2024 year end supplier communications

Thank you for being a valued supplier of Exxon Mobil Corporationⁱ.

We regularly undertake a thorough review of our business practices and those of our affiliates. As part of the review process, we believe it is important to communicate to our goods and services suppliers our expectations for the proper conduct of business activities with, or on behalf of, ExxonMobil. As guided by our long-standing Ethics Policy and other policies in our Standards of Business Conduct, our goal is to ensure we conduct our business in accordance with the highest standards. In turn, we expect our suppliers are committed to similar standards. Our standards cover safety, contract awards, personal business behavior, compliance with all applicable laws, adequate internal controls and the proper recording and reporting of all transactions.

Supplier expectations

As stated in the ExxonMobil Supplier Expectations, it is expected that ExxonMobil and our suppliers will comply with all applicable laws, and all financial settlements, reports and invoicing will correctly reflect the business transactions between us. Specifically, we expect:

• Compliance with the anti-corruption, antitrust, and trade laws of the United States and every other country in which operations are conducted.
• No one at ExxonMobil is authorized to ask your organization to take any action on our behalf that is contrary to applicable law or ExxonMobil policies, including our Anti-Corruption, Antitrust, and International Operations Policies.
• No ExxonMobil employee or supplier is authorized to make an improper payment, including facilitating payments to any employee, official, agent, or instrumentality of any government, commercial entity, or individual in the conduct of ExxonMobil activity or business.

Gifts and entertainment policy

Another key standard is our policy on the giving and receiving of gifts and entertainment. Those parties conducting business with, or on behalf of, ExxonMobil are expected to exercise good judgment in each case. The provision of gifts and entertainment must not be intended to create an improper advantage.

• Our employees are restricted from receiving gifts or favors that exceed a nominal value or receiving any extravagant or frequent entertainment from individuals, companies or firms who do business, or seek to do business with us.
• Likewise, while we do not envision any gifts would be made to third parties, you should be equally prudent on the rare occasion you might provide appropriate gifts or entertainment to third parties when conducting business on behalf of ExxonMobil.
• If you have not already done so, please ensure you adopt adequate safeguards, and you have policies, procedures and/or controls in place to ensure your activities related to commercial interactions and interactions with government officials fully comply with applicable anti-corruption laws and the expectations of ExxonMobil outlined above.

Respecting human rights

ExxonMobil is committed to respecting human rights, and we expect the same of our suppliers. Our Supplier Expectations with regards to human rights include conducting operations and business practices, as well as managing activities, in a manner consistent with the following key international human rights frameworks:

• the International Labour Organization’s 1998 Declaration on Fundamental Principles and Rights at Work, covering elimination of child labor, forced labor, workplace discrimination, recognition of freedom of association, and a safe and healthy work environment; and
• the United Nations Guiding Principles on Business and Human Rights (UNGPs) in effect as of 2011.

Productive work environment

ExxonMobil is committed to a safe, healthy and productive work environment for our employees, contractor employees and others who access ExxonMobil property, sites and facilities. Our expectation is that you have and enforce an alcohol and drug program that, at a minimum, meets the requirements set forth in the agreement¹. Elements of an acceptable contractor’s program should include, but are not limited to the:

1. Prohibition, while on company premises (including off-duty time) of contractor personnel use, possession, sale, manufacture, distribution, concealment or transport of any prohibited substance, which would include alcohol and potentially impairing medications used without a prescription or in a manner inconsistent with the prescription or directions for usage (e.g., some prescription drugs or over-the-counter medications or herbal medicines).
2. Prohibition of any (1) drug or alcohol-related paraphernalia used or designed for use in testing, packaging, storing, injecting, ingesting, inhaling or otherwise introducing into the human body any prohibited substance, (2) paraphernalia or substance used or designed for use to dilute, substitute or adulterate any alcohol or drug test specimen or to otherwise obstruct the alcohol or drug testing process.
3. Removal of contractor personnel from company activities following non-compliance with any aspect of the contractor program or the requirements set forth in the alcohol and drug exhibit in the agreement.
4. Commitment to comply with all applicable drug and alcohol-related laws and regulations.

Concerning the alcohol and drug test panel (including screening and confirmation cutoff levels) – if any - specified by the Alcohol and Drug Exhibit of your agreement with ExxonMobil, the following must be complied with:

A. For agreements containing the Alcohol and Drug Exhibit requiring that alcohol and drug testing, at a minimum, be compliant with the U.S. DOT panel, you may elect to use 1) a panel that meets the U.S. DOT drug panel, 2) a panel that exceeds the U.S. DOT drug panel or 3) the ExxonMobil drug panel, except to the extent any of these panels is preempted by local law.

B. For agreements containing the Alcohol and Drug Exhibit requiring that alcohol and drug testing, at a minimum, be compliant with the ExxonMobil panel, you may elect to use 1) the ExxonMobil panel or 2) a panel that exceeds the ExxonMobil panel (including screening and confirmation levels), except to the extent either of these panels is preempted by local law.

