Our intent is always to comply with all legal and regulatory requirements, including those pertaining to employment practices and business conduct. We take steps to ensure that our employees conduct themselves ethically in business dealings, and we are committed to preventing all forms of corruption within the scope of our business and operations.

Our Ethics & Compliance Program is designed to minimize, to the extent possible, incidences of non-compliance and to ensure that our employees and contractors conduct their work ethically, legally and responsibly. It is also intended to minimize the impact of unethical behavior on our corporate reputation, operations and financial performance; provide internal consistency in the application of compliance and ethical standards; and demonstrate our commitment to corporate social responsibility. The program establishes the accountabilities and responsibilities for our personnel, and addresses internal investigations, audits, self-reporting and discipline. As part of the program, we routinely monitor compliance and take steps to improve our ethics and compliance culture through adherence to established policies and procedures.

Oversight
The oversight of our Ethics & Compliance Program is a shared responsibility of the Audit, Finance & Risk Committee of our Board of Directors, our Executive Leadership Team and our Chief Compliance Officer. Our Chief Compliance Officer is responsible for Enbridge-wide oversight of our overall state of compliance and for enhancing our culture of ethics and integrity. At least once per year, our President & Chief Executive Officer communicates to all employees and provisioned contractors about the importance of ethical behavior through our mandatory training program on the Enbridge Statement on Business Conduct.

Our Ethics & Compliance department investigates significant compliance matters, whether they arise directly from employees, as a result of incidents, in reports received from the Ethics and Conduct Hotline, or under our Whistle Blower Policy. Depending on the nature of the matter in question, our Vice President & Chief Compliance Officer may report significant events related to non-compliance, auditing matters or general ethics issues either to the Audit, Finance & Risk Committee or to the Safety & Reliability Committee of our Board of Directors.

The Internal Audit department helps accomplish our objectives by bringing a systematic and disciplined approach to evaluating and improving the effectiveness of our governance and risk management processes and internal controls. It is responsible for evaluating the efficiency and effectiveness of our compliance with laws, regulations, policies, procedures and contracts.

Policies
Ethics & Compliance Policy: Through our Ethics & Compliance Policy, we provide a comprehensive system of compliance stewardship and accountability in all of our day-to-day operations. The policy outlines the structure for our Ethics & Compliance Program.

Enbridge Statement on Business Conduct: Following the merger with Spectra Energy in early 2017, we updated our comprehensive Statement on Business Conduct and communicated it across the enterprise in September 2017. The Statement includes provisions and references to various internal Enbridge policies and applies to Enbridge Inc., its subsidiaries and controlled entities, as well as their directors, officers, employees, consultants and contractors in all countries where Enbridge conducts business.

Whistle Blower Policy: Our Whistle Blower Policy is designed to protect the integrity of our accounting, auditing and financial control processes. Under the policy, employees and outside parties can confidentially report concerns about financial or accounting irregularities or unethical conduct to the chair of the Audit, Finance & Risk Committee of our Board of Directors. Complaints can also be made anonymously through our Ethics and Conduct Hotline.

Political Contributions Policy: In 2017, we introduced a new, comprehensive Political Contributions Policy that supports our commitment to the highest standard of ethical conduct in our involvement in the political process in all jurisdictions.

Non-Retaliation
We are committed to the principle that no retaliatory action may be taken against anyone who raises non-compliance issues in good faith. Our adherence to this non-retaliation principle is a key component of a strong culture of compliance, and ensures that employees, provisioned contractors and the public can be confident that we will fairly and impartially review and address all issues.

Employee Training
As a condition of employment, employees are required to complete an online Statement on Business Conduct training course. The online training requires employees to certify their compliance with our Statement on Business Conduct during the previous calendar year. Additionally, employees are also required to disclose any actual or potential conflicts of interest.

In 2017, Ethics & Compliance Department personnel provided in-person training sessions and presentations on compliance-related issues—including anti-corruption and bribery, anti-trust issues and prevention of privacy breaches, so as to prevent all incidents of these issues—to hundreds of employees and provisioned contractors.

Reporting Allegations of Non-compliance
Anyone can report issues about any potential breaches of the Statement of Business Conduct, Enbridge Policies and/or the Law. Enbridge maintains an Ethics and Conduct Hotline that is operated by a third-party service provider;  following the merger with Spectra Energy, the respective hotline systems were merged in July 2017. Our service provider delivers each hotline report directly to our Vice President & Chief Compliance Officer, and to our Ethics & Compliance Officers. Individuals who use the hotline may choose to identify themselves or remain anonymous.

We review these reports to the extent possible to address and resolve issues raised and confirmed as breaches with our policies or with the law.

In 2017, we received a total of 140 reports through the following channels:

Of those reports, 89 were anonymous. Some of these reports contained multiple allegations. From the 140 reports we received a total of 238 allegations, as follows:

Our intention is to work according to all external regulations and laws to prevent fines, penalties and violations (monetary and non-monetary).

We are reporting all of our fines, penalties and violations (monetary and non-monetary) in excess of CAN$10,000 and US$10,000 (depending on the country in which they occurred).

In 2017, we remitted the following fines, penalties and violations:

* In addition, the Consent Decree identified a number of enhanced safety measure that we must complete within a four-year period. These measures are, for the most part, consistent with the changes we have made to our overall approach to safety and integrity since our Marshall spill, and have largely been implemented over the past six years as part of the system-wide improvements we have made to our practices. Our compliance with the safety improvement measures specified in the Consent Decree is subject to independent verification.