Business Conduct and Ethics Code

Business Conduct and Ethics Code 4
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Dr.KiaraSimpson,United States,Researcher
Published Date:05-07-2017
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Business Conduct and Ethics CodeValues Our Company’s foundation is built on our values, which distinguish us and guide our actions. We conduct our business in a socially responsible and ethical manner. We respect The the law, support universal human rights, protect the environment and benefit the communities where we work. Chevron Integrity Partnership Way We are honest with others and ourselves. We We have an unwavering commitment to being meet the highest ethical standards in all business a good partner focused on building productive, Getting Results the Right Way dealings. We do what we say we will do. We accept collaborative, trusting and beneficial relationships The Chevron Way explains who we are, responsibility and hold ourselves accountable for our with governments, other companies, our customers, what we do, what we believe and what work and our actions. our communities and each other. we plan to accomplish. It establishes a common understanding Trust Protecting People and the Environment not only for those of us who work here We trust, respect and support each other, and we strive We place the highest priority on the health and safety but for all who interact with us. to earn the trust of our colleagues and partners. of our workforce and protection of our assets and the environment. We aim to be admired for world-class performance through disciplined application of our Diversity Operational Excellence Management System. We learn from and respect the cultures in which we work. We value and demonstrate respect for the High Performance uniqueness of individuals and the varied perspectives We are committed to excellence in everything we and talents they provide. We have an inclusive work do, and we strive to continually improve. We are environment and actively embrace a diversity of passionate about achieving results that exceed people, ideas, talents and experiences. expectations — our own and those of others. We drive for results with energy and a sense of urgency. Ingenuity We seek new opportunities and out-of-the-ordinary solutions. We use our creativity to find unexpected and practical ways to solve problems. Our experience, technology and perseverance enable us to overcome challenges and deliver value. 2 Chevron Business Conduct and Ethics CodeAbout the Business Conduct and Ethics Code The Code helps us understand how Chevron’s values are put into practice every day. Chevron’s Business Conduct and Ethics Code is built Using the Code on our core values and highlights the principles that • Read through the entire Code. guide our business conduct. It provides questions and • Think about how the Code applies to your job, and consider how you might handle situations to avoid answers for situations that you might encounter on the improper, illegal or unethical actions. job and lists resources for help or further information. • Use the questions and answers to help clarify situations that you may encounter. However, the Code cannot address every possible • If you have questions, ask your supervisor or manager or contact one of the resources listed in this Code. workplace situation or list all of Chevron’s corporate policies and procedures. Use it for guidance about Ethical Decision Making our ethical standards and where to take your questions or concerns. Ethical decision making is essential to the success of our Company. Some decisions are obvious and easy to make; others are not. When faced with a difficult situation, asking ourselves the questions below can help us to When each of us follows the Code, we communicate make the right ethical decisions. our commitment to the values that have made Chevron admired both as a business partner and Four “yes” answers are required to qualify an action as ethical and in step with Chevron’s values. as a valued citizen of the global community. It 1. Is it legal? is important to note, however, that violations of If you think an action may be illegal, do not proceed. If you need information about which laws apply in a the Code, or the policies referred to in the Code, given situation, talk with your supervisor, manager or Chevron’s Law department. could result in discipline, including termination of employment or criminal prosecution or both. 2. Is it consistent with Company policy, including our Human Rights Policy? If the proposed action does not comply with Company policy, you should not do it. 3. Is it consistent with The Chevron Way? Consider whether the action would be consistent with our Company’s core values. 4. If it were made public, would I be comfortable? Ask yourself if you would make the same decision if you knew that it would be reported on the front page of tomorrow’s newspaper. 