Setting Third Party Expectations
We hold our contractors and other third parties to the same high ethical standards that we expect of ourselves. They are accountable for assuring the quality and safety of the goods and services they provide us.
Similarly, we are each responsible for knowing and complying with the requirements of the contracts we are working on at all times.
Ensuring Fair Competition
Antitrust or competition laws are designed to preserve a level playing field for all businesses. They promote open and fair competition and prohibit any agreement or practice that unreasonably restrains trade. These laws help ensure that our shippers enjoy the benefit of open competition among the pipelines and other modes of transportation they can use, and that our vendors benefit from competition among their purchasers.
While competition laws are complex, they generally forbid entering into formal or informal agreements with competitors that may restrain trade, such as price fixing, bid rigging, or dividing or allocating markets, territories, or shippers. If a Colonial competitor attempts to discuss any of these topics with you, stop the conversation immediately and walk away. Be particularly cautious when attending trade events, seminars, or industry conferences. In general, avoid conversations about competitively sensitive information (especially rates, services, costs, and expansion plans) with representatives of our competitors. You should report any questionable incident to your manager and the Legal Department immediately.
Appropriate Use Of Competitive Information
Sometimes we have access to information about our competitors that may give us a business advantage. This information may come from our business partners, or from new employees who previously worked for or have information about a competitor. It is important that we act legally and ethically at all times with respect to this information. If confidential information about a competitor is deliberately or inadvertently disclosed to you, contact the Legal Department.
Did You Know?
In 2019, Colonial was recognized as one of the top privately owned companies in America as part of the Inc. Magazine “Private Titans 1000.”
Q&A
Q: I am a manager and one of my team members who recently joined Colonial from a competitor has brought with her to Colonial a strategic plan from her former employer, as well as one of her old employer’s training manuals. She says she wants to use it at Colonial. Should I just ignore this and let her do it?
A. No. If an employee retains competitor information it can result in legal action by the competitor. You must report this to the Legal Department immediately for appropriate action.
Q&A
Q: My work at Colonial requires regular interaction with T.S.A. officials. As part of my job, I am routinely asked to provide the T.S.A. with information about our security program. Do I really need to contact the Legal prior to each and every submission of information to the government?
A. The right approach here would be to discuss with a Colonial attorney and the Director of Government Affairs regarding the types of requests your department routinely receives from the T.S.A. These routine requests, once understood by the Legal Department, could be handled without any legal review according to a prearranged procedure. Extraordinary requests would still require Legal Department review to ensure that you are responding accurately, fully and in accordance with the law.
Q&A
Q: A state elected official would like to know more about Colonial Pipeline and has requested a tour of our operations. Who should I contact to properly vet and facilitate this request?
A. Please notify the Director of Government Affairs to properly engage this type of request.
Working with Regulators and the Government
When we are working with regulators and the government, special rules and regulations apply to us. Above all, we must always be truthful and accurate when dealing with regulators, government employees, officials, and agencies. This means that we must:
• Know and comply with all government contract requirements and details
• Ensure all reports, certifications and statements to the government are current, accurate and complete
• Code all time allocations and costs appropriately
• Act according to our values and Colonial’s best interests
• Answer questions with factual information only; if you are unable to answer, defer the request to your manager or the Director of Government Affairs
Inspections and Investigations
We are committed to promptly responding to and complying with all types of lawful inspections and investigations, including those conducted by the government. We always provide investigators with the information to which they are entitled, and take prompt action to preserve documents that are relevant to any such investigation. Unless handling these types of requests is a routine part of your job, speak with our Legal Department immediately to ensure that requests are addressed properly.