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 2019 Amendments

On April 25, 2019, 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 section on lobbying to provide additional guidance on which activities constitute lobbying and when and to whom to report lobbying activities. When originally drafted, this section was Canadian centric, so updates were made to reflect other lobbying laws to which Husky is subject.
  • Updates to the section on accepting hospitality, promotional offerings and other business courtesies to align with, and reflect changes to, Husky's Anti-Bribery and Anti-Corruption Policy. This included updating the definition of "things of value" and the rules regarding the acceptance or giving of bona fide hospitality, promotional offerings and other business courtesies.
  • Updates to the section on privacy to provide additional guidance on handling of personal information and to reflect Taiwanese privacy law requirements.
  • A number of minor revisions to ensure alignment with other corporate policies.

To read the entire policy, refer to the Code of Business Conduct.
For more information about the policy, contact Jim Girgulis, Senior Vice President, General Counsel & Secretary.

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 Companys 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
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