ExxonMobil requires that employees, officers, directors and those working on our behalf comply with all applicable laws, including the U.S. anti-corruption, anti-trust, anti-boycott, trade sanctions and export controls laws, as well as laws in other countries applicable to our business.
Our corporate governance systems and practices are core strengths of ExxonMobil. We apply a rigorous approach to corporate governance in all aspects of the way we do business, everywhere we operate. Our Standards of Business Conduct, adopted and administered by the board of directors, sets the ethical conduct expectations for our corporation and majority-owned subsidiaries. Our Anti-Corruption Legal Compliance Guide outlines ExxonMobil’s commitment to comply with the U.S. Foreign Corrupt Practices Act, 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.
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.
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 “hotline” 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 termination.
Performance and initiatives
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 of Business Conduct across all functions of the company.
To establish a consistent understanding of our ethical standards, employees are required to confirm annually that they have read and are in compliance with the Standards. ExxonMobil employees receive training on our Standards of Business Conduct at least every four years. ExxonMobil’s law department conducts comprehensive annual training sessions for employees on anti-trust and anti-corruption compliance. Employees in relevant job functions receive in-person training on anti-trust, anti-corruption compliance, anti-boycott, trade sanctions and export controls soon after entering their positions and every year thereafter. In 2017, nearly 18,000 employees and contractors participated in anti-corruption training.