Our presence in nearly every country of the world requires training on international trade laws, including U.S. anti-corruption and anti-trust laws, as well as those in other countries where we do business. All employees are expected to uphold the highest ethical standards of business integrity. Each must comply with all applicable laws and accurately record and track all business transactions.
Employees are subject to disciplinary action, including termination, for violations of our policies. Employees receive training on our ethics policy every four years through business practices reviews, including a detailed review of our Standards of Business Conduct, implementation guidelines and procedures, and the Corporation’s anti-trust and anti-corruption policies. These general training sessions, in addition to more comprehensive training given to relevant functions on a more frequent basis, are a condition of employment at ExxonMobil.
Standards of Business Conduct
Our Standards of Business Conduct define the global ethical conduct of the Corporation and its majority-owned subsidiaries. These Standards, adopted and administered by the board of directors, uphold the values of human rights, labor, the environment and anti-corruption. While ExxonMobil is not a formal signatory of the United Nations Global Compact, its values represent key elements of our Standards. No one has authority to make exceptions or grant waivers to the Standards, and employees are expected to review the Standards each year. Disciplinary action is taken against any employee who violates them.
Regular internal audits and self-assessments help ensure the rigorous implementation of our control systems and Standards of Business Conduct. ExxonMobil’s internal team of more than 200 auditors annually audits approximately one-third of ExxonMobil’s operations, conducting detailed assessments of facilities, business units, personnel and records, and thoroughly investigating noncompliance with the standards. These audits are conducted across all functions of the Corporation.
Bribery and corruption
Anti-corruption practices are an essential component of our compliance program, given that we operate globally and in many challenging environments. The Anti-Corruption Legal Compliance Summary outlines ExxonMobil’s commitment to comply with the U.S. Foreign Corrupt Practices Act (FCPA), the United Kingdom Bribery Act and global anticorruption standards in all business relationships. It also describes elements of the Corporation’s anti-corruption compliance program.
ExxonMobil employees and contractors are prohibited from making payments to, or engaging in transactions with, government officials to influence the performance of their official duties improperly. Maintaining internal controls and keeping accurate and complete transaction records are required. Our standard language for procurement contracts includes a requirement to comply with all laws, keep accurate books and records, and where appropriate, contains specific anti-bribery commitments.
Oil and gas exploration and production often take us to remote parts of the world, with changing political and regulatory climates. In 2012, approximately 31,000 employees took part in anti-corruption training. This training covers the basics of the FCPA, the United Kingdom Bribery Act, global anti-corruption standards, recent developments in enforcement, and compliance with our internal anti-corruption policy, guidelines and processes. Employees in positions assessed to be higher-risk receive training every year and within three months of entering their positions. Every two years, managers and professional employees not in higher-risk positions receive training. Every four years, all ExxonMobil employees are required to attend half-day business practices reviews that include anti-corruption issues. In 2012, employees around the world attended business practices review sessions. Additionally, we monitor legal and regulatory developments and advise employees as appropriate.
We reinforce our commitment to ethics and high standards of business conduct with the expectation that all employees will report suspected violations of laws and company policies. The Corporation provides several confidential mechanisms for reporting, including a 24-hour phone number and a mailing address. Employees can also report violations during supervisory reviews. Confidentiality is respected throughout the investigation process subject to legal requirements; penalizing or threatening an employee for filing a report is prohibited. A Hotline Steering Committee comprising security, audit, law and human resources personnel reviews all reports of suspected violations. The Hotline Steering Committee provides a quarterly report to the Audit Committee, including any violations or major issues. Violations lead to disciplinary actions, including dismissal.
ExxonMobil’s System of Management Control Basic Standards defines essential principles and concepts that drive our business controls. Our Controls Integrity Management System is designed to assess and measure financial control risks, including procedures for mitigating concerns, monitoring compliance with standards and reporting results to the appropriate operations and management groups within ExxonMobil.
These company-wide financial controls meet or exceed the requirements of the Sarbanes-Oxley Act and New York Stock Exchange listing standards. PricewaterhouseCoopers LLP conducted an independent assessment that determined our internal controls system is effective for financial reporting. Regular self-assessments and audits help ensure that every operating unit consistently implements our controls and standards.