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 April 2018 Amendments

On April 25, 2018, 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.

  • Updates to the sections dealing with diversity & respectful workplace and privacy to align them with, and reflect changes to, the content of the other corporate policies referenced in those sections.
  • Updates to the section on trade sanctions and anti-money laundering. When originally drafted, the prior “Economic Sanctions and Terrorism Financing” section was the company’s policy statement on these subject matters. This new “Trade Sanctions and Anti-Money Laundering” section was updated to highlight the key components of, and refers the reader to, Husky’s new Trade Sanctions and Anti-Money Laundering Policy.
  • The topics of community investment and political donations have been separated, as they are now managed independently, and political contributions are subject to an additional approval requirement.
  • The topic of accepting hospitality, promotional offerings and other business courtesies was updated and expanded as follows:
    • Added guidance on the acceptance of hospitality, promotional offerings and other business courtesies.
    • Added guidance on the meaning of “things of value”.

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