Supervision, review and sanctions for violations of laws and regulations at the supranational, national and local level may lead to legal liability, substantial fines, claims for damages, criminal sanctions and other sanctions for noncompliance, and reputational damage.
Applicable laws and regulations include, among others, those relating to financial reporting, taxation, bribery and corruption, securities and commodities trading, fraud, competition and antitrust, safety and the environment, labour and employment practices, machine learning and artificial intelligence and data privacy rules.
The enactment of, or changes to, such laws and regulations or potentially conflicting supervisory directives and priorities, could create compliance challenges and increase the likelihood of a violation occurring.
Equinor is subject to oversight by multiple government authorities in Norway and internationally and may become subject to oversight or be required to report to additional government authorities going forward. Any actual or perceived non-compliance with applicable laws or regulations could result in audits, orders, investigations and could lead to enforcement actions, financial exposure, and operational or reputational impacts.
Equinor is, for example, subject to oversight by the Norwegian Ocean Industry Authority (Havtil), a government supervisory and administrative agency with regulatory responsibility for safety, the working environment, emergency preparedness and security Equinor’s equity securities are listed on Oslo Børs (OSE) and the New York Stock Exchange (NYSE) and its EMTN programme for debt securities is listed on the London Stock Exchange.
Equinor is a reporting company under the rules and regulations of the US Securities and Exchange Commission (the SEC). Equinor is required to comply with the continuing obligations of relevant regulatory authorities, and violation of these obligations may result in legal liability, the imposition of fines and other sanctions.
Equinor is also subject to review from financial supervisory authorities such as the Norwegian Financial Supervisory Authority (FSA) and the SEC. Reviews performed by financial supervisory authorities could result in changes to previously published financial statements and future accounting practices.
In addition, failure of external reporting to report data accurately and in compliance with applicable standards could result in regulatory action, legal liability, and damage to Equinor’s reputation. Trading activities are subject to regulation and actual or perceived non-compliance with such regulations may adversely affect the Group’s financial results and performance.
Individuals or groups of traders acting for or on behalf of Equinor have in the past, and may in the future, act outside of their respective mandates or in speculative manners which are perceived as inappropriate by regulatory authorities which could result in financial loss, fines, reputational damage or loss of licence to operate, including permissions to trade.
Assurance of financial or sustainability statements could identify deficiencies in Equinor’s internal control processes over reporting, which may result in remediation costs and loss of investor confidence that can potentially impact the market price of our securities. Errors, inconsistencies, misinterpretation, misuse or lack of information in our external reporting (e.g. related to environmental matters) can similarly cause loss of investor confidence and expose us to risks associated with accusations of greenwashing.
Non-compliance with anti-corruption and bribery laws, anti-money laundering laws, competition and antitrust laws, sanctions and trade restrictions, human rights legislation or other applicable laws, or failure to meet Equinor’s ethical requirements, could expose Equinor to legal liability, lead to a loss of business, loss of access to capital and damage our reputation and social licence to operate.
Equinor is subject to anti-corruption and bribery laws and anti-money laundering laws in multiple jurisdictions, including the Norwegian Penal code, the US Foreign Corrupt Practices Act and the UK Bribery Act. A violation of such applicable laws could expose Equinor to investigations from multiple authorities and may lead to criminal and/or civil liability with substantial fines.
Incidents of non-compliance with applicable anti-corruption and bribery laws and regulations and the Equinor Code of Conduct could be damaging to Equinor’s reputation, competitive position, and shareholder value. Similarly, a breach of human rights legislation, due diligence and reporting obligations or a failure to uphold our human rights policy may lead to economic sanctions or damage our reputation and social licence to operate.
Equinor has a diverse portfolio of projects worldwide and operates in markets and sectors impacted by sanctions and international trade restrictions. Sanctions and trade restrictions are complex, unpredictable and are often implemented at short notice. Any violation, even if minor in monetary terms, could result in substantial civil and/or criminal penalties and could materially adversely affect Equinor’s business and results of operations or financial condition.
Equinor is subject to competition and antitrust laws in multiple jurisdictions, including the Norwegian Competition Act, the Treaty of the Functioning of the European Union and the Unites States’ Sherman Act, Clayton Act, HSR Act and Federal Trade Commission Act. A violation of such laws could expose Equinor to investigations from multiple authorities and may lead to criminal and/or civil liability with substantial fines.
Incidents of noncompliance with applicable competition and antitrust laws and the Equinor Code of Conduct could be damaging to Equinor’s reputation, competitive position, and shareholder value. There can be no assurance that Equinor’s policies and procedures will be successful in preventing any violations of applicable laws and regulations of this nature.