3 Chevron Business Conduct and Ethics CodeOur Role and Responsibility Each of us has a responsibility to speak up. The Board Audit Committee, supported by the All of us must obey the letter and the Authority Corporate Compliance Policy Committee, made up spirit of the law at all times, wherever we In addition to knowing and understanding this Code, of senior executives in the Company, governs our each of us must understand the level of authority companywide compliance program. Each reporting live or work. Each of the countries where included in our job. We must all be careful to act unit has its own compliance or audit committee our Company does business has its own within the limits of that authority. to manage the responsibilities specific to that organization. This is also often the case for business laws, regulations and customs. Sometimes Guidance units within the reporting units. there can be significant differences from No code or manual can provide complete answers to Reporting Possible Violations one place to another and between regions all questions. In the end, we must rely on our good sense of what our Company’s high standards require. Each of us must speak up promptly if there is any within a single country. However, no matter This includes knowing when to seek guidance on the reason to suspect that anyone in Chevron or its where we work, we are all responsible for proper course of action. We should expect timely and affiliates has violated Company policies or local laws. specific guidance from our supervisors, managers, the We must also report any activity that could damage respecting all applicable laws and following Chevron Law department, the Corporate Compliance the Company’s reputation. One resource available the policies in our Code. group or our local compliance coordinators. to each of us is the Chevron Hotline. You can call or submit a report to the Hotline, which operates Some of us have jobs that require more detailed 24 hours a day, seven days a week. knowledge of particular compliance topics than this Code provides. In this case, our managers Non-Retaliation Policy or supervisors will direct us to the appropriate information in the Corporate Policies and the Chevron does not tolerate any form of retaliation for Manual of Compliance Procedures and Guidelines. reports made in good faith. This includes blatant actions, such as firing, transferring, demoting or publicly Compliance attacking someone, as well as more subtle retaliation, such as avoiding someone, leaving him or her out of Each of us must comply with this Code and with all professional or social activities and so on. It includes Company policies. If we fail to do so, we may face actions taken by managers and employees alike. disciplinary action, possibly including termination. Likewise, any supervisor, manager, officer or director who is aware of any violation and does not promptly report and correct it may be subject to similar consequences. 4 Chevron Business Conduct and Ethics CodeQuestions & Answers The Chevron Hotline is an option for people who Chevron Hotline for some reason are not comfortable discussing the Report any suspected violation of the law or Company QI observed a situation that I suspect is a policies. There are no negative consequences to matter with their supervisor, local management or violation of our guidelines. Should I report this raising concerns in good faith using the Hotline, and Human Resources representative. situation even if I am not completely certain that the Company assures employees that no retaliation will take place. there is a problem? Additional Resources A All employees are responsible for immediately The Chevron Way reporting possible violations to their supervisors The Chevron Way explains who we are, what we do, what we believe and what we plan to accomplish. It or another Company resource. While reporting to establishes a common understanding not only for your supervisor is usually best, you may also call the those of us who work here but for all who interact Chevron Hotline. Your report will be taken seriously with us. and investigated as appropriate. It is better to report a Manual of Compliance Procedures and Guidelines suspicion that turns out not to be an issue than to ignore Consult the Corporate Manual of Compliance a possible violation of the law or Company policy. Procedures and Guidelines (MCP&G) for more information about applicable laws, Company policies, and compliance procedures relating to all subject matter areas covered in the Business Conduct and QIf I see a questionable situation, is it better Ethics Code. for me to call the Chevron Hotline or to talk to my supervisor? Request Guidance or Voice Concerns For Additional Guidance Contact your supervisor, your manager, Corporate Corporate Policies Compliance or the Compliance liaison or coordinator A You do not have to call the Chevron Hotline for your reporting unit. 1. The Chevron Way if there is a way to resolve the situation through a 2. Manual of Compliance Procedures discussion with your supervisor, local management or and Guidelines your local Human Resources representative. 5 Chevron Business Conduct and Ethics CodeOur Employees We value the uniqueness of individuals and the various perspectives and talents they provide. We are our Company’s most valuable resource We Respect Diversity We Provide Equal Opportunity and are essential to its success. In the course of Diversity is also a fundamental value at Chevron. As Our policy against discrimination aligns with our our daily work, we use our creativity, experience, stated in The Chevron Way, this means that “we learn position on diversity. The Company follows the laws technology and perseverance to find innovative and from and respect the cultures in which we work.” that prohibit discrimination in employment practices, practical solutions to all challenges that arise. Our We also value “the uniqueness of individuals and the wherever we do business. It is Chevron’s policy to values of Ingenuity and High Performance would be varied perspectives and talents they provide.” We provide equal employment opportunities and to treat meaningless if Chevron did not have the highest- promote diversity within our workforce and have an applicants and employees without illegal bias. It is our quality workforce possible and continually work to inclusive environment that helps each of us to fully policy that no one at Chevron should ever be subject develop its employees. participate and