Ethics

ExxonMobil transacts business activities in nearly every country of the world, necessitating regular training on international trade laws, including the anti-corruption and antitrust laws of the United States and other countries where we do business. All employees are expected to uphold high ethical standards and business integrity. They must comply with all applicable laws and accurately record and track all transactions. Employees are subject to disciplinary action up to, and 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 a review of antitrust, competition, and anti-corruption laws. These general training sessions, in addition to more comprehensive training given to relevant functions, are a requirement of employment at ExxonMobil. This training is supplemented by annual redistribution of the policy to ensure ongoing employee awareness. The next general review session is scheduled for 2012.

Standards of Business Conduct
Our commitment to ethics creates a competitive advantage for the Corporation and helps ensure shareholder value. Our culture of ethical standards and compliance is documented in our Standards of Business Conduct, which foster the values of human rights, labor standards, the environment, and anti-corruption as outlined in the United Nations Global Compact. While ExxonMobil is not a formal signatory of the Global Compact, its values are key elements of our Standards. The Board of Directors has adopted and oversees the administration of the Standards—the foundation policies of the Corporation. The Standards articulate expectations and define the basis for the worldwide conduct of the Corporation and its majority-owned subsidiaries. Employees are expected to review the Standards each year. Disciplinary action is taken against any employee who violates these Standards. There are absolutely no exceptions to this approach.

Internal audits
Regular internal audits and self-assessments help ensure the rigorous implementation of our control systems and Standards. ExxonMobil’s internal audit team annually audits about one-third of ExxonMobil’s operations, conducting detailed assessments of facilities, business units, personnel, and records, and thoroughly investigating noncompliance with the Standards.

Bribery and corruption
We maintain our strong commitment to anti-corruption practices in all of our operations worldwide. The Anti-Corruption Legal Compliance Summary details 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. To ensure compliance, 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. In a few parts of the world, we conduct oil and gas exploration and production in remote areas where there may only be a limited number of local businesses and a small technically skilled population. Government structures and local business practices are sometimes closely linked through social and family relationships. In these challenging situations, ExxonMobil steadfastly upholds our commitment to full compliance with the FCPA and local laws, even if it requires extensive analysis of business relationships to ensure transparency. Our standard language for all contracts includes a requirement to comply with all laws and to keep accurate books and records, and where appropriate, contains specific anti-bribery commitments. For all new agreements and renewals, our procurement staff assesses baseline information obtained in procurement processes to recognize warning signs, and when necessary, consults the law department. In addition, procurement staff must comply with a mandatory screening process to ensure that proper anti-corruption due diligence is being performed on intermediaries in countries that are assessed to be high-risk for corruption. This process involves identifying high-risk parties, gathering additional information on those parties, and consulting with the law department.

Training
Political and regulatory landscapes across the globe are constantly changing and require diligent anti-corruption training programs. In 2010, more than 33,000 employees whose positions may require interaction with government agencies or officials received anti-corruption training. This training covered the basics of the FCPA, global anticorruption standards, recent developments in enforcement, and compliance with internal anti-corruption guidelines and processes. Additionally, we monitor events and political changes and alert employees as appropriate. Every four years, all employees attend mandatory Business Practices Reviews that address anti-corruption issues.

Reporting and Investigating Suspected Violations
All employees are responsible for reporting any and all suspected violations of company policies. The Corporation provides several confidential mechanisms for reporting, including a 24-hour hotline phone number and mailing address. It is a violation of the Corporation’s procedures for an employee to be penalized or threatened in any way after filing a report. 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. All reports of suspected violations of law, business practices, or internal control procedures are thoroughly investigated, and major issues or violations are reported to the Audit Committee. Appropriate disciplinary action is taken for all violations, and no exceptions are made based on level of employment.