To live out our core value to always do the right thing, we embrace honesty and uncompromised integrity in everything we do.

In all of our business practices and relationships, Devon is committed to high ethical, moral, professional and legal standards. Our Code of Business Conduct and Ethics guides each Devon director, officer and employee in meeting our standards and fulfilling our responsibilities to our shareholders, governmental and regulatory authorities, business partners and each other. In addition, Devon’s president and chief executive officer (CEO), chief financial officer and chief accounting officer must meet further requirements for the highest level of ethical and legal behavior as described in a separate Code of Ethics.

We also require directors, officers and employees to comply with related policies, including our Zero Tolerance Anti-Harassment Policy, Anti-Corruption Policy, and Employee Gifts and Entertainment Declaration Policy and Procedure. These policies and our code of conduct are reviewed and updated annually to ensure ongoing compliance with laws and regulations and to reflect current business practices. No substantive changes were made to our code or related policies in 2018.

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To ensure high awareness of our commitment to ethics and integrity, all Devon employees must successfully complete a training course on ethics when they join the company and annually thereafter. We also require employees to acknowledge and agree to abide by the Code of Business Conduct and Ethics annually.

Devon employees are obligated to help enforce the code by reporting potential violations via one of several confidential channels, including our Ethics & Compliance Helpline. Anyone can access the Helpline at any time to report harassment, inappropriate behavior, fraud, unsafe acts, accounting irregularities or any other potential code or policy violation. In 2018, 85% of reports were made through this online portal. The Helpline can also be used to request guidance on Devon’s ethics policy, follow up on a reported issue or to ask an ethics-related question.

Reports to the Helpline can be made anonymously and confidentially. Approximately 65% of Helpline users request anonymity, and all reports are treated as confidential to the fullest extent possible. Devon investigates reports promptly, with 100% of cases initiated in 2018 closed by year-end at an average of 19 days from the opening of an investigation to its close. In 2018, 71% of reports were unsubstantiated or simple inquiries. We have not experienced a pattern of specific types of allegations or issues related to specific locations. We do not tolerate retaliation against anyone who makes a good-faith report of an actual or suspected violation of our code, policies or applicable law. We provide the board of directors with periodic reports on Helpline activity to assist in the board's role of monitoring our ethical standards and practices.