contribute to Chevron’s success. to discrimination on the basis of: • Race • Religion • Color • National origin • Age • Sex • Gender identity • Gender expression • Genetic information • Disability • Veteran status • Political preference • Sexual orientation • Membership or nonmembership in any lawful organization • Or other basis prohibited by local laws or regulations In the United States, discrimination is prohibited in hiring, rate of pay, promotion, demotion, transfer, layoff or termination. Many other countries have similar anti-discrimination laws. 6 Chevron Business Conduct and Ethics CodeEmployee Compensation and Tenure Alcohol Preventing Workplace Violence and Harassment Our Company has a “pay-for-performance” The use, possession, distribution, purchase or sale of philosophy. We administer wages, salaries and alcohol by any person while on Company premises The Company prohibits actual or threatened violence benefits to maintain our competitive position in or while operating Company equipment is prohibited against co-workers, visitors or anyone else who is the marketplace. It allows us to attract and retain unless prior permission has been obtained from either on our premises or has contact with employees top-notch personnel, provide incentives and reward appropriate Company management. In certain in the course of their duties. Every threat of violence is excellence. This approach to compensation supports circumstances, such as official Company events, use serious. We must report any such event immediately. our value of High Performance. of alcohol may be authorized as long as permission is received in advance from appropriate operating Threats of immediate concern should be referred Chevron does not guarantee employment in a company or corporate department management. Any to Global Security or your local police department specific job or for any particular period of time to person under the influence of alcohol is prohibited or both. any employee. from entering Company premises, engaging in Chevron is also committed to a workplace free of Company business or operating Company equipment. Controlled Substances and Drugs harassment. If you are confronted with harassment, you Any use of alcohol or any other substance that causes should report your concern to your supervisor, local The Company prohibits the use, possession, or contributes to unacceptable job performance or management, Human Resources representative or distribution, purchase or sale of controlled substances unusual job behavior is also prohibited. Chevron’s Hotline. on its premises while conducting business for the Company or while operating Company equipment. Where allowed by law, the Company may conduct Controlled substances include: searches and test for drug and alcohol use. • Illegal drugs and narcotics In many locations worldwide, the Company makes • Prescription drugs obtained or used without resources available to assist employees with drug or a legal prescription alcohol problems. For information about Employee • Other unlawful substances or materials Assistance and WorkLife Services, consult the Human Resources website or contact your supervisor or local Human Resources representative. 7 Chevron Business Conduct and Ethics CodeQuestions & Answers QI posted for a job in a different department whose staff consists of five males. The manager made a job offer to a male. (I am a female.) I feel I may have been discriminated against. What can I do? QI am a supervisor who has only one minority employee. Unfortunately this employee is having performance problems. I am afraid to give a negative review for fear of being accused of discrimination. What should I do? A If you believe you are being discriminated against, report this to your supervisor, a Human A Provide consistent feedback to all members of your group. Be fair in your evaluation, and document your Resources representative or the Chevron Hotline. proof with facts and examples. If you are accused of discrimination and have followed Company policies, the Company will support you. If you need help, consult with your local Human Resources representative. QYesterday I had an argument with a co-worker For Additional Guidance that almost escalated into a physical confrontation Corporate Policies when he challenged me to meet him outside. I believe 200: Employment 226: Discipline 263: Drugs/Controlled Substances he may try to harm me at some point. What can I do? 202: Harassment 230: Total Remuneration 264: Alcohol 210: Termination 256: Labor Relations 570: Security of Personnel and Assets A Report this incident to your supervisor or your local Human Resources representative. Threats of immediate concern should be referred to Global Additional Resources Security or your local police department or both. Employee Assistance and WorkLife Services can help resolve personal, family and work-related concerns or problems, including help with drug or alcohol problems. 