7 Standards of Business Conduct Overview

7/27/2019 7 Standards of Business Conduct Overview

1/20

Standards of Business Conduct

Overview


2/20

- 2 -

ExxonMobi l

Standards of Business Conduct - Key Principles

The methods we employ to attain results are as important as the resultsthemselves

ExxonMobils reputation for honesty, ethical behavior and fair dealing is a

priceless company asset

The Standards of Business Conduct policies provide the framework for howall employees are to operate

The Corporations employees are expected to observe the highest standards

of integrity in the conduct of the Corporations business

Lack of compliance could potentially result in violations of laws or governmentregulations, misstatement of financial results, loss of customers or preferredsuppliers, inadequate product quality, environmental incidents, and more.

ExxonMobils reputation as a corporate citizen depends on our understanding of

and compliance with the Standards of Business Conduct


3/20

Standards of Business Conduct

Environment Policy

Guiding Principles

Safety Policy

Product Safety Policy

Ethics Policy Customer Relations and

Product Quality Policy

Conflicts of Interest Policy

Alcohol and Drug Use Policy

Corporate Assets Policy Equal Employment

Opportunity Policy

Directorships Policy

Gifts and Entertainment Policy

Harassment in the WorkplacePolicy

Political Activities Policy

International OperationsPolicy

Antitrust Policy

Procedures and Open DoorCommunication

Health Policy


4/20

- 4 -

ExxonMobi l

Employee Irregularities

DISCIPLINE

Employee irregularities result in discipline up to and including termination.

Management determines disciplinewith Audits endorsementafter an investigationis conducted.

Internal Audit must be notified as soon as a potential irregularity is identified.

Potential cases must be reported to site Controllers/Controls Advisor who will

contact Internal Audit.

Audit performs an independent review of the investigation and determines if areportable irregularity has taken place

Self-disclosure and full cooperation during the investigation may be mitigatingfactors in determining discipline.


5/20

- 5 -

ExxonMobi l

Ethics Policy

BACKGROUND:

Defines expectations for integrity, honesty, and candor in our business dealings

Requires candor from employees at all levels and adherence to policies and internalcontrols

Requires compliance with government laws, rules and regulations

States that no employee can direct another employee or contractor to violate any policyor law

Requires all transactions to be accurately reflected in the books and records of theCorporation


6/20

- 6 -

ExxonMobi l

Ethics Policy Violation Examples

Deliberately...

Violating the law or regulations

Bypassing required approvals

Falsifying accounting records and reconciliations, lab results, product specification tests,equipment inspection reports, production volume reports, witnessing and inventory records

Misreporting of safety or environmental incident, including cover-up of what actuallyhappened

Maintaining any off-the-record bank accounts

Splitting of an invoice or requisition or AFE to avoid proper approval level

Lying to or hiding something from the Internal/External auditors or Management

Misstating management stewardship reports

DISCIPLINE

Almost always termination (or the maximum allowed under local law).


7/20- 7 -

ExxonMobi l

Conflicts of Interest (COI) Policy

BACKGROUND:

Involves a situation where an employees personal interests are, or could give the

appearance of being, in conflict with the Companys interests

Policy supplemented by detailed guidelines - violating a specific guideline is consideredviolating the policy

Many of the individual guidelines extend to the employees spouse and dependent family

members

Many (but not all) of the individual guidelines require review of employee situations andconsent by a senior executive


8/20- 8 -

ExxonMobi l

COI Policy Violation Examples

Competing with the Company via a personal business (i.e. business selling seismic data; having anownership interest in a service station)

Employment of employee's spouse or dependent by a competitor in a common technical/professionalfield where they normally have access to proprietary information and Management approval notobtained.

Awarding work to or having administrative oversight over a supplier that employs a close familymember

Purchase, sale or lease of property, facilities or equipment from or to the Company where an

opportunity for preferential treatment and Management approval not obtained.

Requesting a supplier to consider employing a family member when in a position to influence theamount of ExxonMobil business awarded to the supplier

Ownership of mineral interests without Management approval

Using information obtained in employee role that is not available to the public to make personalinvestment decisions

Use of Company personnel, facilities, equipment or supplies for personal benefit and not in accordancewith accepted practices and procedures

Buying or selling puts or calls or other options on ExxonMobil stock (applies to MPT employees,spouses and dependent family members)

DISCIPLINE

Usually termination


9/20- 9 -

ExxonMobi l

Corporate Assets

BACKGROUND:

Generally involves a deliberate action for personal gain

Many actions included in this category:

Thefts over $5K (8010)

Misuse of assets

Expense account, credit card and employee program abuse Information disclosure

Loss from third party actions

Category includes theft of property by unknown persons


10/20- 10 -

ExxonMobi l

Corporate Assets Examples

Intentional personal use of a Company credit card (AMEX, P-Card, etc) even when

payment is made promptly A single accidental personal use (provided wrong card) is not an irregularity providedit is self-disclosed as soon as it is known and payment is made promptly.

