Doing what’s right

At Devon, we’re committed to doing what’s right and to demonstrating our fundamental value of integrity in all aspects of our business. Openness, honesty and respect are key to building trusting relationships, demonstrating courage and delivering results for our stakeholders. Our high standards of ethical and legal conduct, transparency and compliance with all applicable laws and regulations are vital to creating sustainable value for our shareholders.

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 reviews our business ethics program annually, including the Code of Business Conduct and Ethics (code) and our Anti-Corruption Policy and Procedures.

Establishing high standards

Our code and associated policies reflect a blending of best practices of legacy Devon and WPX following our merger in 2021. The code sets out the basic principles for legal and ethical conduct for each Devon director, officer and employee, and guides how we fulfill our responsibilities to each other, business partners, shareholders, governments and the law. We also require our chief executive officer, chief financial officer and chief accounting officer to adhere to an additional, more rigorous code of ethics.

我们预计德文郡董事、乐动电脑版官员和雇员to comply with policies associated with the code that provide guidance on specific business practices. These include our Zero Tolerance Anti-Harassment Policy, Drug and Alcohol Abuse Prevention and Testing Policy, Delegation of Authority Policy, Conflicts of Interest Policy and Environmental, Health and Safety Policy.

Devon proactively reinforces the importance and understanding of our ethical standards, legal obligations and regulatory compliance requirements. We require employees to complete an ethics training course when they join the company, and this training was part of onboarding for employees joining Devon from WPX in 2021. All employees receive the same ethics training annually, and must acknowledge and agree to abide by our code and its related policies. We reported a 100% rate of code acknowledgement in 2021 to the Audit Committee.

To maintain high awareness and understanding of Devon’s expectations, we review the training, code and policies each year and update them as needed.

Reporting violations

To help us maintain our relationships and reputation, Devon employees have an obligation to enforce the code and report potential violations. We do not allow retaliation for making a report in good faith.

Employees can make a report to our executive vice president and general counsel or to our third-party Ethics and Compliance Helpline, available at all times by phone and online. The Helpline is a secure, safe and confidential channel to report harassment, inappropriate behavior, fraud, unsafe acts, accounting irregularities, human rights violations or any other potential code or policy violation. In addition, employees can use the Helpline to seek guidance on our ethics policy, follow up on a reported issue or ask an ethics-related question. The Helpline is also available for reporting by stakeholders. Reports will be investigated promptly.

Fraud awareness

We work to prevent invoicing abuse, digital scams and other types of fraud with an active fraud awareness program. Our team of fraud examiners has fraud investigation experience. They help enable us to identify and avoid working with vendors that pose a fraud risk and quickly take action to prevent financial loss and mitigate risk.

Devon has expanded the composition of our internal steering committee that identifies industry trends and emerging threats. Committee members include field operations, supply chain and other functions. The committee also shares information with our corporate security, internal audit and digital security teams to prevent fraud across the company.

In 2022, we’re visiting major field offices to provide in-person fraud awareness training for employees who work in the field, in accounting and other functions, and to hear their observations about new threats and scams. We share information on fraud trends with all employees to help them recognize and report fraudulent activity.