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Natural Gas and Power Marketing

Reliable economic supplies of natural gas and power are fundamental to the world’s economic growth. ExxonMobil employs a worldwide team of commercial experts, with detailed knowledge of global energy markets, to maximize the value of the company’s gas, natural gas liquids, and power interests.

Over the coming decades, natural gas is expected to play an increasingly important role in fueling the world’s economic growth. ExxonMobil sells approximately 11 billion cubic feet of gas per day and is active across the gas value chain in most major markets. Our global presence, combined with our ability to leverage expertise across our Upstream, Downstream, and Chemical businesses enables us to create innovative integrated solutions. This provides an important competitive advantage and positions ExxonMobil strongly to help meet the world’s growing natural gas and power demands.

Power activities
ExxonMobil has interests in about 16,000 megawatts of power generation capacity worldwide. This includes a majority interest in the Castle Peak Power Company that generates electricity for consumers in Hong Kong and mainland China. In 2009, ExxonMobil and our partners awarded contracts for front-end engineering and design for a new 500-megawatt power plant in Nigeria. We are an industry leader in the application of cogeneration technology with interests in approximately 4900 megawatts of capacity. We continue to look for opportunities around the world to make use of cogeneration to efficiently supply the power and steam demands of our facilities.

Guidelines for reporting to natural gas index developers

Introduction
These Guidelines apply to employees of ExxonMobil Gas & Power Marketing Company, a division of Exxon Mobil Corporation ('Corporation') and affiliates (collectively 'Company'), who make purchases and sales of natural gas and who report such purchases and sales to index developers in the United States.

These Guidelines are in compliance with Section 284.403 of the Federal Energy Regulatory Commission's ('Commission') regulations and Order No. 644, 105 FERC 61, 217 (2003); and in conformance with the Commission's July 24, 2003, Policy Statement on Natural Gas and Electric Price Indices, Price Discovery in Natural Gas and Electric Markets, 104 FERC 61,121 (2003) as clarified in the December 12, 2003, Order on Clarification of Policy Statement on Natural Gas and Electricity Price Indices, Price Discovery in Natural Gas and Electric Markets, 105 FERC 61,282 (2003) ('Policy Statement').

As is stated in the Ethics Policy of the Corporation, the policy of the Corporation is to comply with all governmental laws, rules, and regulations applicable to its business. It is the policy of the Corporation that all transactions will be accurately reflected in its books and records. Falsification of books and records is strictly prohibited. Employees are expected to record all transactions accurately in the Corporation's books and records, and to be honest and forthcoming with the Corporation's auditors. Also, as is stated in the Antitrust Policy of the Corporation, employees are expected to comply with the antitrust and competition laws of the United States and with those of any other country that are applicable to the Corporation's business.

Base Requirements and Prohibitions
The following requirements and prohibitions apply to Company employees who make natural gas sales or purchases in the United States or report such transactions to developers of natural gas indices in the United States:

  • Company employees making natural gas sales and purchases should not engage in actions or transactions that are without a legitimate business purpose or use or employ manipulative or deceptive devices or contrivances in connection with the purchase or sale of natural gas.
  • Company employees reporting natural gas transactions to developers of natural gas indices should provide accurate and factual information, and they should not knowingly submit false or misleading information to any such developer or omit material information.
  • Company employees reporting natural gas transactions to developers of natural gas indices should do so in a manner consistent with the procedures set forth in the Commission's Policy Statement, as the Commission may clarify it from time to time.
  • Company employees with questions about the Commission's Policy Statement should consult the Law Department of the Corporation.

Reporting Procedures
The following procedures apply to Company employees reporting natural gas transaction data to developers of natural gas indices:

  • The Company should enter into appropriate confidentiality agreements with index developers and employees should comply with those agreements.
  • Employees reporting transactions should be independent from and not responsible for the sale and purchase of natural gas.
  • Employees reporting transactions should verify the accuracy and completeness of data before submitting it.
  • Employees should report each bilateral, arms-length qualifying transaction (as defined by the index developer) between non-affiliated companies in the physical (cash) markets at all trading locations in a timely manner. Physical (cash) market reporting should not include financial hedges, financial transactions, or swaps or exchanges of natural gas. Data should be provided for each transaction separately. For each transaction, the following information should be provided: (1) price; (2) volume; (3) buy/sell indicator; (4) delivery/receipt location; (5) transaction date; and (6) term (next day or next month).
  • Any reporting errors identified by employees should be corrected as soon as practicable, even if the index developer will not be able to incorporate such corrections in its indices. Employees should cooperate with the error resolution process adopted by each index developer, including adhering to the process and timeline for submitting corrections and for responding to inquiries from the index developer. Like the original data submission, this function should be carried out by employees who are independent from and not responsible for the sale and purchase of natural gas. The Company should consider process changes recommended by index developers to improve the accuracy and timeliness of data reporting.

Record Retention
Employees should retain all transaction data reported pursuant to Subsection III D for a period of five years from the dates of the reports.

Annual Audits
The Company should arrange for an auditor to review the Company's data gathering and submission process at least once per year. That auditor may be a member of the Corporation's Internal Audit staff and should be independent from the Company's trading and reporting departments and personnel. The Company should make results of the audits available upon request to any index developer to which the Company submitted transaction trade data during the audit period(s). The Company should keep audit reports for a period of five years.

Failure to Follow Guidelines
Failure to follow these Guidelines may result in disciplinary action, up to and including separation.

Availability of Guidelines
The Company should post these Guidelines on the Company's internet site.

Additionally, the Company should make these Guidelines available in hard copy free of charge on reasonable request.