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  • As referenced in the 2009 Corporate Citizenship Report Corporate Governance 2009 Corporate Citizenship Report

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Ethics

We believe that an unwavering commitment to high ethical standards and business integrity is critical to our competitive advantage and shareholder value. We expect our employees to integrate our commitment to ethical behavior into their activities and decision-making, including complying with all applicable laws and recording all transactions accurately in our books and records. Employees are required to annually confirm they have read the policies set forth in our Standards of Business Conduct. We provide detailed training on our ethics policy to all employees every four years. Regular training is provided on international trade laws applicable to our business, including the anti-trust and competition laws of the United States and other countries where we do business.

Bribery and corruption.
ExxonMobil’s Anti-Corruption Legal Compliance Summary lays out policies that govern our anti-corruption compliance program and our commitment to compliance with the U.S. Foreign Corrupt Practices Act (FCPA) and global anti-corruption conventions in all business relationships, including those with consultants, agents, and intermediaries. In compliance with the FCPA and other anti-corruption laws, all ExxonMobil employees and contractors are prohibited from making improper payments to, or engaging in improper transactions with, government officials to influence the performance of their official duties. As required under the FCPA, we maintain appropriate internal controls and keep accurate and complete records of the transactions in which we engage.

Our formal anti-corruption law training program includes annual training for employees in sensitive positions who might engage with government officials in countries reputed to be at high risk for corruption. In 2009, over 7000 employees received this focused training. Biennial, basic anti-corruption training is also provided worldwide for personnel who may interact with government agencies or officials; the next will occur in 2010. Every four years, all employees worldwide are required to attend a half-day Business Practices Review, which includes anti-corruption training. Business Practices Reviews were held in 2008 and are scheduled for 2012.

Doing business in some developing countries or remote areas in which oil and gas are found can be challenging in that there may be a limited number of local businesses and a small population of educated citizens. As a result, there may be a small community of government officials and business owners, many of whom are connected by a network of social and family relations. These conditions do not alter ExxonMobil’s commitment to full compliance with the FCPA and local laws and may require extensive analysis of business relationships to ensure they are at arm’s length, transparent, and based on fair market value. Our standard language for all contracts includes a corruption prevention and business ethics clause.

Internal audits
On average, our internal auditors conduct comprehensive audits of one-third of our corporate operating units and business activities each year. In 2009, this included an audit of the reporting processes behind the previous Corporate Citizenship Report. Approximately 240 trained internal auditors have unrestricted access to facilities, business units, personnel, and records and are empowered to investigate all potential noncompliance with the Standards and anti-corruption laws.

Reporting and investigating suspected violations
The Corporation provides a number of mechanisms to employees for reporting suspected violations of company policies, including a 24-hour hotline phone number and mailing address. A Hotline Steering Committee, comprising security, audit, law, and human resources personnel, handles suspected violations and provides a report to the Audit Committee on a quarterly basis. Internal auditors and management investigate suspected violations of law, business practices, or internal control procedures. Each case is thoroughly investigated, while maintaining confidentiality, and significant matters are reported to the Audit Committee. No action can be taken or threatened against any employee for asking questions, voicing concerns, or making complaints in conformance with company procedures. Violations by employees lead to disciplinary actions up to, and including, separation from the company. The Board makes no exception for cases involving an executive officer or director.