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Policy: Our Business Conduct and Ethics Code
Approach: Rigorous Processes for Operating Ethically
Policy: Our Business Conduct and Ethics Code
Integrity is one of ChevronTexaco's core values, and we are committed to meeting the highest ethical standards in all our business dealings.
ChevronTexaco's policy is to adhere to the letter and the spirit of the law. The ChevronTexaco Business Conduct and Ethics (BC&E) Code describes the company's policies for proper business conduct in a range of areas, such as conflicts of interest, public policy activities, gifts to officials, agreements with competitors, privacy of personal information, nondiscrimination, and U.S. export controls and trade sanctions. ChevronTexaco's Manual of Compliance Procedures and Guidelines provides greater detail on specific laws and policies related to many of the issues addressed in the BC&E Code.
Also included in our BC&E Code is ChevronTexaco's policy to comply fully with the letter and spirit of the U.S. Government's Foreign Corrupt Practices Act (FCPA). Payments to international officials or parties for the purpose of obtaining or retaining business is strictly against ChevronTexaco policy, even if the refusal to make them may cause the company to lose business. In instances where officials expect payment to expedite the proper performance of "routine governmental action" - a practice allowed under the FCPA - ChevronTexaco requires all such requests to be forwarded to our Corporate Comptroller for review and approval.
Approach: Rigorous Processes for Operating Ethically
We use a variety of processes and control systems, up to and including termination, to ensure compliance with our ethical policies and guidelines and accountability for violations.
ChevronTexaco Directors, employees and contractors are required to comply with the BC&E Code and the Manual of Compliance Procedures. All employees are required to read and be trained on the code. The Audit Committee of the Board of Directors helps the Board monitor the company's adherence to the BC&E Code. ChevronTexaco operating companies and corporate departments have their own Compliance/Audit Committees. These committees are responsible for overseeing compliance and ensuring that their respective organizations develop, implement and effectively operate processes to provide reasonable assurance of compliance with all applicable laws and regulations and company policies. Corporate Compliance Audits are conducted by an Internal Audit function to help ensure compliance processes are functioning properly.
Operating company and corporate department heads must send an annual "Representation Letter" to the corporation confirming that they have effective processes in place to ensure compliance with all applicable policies, laws and regulations. This letter covers areas ranging from conflicts of interest and the FCPA to health, environment and safety and human resources issues such as anti-harassment. If, during the year, Internal Audit has issued a "less than satisfactory" audit in any area, the representation letter must explain what corrective action is being taken. A representation also has to be made that processes are in place to identify and bring to management's attention any areas where company employees or directors are exposed to U.S. penalties or criminal liability in connection with nonoperated joint-venture operations.
If any employee or director has information that indicates another employee or agent, consultant or contractor is violating ChevronTexaco policies or any applicable laws, the BC&E Code requires him or her to report their concerns to management, legal counsel, the Corporate Auditing Department, Corporate Security or ChevronTexaco's global hotline. All calls to the hotline are confidential and can be made anonymously. ChevronTexaco also provides for direct communication of Hotline calls to the Audit Committee of the Board of Directors. It is ChevronTexaco's policy that no employee will be retaliated against for making a report of a suspected violation of the company's policies or law. Any subsequent corrective or disciplinary actions taken against individuals who violate the code are taken at the local level and not tracked on a corporatewide basis.
ChevronTexaco gives employees clear guidelines on appropriate ethical behavior and reinforces those guidelines. Yet policies, principles and guidelines - no matter how comprehensive - cannot always provide definitive answers to employees' questions about conduct. Ultimately, the company relies on its values and employees' good judgment, including a sense of when it's appropriate to seek guidance on the appropriate course of conduct.
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