8 Chevron Business Conduct and Ethics CodeHuman Rights Chevron’s support for universal human rights is a core value in The Chevron Way. Chevron’s Human Rights Policy reaffirms Our Commitment Your Responsibility our longstanding support for universal All employees are required to comply with Human Chevron’s Human Rights Policy 520 states that Rights Policy 520. This expectation includes the “We conduct our global operations consistent with human rights. We condemn human rights following actions: the spirit and intent of the United Nations Universal abuses. This commitment is encompassed Declaration of Human Rights.” • Conducting yourself according to the values in The Chevron Way and according to the in The Chevron Way vision and values This means that our policies and practices address commitments outlined in Human Rights Policy 520 and other corporate policies that ensure four areas: • Understanding and obeying local laws and we operate safely and responsibly and • Employees: We treat our employees with dignity acting consistently with Chevron’s policies and and respect and promote diversity in the workplace. procedures in compliance with applicable laws and • Reading and acknowledging this Business Conduct • Security: We protect personnel and assets in a regulations. Chevron’s position on human and Ethics Code manner consistent with Chevron’s participation in rights is clearly laid out in our Human the Voluntary Principles on Security and Human • Reporting noncompliance with Human Rights Rights, a global initiative that provides guidance on Policy 520 Rights Policy. companies’ engagement with security forces. • Communities: We engage with communities What Are Human Rights? to build upon our understanding of potential Human rights are generally defined as basic human rights issues in order to enhance the standards of treatment to which all people are benefits of our projects and operations and entitled, regardless of nationality, gender, race, manage potential impacts. economic status or religion. • Suppliers: We encourage our suppliers to treat Although governments have the primary duty to protect their employees, and to interact with communities, and ensure fulfillment of human rights, Chevron in a manner that respects human rights. recognizes that companies have a responsibility to respect human rights and can also play a positive role in the communities where they operate. For Additional Guidance Please read Human Rights Policy 520 or contact the Policy, Government and Public Affairs (PGPA) department in your reporting unit or business unit. 9 Chevron Business Conduct and Ethics CodeCompany Records and Internal Controls Fair and accurate books and records are essential for managing Chevron’s business. Fair and accurate books and records are essential for Our Shared Responsibility Audits managing Chevron’s business and maintaining the Chevron’s books and records must be prepared Audits performed by our internal and external accuracy and integrity of the Company’s financial accurately and honestly, both by our accountants auditors help ensure compliance with established reporting and disclosure. This is true for both who prepare records of transactions and by any of us policies, procedures and controls. Audits also reports filed with the U.S. Securities and Exchange who contribute to the creation of business records, help identify potential weaknesses so they may Commission and for other public communications. Our for example, by submitting expense reports, job logs, be remediated promptly. All of us are required to commitment to the value of Integrity is fundamental measurements and time sheets. All of our books and cooperate fully with internal and external audits. This to the accuracy of financial reports the Company records must be supported by enough documentation means always providing clear and truthful information makes to the public. to provide a complete, accurate, valid and auditable and cooperating fully during the audit process. record of each transaction. Both Company policy and various laws, such as Fraud the Sarbanes-Oxley Act of 2002 (SOX), require the completeness and accuracy of our financial records. Engaging in any scheme to defraud anyone — Any attempt to conceal or misstate information in of money, property or honest services — violates Company records is a serious offense and may result Company policy and the law and carries severe in disciplinary action and criminal prosecution. Each penalties. Those consequences apply to any of us is responsible for reporting any suspected dishonest or fraudulent activities, including misusing violations of the Company’s accounting policies or stealing Company assets or falsifying a travel and procedures. You should report any suspected and entertainment expense report, among other violation of these policies to your manager or violations. The Company relies on its internal controls supervisor, the Corporate Audit department or the and the personal integrity of all its employees, Chevron Hotline. contractors and directors to protect Company assets against damage, theft and other unauthorized use. Internal Controls Reliable internal controls are critical for proper, complete and accurate accounting and financial reporting. Each of us must understand the internal controls relevant to our positions and follow the policies and procedures related to those controls. We are all encouraged to talk to our managers or supervisors immediately if we ever suspect that a control does not adequately detect or prevent inaccuracy, waste or fraud. 10 Chevron Business Conduct and Ethics CodeQuestions & Answers QI am not a manager. Can I be held legally responsible for failing to report Company information accurately? the integrity of the transaction, you should feel free For Additional Guidance to ask a higher level of management or your reporting Corporate Policies unit’s compliance coordinator or report your concern A Yes. Although top management must sign off 130: Internal Controls to Corporate Audit or the Chevron Hotline. on our Company’s financial reports, every employee 132: P ayment Authority records some transactions, and these all affect the 134: Auditing financial reports. Be sure every transaction you record 136: Availability of Records is accurate. QMy supervisor told me to destroy documents 190: Delegation of Authority related to a project that we did last year. Now, the 420: Preparation, Approval and Execution internal auditors are asking questions as though