ethics

ExxonMobil complies with all governmental laws, rules, and regulations applicable to our business. We expect employee candor at all levels and adherence to company policies and controls. Employees are responsible for reporting suspected violations of law or corporate policy to management. Each year, our employees are required to confirm that they have read and are familiar with the policies set forth in our Standards of Business Conduct. We conduct detailed training on the Standards on a regular basis to ensure that employees understand company expectations.

Our Standards of Business Conduct include a Code of Ethics and Business Conduct, which outlines our policies to prevent bribery and corruption. It includes clear guidance on ethics, gifts and entertainment, conflicts of interest, antitrust, and directorship policies. Responsibilities for authorizing, approving, and recording financial transactions are appropriately segregated to reduce risks. All payments to third parties are expected to comply with the Foreign Corrupt Practices Act and our Guidelines for Payments to Third Parties.

Internal Audits
On average, one-third of corporate business activities and operating units are audited by our internal audit department each year, and operating units also undergo regular self-assessments. ExxonMobil deploys approximately 250 specially trained internal auditors throughout our facilities and business units. Internal auditors have unrestricted access to facilities, personnel, and records. Independent investigations are conducted in situations of potential noncompliance with ExxonMobil’s Standards of Business Conduct.

Investigations of Potential Policy Violations
Internal auditors and management investigate suspected violations of law, business practices, or internal control procedures, which include conflicts of interest, exceeding transaction authority limits, falsified expense reports, misuse of company assets and credit cards, and petty theft. Potential cases of noncompliance are identified through internal control procedures, supervisory reviews, hotline calls, and employee or third-party tips. Each case is thoroughly investigated through document reviews and interviews. Confidentiality is maintained throughout the process, and results are reviewed with audit personnel and business management to determine appropriate action.

Violations by employees lead to disciplinary actions up to, and including, separation from the company. Significant matters are reported to the Audit Committee of the Board of Directors. The Board makes no exception for cases involving an executive officer or director.

Reporting Suspected Violations
The Corporation provides a number of mechanisms to employees for reporting suspected violations, including a hotline phone number and mailing address. Correspondence is handled by a Hotline Steering Committee, comprised of security, audit, law, and human resources personnel, and reported to the Audit Committee on a quarterly basis. We expect persons responding to employee questions, concerns, complaints, and suggestions to use discretion to maintain confidentiality and protect anonymity to the greatest extent possible. No action can be taken or threatened against any employee for asking questions, voicing concerns, or making complaints in conformance with company procedures.