Excessive personal use (more than de minimus) of Company assets, including PC,internet, telephone, cell phone, copier

Accessing and/or distributing sexually explicit materials Zero Tolerance

Thefts and attempted thefts of Company cash or assets or time (excessive absenteeism isa performance issue, being absent while claiming to be at work may be an irregularity)

Misuse of Company assets

Lying to obtain Company benefits where the benefits were not earned: Educationalreimbursement, matching grants, etc.

Falsification of expense statement for personal gain

Inappropriate disclosure (intentional or unintentional) of significant Company information

DISCIPLINE

Depending on the circumstances, can range from verbal reprimand to termination


11/20


12/20- 12 -

ExxonMobi l

Gifts and Entertainment

BACKGROUND:

Expects employees to use good judgment taking into account pertinentcircumstances:

Serves a valid business purpose

In keeping with good business ethics

Is customary and proper under the circumstances and gives no appearance ofimpropriety

Does not impose any sense of obligation on the recipient to the donor

Cannot be viewed as frequent, extravagant or excessive

Does not involve materials, services, repairs or improvements at no cost or anunreasonably low cost

Employee is able to reciprocate

Giving or receiving cash is never allowed without a pre-approved exception.

EXAMPLE:

Employee accepts/provides significant inappropriate gifts or entertainmentwithout Management approval.


13/20


14/20

Drug & Alcohol Policy

The Corporation recognizes that alcohol, drug, or other substance abuseby employees will impair their ability to perform properly and will haveserious adverse effects on the safety, efficiency and productivity of otheremployees and the Corporation as a whole.

The misuse of legitimate drugs, or the use, possession, distribution or

sale of illicit or unprescribed controlled drugs on company business orpremises, is strictly prohibited and is grounds for termination.

Possession, use, distribution, or sale of alcoholic beverages oncompany premises is not allowed without prior approval of appropriatesenior management.

Being unfit for work because of use of drugs or alcohol is strictlyprohibited and is grounds for termination of employment.

While this policy refers specifically to alcohol and drugs, it is intended toapply to inhalants and all other forms of substance abuse.


15/20


The Corporation recognizes alcohol or drug dependency as atreatable condition. Employees who suspect they have an alcohol ordrug dependency are encouraged to seek advice and to followappropriate treatment promptly before it results in job performanceproblems.. No employee with alcohol or drug dependency will be

terminated due to the request for help in overcoming thatdependency or because of involvement in a rehabilitation effort.

The Corporation may also require employees to submit to medicalevaluation or alcohol and drug testing where cause exists to suspectalcohol or drug use, including workplace incidents.


16/20


The Corporation may conduct unannounced searches for drugs andalcohol on company owned or controlled property.

Unannounced periodic or random testing will be conducted when anemployee meets any one of the following conditions: has had a

substance abuse problem, or is working in a designated positionidentified by management, a position where testing is required bylaw, or a specified executive position. A positive test result or refusalto submit to a drug or alcohol test is grounds for disciplinary action,including termination.


17/20

Harassment in the Workplace

It is the policy of Exxon Mobil Corporation to prohibit any

form of harassment in any company workplace. The

policy prohibits unlawful harassment based on race,color, sex, religion, national origin, citizenship status, age,

physical or mental disability, veteran or other protected

status


18/20


Under the Corporation's policy, harassment is any inappropriateconduct which has the purpose or effect of:

creating an intimidating, hostile, or offensive work environment;

unreasonably interfering with an individual's work performance;

or affecting an individual's employment opportunity.

Forms of harassment include, but are not limited to, unwelcomeverbal or physical advances and sexually, racially, or otherwise

derogatory or discriminatory materials, statements, or remarks.

All employees, including supervisors and managers, will be subjectto disciplinary action up to and including termination for any act ofharassment.


19/20


Employees or supervisors who observe or become aware ofharassment should immediately advise their supervisors, highermanagement, or their designated Human Resources Departmentcontacts. No employee should assume that the Corporation is awareof a problem. All complaints and concerns should be brought tomanagement's or the Human Resources Departments attention sothat appropriate corrective steps can be taken.

No retaliation will be taken against any employee because he or shereports a problem concerning possible acts of harassment.


20/20

I Will Not Get Hurt Today

Documents

7 Standards of Business Conduct Overview