenovus had a membership in 2016 that cost more than $1,000. The advocacy positions taken by these groups may or may not reflect Cenovus’s perspective.
- Alberta Chamber of Resources
- Alberta Chamber of Commerce
- Bonnyville & District Chamber of Commerce
- Brooks & District Chamber of Commerce
- Canadian Council For Aboriginal Business
- Catalyst Canada Inc.
- Cold Lake Regional Chamber of Commerce
- Drumheller & District Chamber of Commerce
- EXCEL Partnership
- Greater Vancouver Board of Trade
- Independent Power Producers Society of Alberta
- Lac La Biche & District Chamber of Commerce
- Medicine Hat & District Chamber of Commerce
- Saskatchewan Chamber of Commerce
- Business Council of British Columbia
- C.D. Howe Institute
- Calgary Chamber of Commerce
- Canadian Council of Chief Executives
- Canadian Association of Petroleum Producers
- Canadian Society for Unconventional Resources
- Industrial Power Consumers Association of Alberta
- Northeast Capital Industrial Association
- Petroleum Technology Alliance Canada
- Public Policy Forum
- Resource Works Society
We support three categories of donations through Cenovus’s community investment program:
- Sponsorships (commercial initiatives): financial support to organizations for activities in the community that directly support a business objective or promote the commercial interests of the corporation
- Charitable donations: one-off or intermittent donations in response to charity appeals or in support of employee charitable activities
- Community investments: longer-term strategic involvement in community partnerships that address a specific range of social issues that are important to the company or to company stakeholders
The following list identifies the organizations to which Cenovus provided financial sponsorship support that totaled over $1,000 in 2016 for activities considered to be a “sponsorship” as defined above and that may also have supported advocacy in one or more of the following ways:
- Support of activities to encourage stakeholder dialogue on policy related matters that may have involved engagement with government officials
- Support of events that generally promoted a position on a project that aligned with Cenovus’s commercial interests
- Support of events (e.g. gala dinners) that provided general financial assistance to an organization known to undertake policy advocacy activity, such as meeting or corresponding with government officials for the purpose of influencing decisions. The advocacy position of these groups may or may not reflect Cenovus’s perspective
- Alberta Energy Challenge
- Alberta Student Energy Conference
- Calgary Chamber of Commerce
- Canadian Chamber of Commerce
- Canadian Club of Vancouver
- Carleton University
- Edmonton Chamber of Commerce
- Fraser Institute
- Fuse Collective
- Global Business Forum
- IHS CERA Oil Sands Dialogue
- Pembina Institute
- University of Ottawa Positive Energy Project
Our political contributions
Before changing its policy on March 1, 2017 to prohibit future contributions to political parties, Cenovus made two political contributions in 2016. This included donations to the British Columbia Liberal Party and Saskatchewan Party totalling less than $10,000 for each organization, respectively.