they of Documents are concerned. Since my supervisor told me to do this, QLast week, I entered a transaction for an 566: Information Retention I should not be in trouble, should I? associate. I had several questions about the way the deal was done. Even though my supervisor could not really answer the questions, she assured me that it A The auditor is not investigating to get anyone was all “trustworthy” and that I should just plug in the “in trouble.” The auditor’s role is to ensure that our numbers as requested. What should I have done? Company follows required policies and processes. You are responsible for understanding our document retention policies. If your supervisor told you to A It’s your responsibility to understand every destroy documents that should have been retained, transaction you enter because you may need to answer blindly following orders was not the right course of questions about its accuracy. You were correct to ask action. The best thing you can do now is to answer the your supervisor for advice. Even though she approved auditor’s questions completely and honestly. the transaction, if you still have questions related to 11 Chevron Business Conduct and Ethics CodeAvoiding Conflicts of Interest We expect each other to act in the best interests of the Company. At Chevron, we always expect one another to act in Any activity that has the appearance of a conflict of • Give a gift or entertainment to anyone for the the best interests of the Company. This means that interest — whether or not an actual conflict exists — purpose of improperly influencing him or her to business decisions should be made free from any must be avoided. If you think you may be in a take action in favor of Chevron. conflict of interest. They should also appear impartial. situation that could be perceived as a conflict, If we ever feel that it may be appropriate to accept We must make our decisions based on sound disclose the potential conflict to your supervisor or a gift of more than nominal value, we should seek business reasoning. manager immediately. Of course, if any of us sees a guidance from our supervisors. conflict of interest at Chevron, we must report it. Conflicts of interest may occur when an individual’s outside activities or personal interests conflict or Avoiding conflicts of interest in all of our business appear to conflict with his or her responsibilities to decisions is essential to our values of Integrity Chevron. An outside activity would be considered a and Trust. conflict of interest if it: Avoid Accepting or Giving Gifts, Fees, • Has a negative impact on our business interests. Favors or Other Advantages • Negatively affects Chevron’s reputation or relations with others. It is also a conflict of interest for a Chevron employee • Interferes with an individual’s judgment in or director to give or receive gifts or entertainment carrying out his or her job duties. of more than nominal value or cash in any amount to or from people or companies doing or seeking to do Employees and directors — and their close relatives – business with Chevron. Therefore, we must not: must never: • Accept fees or honoraria in exchange for services • Compete against the Company. provided on behalf of the Company. • Use their position or influence to secure an • Provide or accept gifts or entertainment from improper benefit for themselves or others. anyone doing or seeking business with Chevron • Use Company information, assets or resources or any of its affiliates. Generally, modest forms of for their personal gain or the improper benefit gifts and entertainment received from vendors are of others. acceptable and do not create conflicts of interest. Consult with your local compliance coordinator • Take advantage of inside information or their to learn about the guidelines established by position with the Company. your reporting unit for “nominal value” gifts and entertainment. 12 Chevron Business Conduct and Ethics CodeWe must never use material nonpublic information of any kind for personal gain. not complete a security transaction until the first Insider Trading Is Prohibited business day that is at least 24 hours after the time that It is illegal to purchase or sell Chevron securities if the information is publicly released. Some examples you have “material nonpublic information” concerning of nonpublic information that could be considered Chevron. Securities include common stock or other material include: debt or equity securities, options or shares held in • Financial forecasts Chevron investment and retirement plans. It is also • Changes in sales, market share or production illegal to purchase or sell the securities of another company if you have material nonpublic information • Changes in debt ratings or analyst upgrades or about that company. If you engage in insider downgrades of Chevron securities trading you will likely lose your job and be subject to • Earnings, dividends or stock splits significant civil and criminal penalties. • Proposed mergers, acquisitions or divestitures We must never use material nonpublic information • Marketing plans about Chevron or the companies doing business with • Strategic plans Chevron for personal gain. In addition, we must never • New product information give material nonpublic information to others who may • Changes in top management purchase or sell Chevron securities or the securities of other companies. If you provide a “tip” to someone Whether any particular information could be who then buys or sells securities, both of you can be considered “material” by a reasonable investor convicted of insider trading. depends on specific circumstances. A major factor in determining whether information is material “Nonpublic information” is information that is known is the impact that information could have on the within the Company and has not been publicly Company’s financial condition or stock price. If you released. “Material information” is information that are in doubt as to whether nonpublic information you a reasonable investor would consider important when have is material, you should seek guidance from your deciding to buy or sell securities. Employees who are supervisor or your local Chevron legal counsel. in possession of material nonpublic information may 13 Chevron Business Conduct and Ethics CodeQuestions & Answers For Additional Guidance QMy father owns a controlling interest in a QI recently learned that our Company will Corporate Policies company that has supplied materials to Chevron announce disappointing financial results for this 20: Insider Trading for many years. I was recently hired, and in my new quarter. Is this inside information? 282: Conflict of Interest position, I now have authority to contract with that same supplier. Am I faced with a potential conflict A Yes. This kind of financial news can have of interest? a negative effect on a company’s stock price and would certainly be considered material nonpublic A Even though the supplier is a longtime vendor information, or inside information. If you sell Chevron of our Company, an appearance of a conflict has securities on the basis of this information before it now been created because you are involved in the becomes public, you are engaging in insider trading. decision-making process regarding the selection of the supplier. In this case, the problem could be resolved if an independent decision maker, such as your manager, QI accidentally saw a copy of a confidential acts instead of you. The important action for you to memo describing a large contract that our Company take is to formally disclose the potential conflict to will soon sign with another company. If I buy some of the other company’s stock on the basis of this your supervisor or manager so that it may be resolved. information and before news of the contract is made public, am I engaging in insider trading? A Yes. Assuming that the news of this contract is material nonpublic information, or inside information, if you purchase securities of the other company on the basis of this information before it becomes public, you are engaging in insider trading. 14 Chevron Business Conduct and Ethics CodeAntibribery, International Trade and Antiboycott Laws Wherever Chevron operates, we respect and comply with the local laws and regulations. Wherever Chevron operates, we must respect and Chevron employees and contractors are prohibited commercial transactions. Due to the complexities conform to each country’s unique customs and from making payments or providing anything of value of these international trade laws, we must seek business practices. Above all, we must follow its to government officials with the intent to improperly guidance from Chevron’s legal counsel before laws and regulations. influence the performance of their official duties or exporting or importing goods or services or gain any other improper advantage. Chevron requires engaging in transactions that might be affected When business transactions involve more than one that internal controls be in place and functioning by trade sanctions. country, we must find the best way to comply with all and that accurate and complete transaction records applicable laws. Whenever a possible conflict of laws be kept within the Company. Our standard language Understanding Antiboycott Laws situation arises, we should always seek guidance from for procurement contracts includes a requirement Some countries have adopted laws prohibiting their our organization’s legal counsel. for our suppliers and contractors to comply with all people and businesses from participating in or applicable laws and keep accurate books and records. cooperating with international trade embargoes or Bribery Is Always Prohibited Where appropriate, our procurement contracts sanctions that have been imposed by other countries. contain specific antibribery commitments. Bribery of any government official in any country is For example, antiboycott laws in the United States strictly against Chevron policy, even if the refusal to penalize U.S. companies, like Chevron, if they or their Complying With International Trade Laws make such a payment would result in the Company subsidiaries or affiliates participate or cooperate losing a business opportunity. Laws that apply to Chevron operations outside the with international boycotts not supported by the United States include the local laws of countries where United States. U.S. antiboycott laws also require these Almost every country prohibits the bribery of its our operations occur as well as certain U.S. laws that companies to report any request to participate or own officials. In addition, many countries have govern international operations of U.S. companies and cooperate in such a boycott. Any employee receiving antibribery/anticorruption laws that make it illegal to U.S. persons. Many countries have laws that restrict a request of this sort should inform Chevron legal bribe officials of other countries. In the United States, or otherwise require licensing for the export or import counsel immediately. that law is the Foreign Corrupt Practices Act (FCPA). of certain goods and services to other countries and Employees with duties that involve transactions or to certain parties. Countries may also impose various travel outside of the United States must familiarize kinds of trade sanctions or embargoes against other themselves with this law. countries or persons. Management approval is required before any gift The scope of these trade sanctions or trade or payment can be made to a government or public embargoes may vary widely from country to country. official. In some cases, the gift or payment must They may range from specific prohibitions on trade in also be approved by your compliance coordinator a specific commodity to a total prohibition of all or Corporate Compliance. 