Good governance is essential to ensuring the long-term viability of our business, promoting economic development of the communities where we operate and responsibly providing the energy needed to power the world’s progress. ExxonMobil employs a variety of policies and processes to uphold good corporate governance, avoid corruption and promote transparency underpinned by an independent board of directors that provides oversight on our corporation’s affairs. For ExxonMobil, upholding the highest ethical standards of business conduct is critical to maintaining our global license to operate. A commitment to ethics and integrity is a core value of our corporate culture. All employees, officers, directors and those working on our behalf are required to comply with all applicable laws, including U.S. anti-corruption, anti-trust, anti-boycott, trade sanctions and export controls laws, as well as laws of other countries applicable to our business.
Standards of Business Conduct
Our Standards of Business Conduct, adopted and administered by the board of directors, ensure we operate at the highest level of operational integrity by setting the ethical conduct expectations of our corporation and majority-owned subsidiaries. These Standards cover a range of topics including 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.
To establish a consistent understanding of our ethical standards of business integrity, all ExxonMobil employees receive training on our Standards of Business Conduct every four years, including a detailed review of the company’s ethics, anti-trust, anti-corruption and gifts and entertainment policies.
Employees are required to read the Standards annually and confirm compliance. In addition to these business practice reviews, regular training is provided on anti-boycott, trade sanctions and export controls for employees with relevant job functions. No one has authority to make exceptions or grant waivers to the Standards. Employees are subject to disciplinary action, up to and including termination, for violations of our policies.
We conduct regular internal audits and self-assessments to help ensure the rigorous implementation of our control systems and the Standards of Business Conduct. ExxonMobil’s internal team of more than 200 auditors annually reviews approximately one-third of the corporation’s operations, including detailed assessments of facilities, business units, personnel and records. We thoroughly investigate any suspected acts of noncompliance with the Standards across all functions of the company.
Systems and practices for reporting violations
ExxonMobil encourages employees and contractors to ask questions, voice concerns and report any suspected violations of company policies. In addition to our open-door communication procedures, ExxonMobil has 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 process, subject to legal requirements; retaliation against any employee is strictly prohibited.
As part of our commitment to reinforcing ethics and high standards of business conduct, a hotline steering committee comprising personnel from security, internal audit, law and human resources reviews reports of suspected violations. The board audit committee receives a quarterly report that summarizes the steering committee’s findings, including any violations or major issues. Confirmed violations lead to disciplinary actions, up to and including dismissal.
We seek to maintain the highest anti-corruption compliance in all aspects of our operations. Our Anti-Corruption Legal Compliance Guide outlines ExxonMobil’s commitment to comply with the U.S. Foreign Corrupt Practices Act (FCPA), the United Kingdom Bribery Act and global anti-corruption standards in our business relationships. The Guide also describes elements of the corporation’s anti-corruption compliance program. To ensure continued relevance and accuracy, ExxonMobil reviews the Guide annually and provides updates as needed.
ExxonMobil employees and contractors acting on our behalf are prohibited from making payments to or engaging in transactions with government officials that improperly influence the performance of their official duties. Our standard language for procurement contracts includes requirements to keep accurate books and records, and, where appropriate, contains specific anti-bribery commitments.
Because we operate in parts of the world with changing political and regulatory climates, we believe it is imperative to train our employees on our anti-trust and anti-corruption policies. ExxonMobil’s law department conducts comprehensive annual training sessions for employees on anti-trust and anti-corruption compliance. In 2015, approximately 19,000 employees participated in anti-corruption training. Employees in relevant job functions receive in-person training soon after entering their positions and every year thereafter. Other managers and professional employees receive training every two years. We monitor legal and regulatory developments and advise employees as appropriate. To ensure continuous improvement, we evaluate the effectiveness of our compliance program regularly.