Responsible business conduct

Integrity is the foundational corporate value at Devon. Doing business with openness and honesty is the starting point to live out our other core values of building trusting relationships, having courage to take intelligent risks and delivering results.

Devon is committed to high ethical, moral, professional and legal standards in all our business practices and relationships. We seek to always do what’s right, be transparent with our results and speak up with respect.

The Audit Committee of Devon’s board of directors monitors our business practices and ethical standards and oversees legal and regulatory compliance. Together with Devon’s executive vice president and general counsel, the Audit Committee annually reviews our business ethics program, including the code and our Anti-Corruption Policy and Procedures.

The code guides each Devon director, officer and employee in fulfilling our responsibilities to each other, our business partners, shareholders, government and legal systems. We also require our chief executive officer, chief financial officer and chief accounting officer to adhere to an additional, more stringent Code of Ethics holding them to the highest level of ethical and legal behavior.

Devon directors, officers and employees also are expected to comply with policies that provide guidance on specific business practices. These include our Zero Tolerance Anti-Harassment Policy, Anti-Corruption Policy and Procedure, Conflicts of Interest Policy, Employee Gifts and Entertainment Declaration Policy, Information System General Usage Policy and Environmental, Health, and Safety Policy.

We take proactive steps to reinforce the importance of understanding our ethical standards, legal obligations and regulatory compliance requirements. Devon employees are required to complete an ethics training course when they join the company. Following the merger, employees joining Devon from WPX received this ethics training as part of their onboarding. Annually, all employees receive the same ethics training and are required to acknowledge and agree to abide by our Code of Business Conduct and Ethics.

We review the training, code and policies each year and update them as needed to keep the content current and relevant. Our goal is to maintain high awareness and understanding of Devon’s expectations.

Obligations for reporting

Violations of the code or related policies are serious matters that could damage Devon’s relationships and reputation. Devon employees are obligated to enforce the code and report potential violations, with no fear of retaliation. Reports can be made by contacting our executive vice president and general counsel.

Employees and other stakeholders may also make a safe, secure and confidential report to our third-party Ethics and Compliance Helpline by phone or online. The Helpline is available at all times to report harassment, inappropriate behavior, fraud, unsafe acts, accounting irregularities, human rights violations or any other potential code or policy violation. The Helpline can also be used to seek guidance on Devon’s ethics policy, follow up on a reported issue or ask an ethics-related question. Our board of directors receives periodic reports on Helpline activity to assist in its role of monitoring our ethical standards and practices.