Governance

Photo by Kyla Chambers

High ethical standards start at the top.

We are committed to sound corporate governance practices directed by our active and engaged Board of Directors. Our Board of Directors reflects an effective balance of fresh perspective and industry and company experience, responsible for representing the long-term interests of our stockholders.

Our Board of Directors’ oversight includes the assessment of risks to our business and the measures taken to minimize and manage such risks, including in the areas of environmental stewardship, scenario analysis and planning, social responsibility, cyber-security and economic growth.

The Environmental, Social and Governance Committee (ESG Committee) of our Board of Directors is charged with oversight of climate-related issues. The ESG Committee reviews and assesses the effectiveness of the company’s ESG initiatives, and monitors, responds to, and makes recommendations regarding ESG-related trends and emerging issues, including climate-related risks and opportunities.

The ESG Committee periodically reviews the company’s status with respect to federal, state, and local regulations for air emissions, water, wildlife, spill reporting, safety, and general operations. The ESG Committee regularly reviews ESG-related disclosure practices within the industry and more broadly, peer benchmarking of ESG metrics, and changing technologies and practices that have the potential to improve the company’s overall ESG strategy and performance.

In addition to the ESG Committee, our CEO, who is a member of the Board of Directors, is a member of our Management ESG Committee and directs management’s efforts and responsibilities for climate related issues. This multidisciplinary committee meets regularly and works closely to identify, monitor, and evaluate environmental-related policy, regulatory, and legislative developments. The committee reports on current ESG risks and opportunities, makes recommendations to the Board of Directors on policies, programs, and initiatives necessary to achieve company’s ESG targets and goals, and monitors company performance towards achieving ESG goals and targets.

Ethics

We are committed to conducting our business consistent with the highest ethical standards. We value and expect integrity and honesty of our employees and contractors while operating in compliance with applicable laws and regulations. Our Code of Business Conduct and Conflict of Interest Policy states the standards of integrity and conduct that every SM Energy employee, officer, and director is expected to uphold. We conduct trainings on our Code and require annual certification of compliance. As a means of promoting compliance, we support multiple methods of reporting violations and concerns, including anonymous reporting through our confidential hotline, and we prohibit retaliation against any employee for providing information concerning a violation of law, regulation, or policy.

Cybersecurity

We believe cybersecurity plays a critical role in our core sustainability practices because information and communications technologies increasingly support our traditional sustainability activities. We have implemented security efforts to protect the confidentiality, integrity, and availability of information. This includes quarterly updates presented to the Board of Directors, building a culture of cybersecurity awareness and behaviors for employees, testing our response and business continuity capabilities in the event of an incident, including actively partnering with an external Incident Response team. Additionally, we perform tabletop cybersecurity and business continuity scenarios with our internal teams, our senior executive team, and our Board of Directors.

Advocacy and Lobbying

At SM Energy, we are proud to contribute to United States energy independence. To help our country become energy self-reliant, SM Energy works with industry partners and our legislative representatives to advocate for a secure energy future. SM Energy does not have a political action committee; however, through industry trade associations, we participate in the legislative process to inform policymakers and regulators about our industry and advocate for solutions that mutually benefit the communities in which we live and work.

SM Energy Hotline

1.844.747.2906 | sm-energy.ethicspoint.com

We are committed to preserving, protecting, and fostering a culture of trust and integrity that has long defined SM Energy as a company. Doing this requires that every SM Energy director, officer, employee, and contractor voice concerns of any suspected violation of the law or company policy.