Company Communications, Disclosure and Insider Trading / Reporting Policy

Husky Energy Inc. has publicly traded securities and, therefore, must comply with certain legal and regulatory requirements regarding the public disclosure of Material Information and its directors, officers and employees must comply with insider trading and reporting requirements.

Code of Business Conduct

Husky and its employees will conduct themselves in accordance with the Husky Code of Business Conduct. As set out in the Code, employees are expected to accept certain responsibilities, adhere to acceptable legal business principles, and exhibit a high degree of personal integrity at all times. The Code sets out the standards an employee is expected to meet, and includes sections on compliance with laws, avoidance of conflict of interest, proper record-keeping, political contributions, safeguarding of company resources, fair competition, bribery or other offering of payments, and guidelines on accepting payments and entertainment.

Husky takes very seriously any allegation that an employee has not conducted him or herself in accordance with the Code of Business Conduct. Anyone who is concerned about a potential instance of non-compliance by a Husky employee or contractor is encouraged to discuss it with their supervisor or manager. If that is inappropriate, ineffective, or uncomfortable, you may report the potential non-compliance through the Ethics Help Line.

An employee who is found to have engaged in conduct contrary to the Code of Business Conduct will be disciplined, up to and including termination of employment for just cause.

Husky prohibits retaliatory action against any employee who, in good faith, reports a possible violation.

Summary of February 2017 Amendments

On February 23, 2017, the Board of Directors of Husky Energy Inc. approved a general update of its Code of Business Conduct. The following is a general summary of the principal areas of change.

  • Revised so that the Code applies to Husky Energy Inc. and all divisions, subsidiaries and affiliate companies instead of Husky Oil Operations Limited.
  • Updates to the sections dealing with alcohol and drugs, fair competition, bribery and other improper payments, insider trading, and privacy to align them with, and reflect changes to, the content of the other corporate policies referenced in those sections.
  • The topics of accepting hospitality, lobbying, confidential information, and conflicts of interest were updated and expanded as follows:
    • Added guidance on the acceptance of hospitality and other business courtesies.
    • Added language to highlight that jurisdictions outside Canada have different rules regarding lobbying.
    • Added requirement to consult with the Legal Department or appropriate Senior Vice President prior to engaging in lobbying to ensure compliance with all applicable lobbying rules.
    • The definition of confidential information was expanded to include (i) contractor and customer lists, and (ii) material non-disclosed information, as dealt with in the Company Communications, Disclosure and Insider Trading/Reporting Policy.
    • Added prohibition on personal use of confidential information or intellectual property.
    • Included partners in the list of entity types that Personnel could have a potential conflict with.
    • Specified that restrictions on relationships with suppliers, customers, partners and competitors will also apply, as appropriate, to affiliates of those entities.
  • Specified that the non-retaliation provision does not apply to Personnel if they participated in prohibited activity, even if they reported it.

Majority Voting Policy

The Board of Directors of Husky Energy Inc. has adopted a policy providing for majority voting for director elections at any meeting of the Company’s shareholders where an uncontested election of directors is held.

Download the Company Communications, Disclosure and Insider Trading / Reporting Policy
Download the Code of Business Conduct