This information is offered only to clarify the relevant language in your existing agreement(s) and does not create any additional contractual obligation. Capitalized terms should be understood as those terms are defined in the relevant A&D Exhibit.

Providing goods and services

While you may be organized outside of the United States, it is imperative that, in providing goods and services to ExxonMobil affiliates worldwide, you not deal with any entities, organizations, persons or vessels with which a U.S. person could not deal and that you not provide to ExxonMobil any goods or services in which a U.S. person could not deal, for example goods manufactured or extracted in a country subject to comprehensive U.S. sanctions.

The countries and territories currently under comprehensive U.S. sanctions are Cuba, Iran, North Korea, Syria and the non-government controlled regions of Ukraine. The United States also imposes comprehensive sanctions against persons, entities and vessels on the U.S. Treasury Department Office of Foreign Assets Control’s List of Specially Designated Nationals and Blocked Persons (“SDN”), including any entities or vessels owned directly or indirectly, individually or in the aggregate, 50% or more by one or more SDNs, and it imposes more limited sanctions against Russia and Venezuela. We fully expect you to comply with any applicable sanctions and export controls, including relevant EU, UK or other applicable sanctions and export controls and, in providing goods or services to ExxonMobil affiliates worldwide, we expect that you not deal with any sanctioned party or provide to ExxonMobil any goods or services with which a U.S. person cannot deal. Should you have any questions about which entities, organizations, persons or vessels are sanctioned, please consult with an attorney experienced in such matters.

Data protection

ExxonMobil expends considerable resources protecting our data, including defending our computer network from the increased risk of sophisticated cyber-attacks and stewarding personal information according to regulatory requirements.

This communication reinforces our expectation that you take appropriate steps to protect information (electronic and hardcopy) and information systems in your control from new and evolving risks of cyber attackers. You should maintain appropriate data protection and cybersecurity measures based on professional guidance and best practices.

If there are circumstances where you suspect information related to ExxonMobil is compromised, you should promptly bring such circumstances to our attention. Please contact us if you have any suspicions as to whether an email purportedly from ExxonMobil is actually from our company. Also, we request that you regularly train your personnel on cybersecurity, including training to be alert to cybersecurity attacks that rely on personal inattention, such as “phishing” attacks or other suspicious emails containing attachments or links that could potentially compromise computer systems.

More and more countries around the world are adopting data protection or data privacy laws, which regulate the collection and processing of information, including personal information. These laws deal not only with how such information is collected and stored, but also the purpose(s) for which it is used. In addition, in many countries, there are also particular restrictions on how personal information is transferred across national borders and to third parties.

ExxonMobil is committed to protecting the personal information of our employees, contractors, vendors, customers and other third parties with whom we deal. If you have not already done so, please ensure you adopt adequate safeguards to keep all personal data used pursuant to your agreement with us secure, and that you have controls and tools in place to ensure compliance with applicable data privacy laws.

We also ask you to be alert to the potential for Illegal Information Brokering, where persons approach suppliers offering confidential information that is used to obtain business through corruption of the competitive bidding process. Such practice is illegal, and we ask that you report the occurrence of any such incident.

It is your responsibility to communicate the expectations of the above paragraphs to all subcontractors that work for you on ExxonMobil projects or sites.

Financial data

Finally, we expect that all financial data shall be complete and accurately recorded, and all invoices to ExxonMobil accurately reflect pricing, payment terms and other provisions as stated in your contract with us. We are committed that contracts and other awards are made in a fair manner. We encourage you to contact us if you are aware of any practices that fail to meet these standards or if you have any concerns in this regard.

For best awareness and understanding of our business standards, we expect you to bring this communication to the attention of those within your organization who have business contact with us or our affiliates.

Should you at any time have any questions or concerns as to the application of these business standards, please let us know by contacting our Controls Advisor for the applicable region*.

*Alternatively, you may call the ExxonMobil corporate “hot line” at either 1.800.963.9966 (inside the United States) or 1.346.335.6100 (call collect outside the United States).

Language translations / country-specific

ⁱ Corporate Separateness Notice

Exxon Mobil Corporation has numerous affiliates, many with names that include ExxonMobil, Exxon, Esso and Mobil. For convenience and simplicity in this communication, the short term “ExxonMobil” is used in this communication to refer to groups of companies or to specific subsidiaries of Exxon Mobil Corporation. For all of these, word selection may have been based on convenience and simplicity, and may not identify reporting relationships, legal entities, or relationships among legal entities. Nothing in this material is intended to override the corporate separateness of local entities. Working relationships discussed in this communication do not necessarily represent a reporting connection, but may reflect a functional guidance, stewardship, or service relationship.

¹ For Denbury Onshore, LLC, Pioneer Natural Resources USA, Inc., or Pioneer Water Management LLC vendors, who have not signed the new Master Services Agreement with ExxonMobil Global Services Company, please refer to the drug and alcohol requirements in your existing, applicable agreements.