15 Chevron Business Conduct and Ethics CodeQuestions & Answers QI recently met an agent who can assist our QA dinner is planned to celebrate a major Company in obtaining business in a country where it has accomplishment in a joint-venture project. Our been particularly difficult for us to become established partners include national oil companies (NOCs) and and obtain necessary government permits. May I other commercial partners. Management would engage this agent on behalf of our Company? like to present gifts to all participants. Under the anticorruption laws, the NOC partners are deemed government officials. May we invite them to the A Before you engage this agent, consult with your celebration? local Chevron Law department and local compliance coordinator to ensure that the agent is reputable and that its business methods are aligned with both local A Please consult your compliance coordinator. and U.S. laws. Due diligence on this agent’s reputation The event and the gifts are likely subject to pre-approval is critical because the Company could be legally liable by your local compliance, reporting unit compliance, or for acts of the agent or other third party. Corporate Compliance. Incurring reasonable costs for a celebratory event with a valid business purpose may not be prohibited under applicable anticorruption laws, including the FCPA. Presenting appropriate gifts may QA port official has told me that it will take weeks also be allowed. to deliver materials to a work site unless a payment is made to help him “expedite” our shipment. Should I comply with his request? For Additional Guidance Corporate Policy 324: Gifts to U.S. Public Officials A No. This payment likely violates local and other applicable antibribery laws. 16 Chevron Business Conduct and Ethics CodeGovernment Affairs and Political Involvement Chevron’s participation in the political arena is conducted in accordance with the highest ethical standards. In the course of doing business around the world, Providing Gifts to U.S. Public Officials Making Political Contributions Chevron interacts regularly with government officials. Under certain circumstances, Chevron may provide Political contributions by the corporation concerning How we conduct ourselves with governments and gifts to U.S. public officials. Such gifts must always be elections of any kind, whether monetary or in the political arena can affect our reputation, our in strict compliance with the law, Company policy and nonmonetary (such as allowing an employee to work operations around the world and our ability to work the values of The Chevron Way. on a campaign while on Company time) must be with government officials and other stakeholders. The planned, budgeted, legally reviewed and approved in Trust that we depend upon from both local and global We must seek guidance from Chevron’s Law advance by PGPA, internal and external legal counsel, communities and governments is essential to our department before committing to provide any gifts and in certain cases by the Vice President, Policy, business, and we must continually earn it. to U.S. public officials. These include elected and Government and Public Affairs. appointed U.S. officials at the local, state and federal Our activities must meet the highest ethical levels as well as government employees such as Engaging in Political Activities on Our Own standards and comply with both U.S. and local laws public safety officers and public university professors. and regulations. In all instances, it is imperative for Chevron encourages us to participate in the Laws regulating “gifts” typically define that term as employees to seek proper guidance and obtain the political and governmental process and, when anything of value, including meals, gift certificates, required approvals before engaging in government or permitted by a country’s laws and customs, to travel expenses, event tickets or honoraria. Any political activities. communicate our personal views to appointed payment made to a third party on behalf of a public and elected officials. However, we cannot identify official, such as a payment to a hotel for a hotel room Engaging in Lobbying Activities ourselves as representatives of Chevron or any of used by a public official, is considered a gift to the its affiliate companies. Lobbying is an activity aimed at influencing public public official. Certain gifts may be prohibited by law, policy decisions by providing information to elected or create reporting obligations, or create conflicts of Under no circumstances will the Company appointed officials and their staff. Lobbying activities interest. U.S. laws that regulate gifts to public officials reimburse any employee for making a personal include both direct communication with public apply even when the officials are outside the United political contribution. officials and providing support to any person who States. For example, U.S. federal law applies to the engages in such communication. gift of a meal given to a U.S. embassy employee Employees may not engage in personal political outside the United States. activities during paid working hours or when using Lobbying activities, in the United States and Company resources (such as email, phone and elsewhere, are strictly regulated. Prior to engaging Gifts to non-U.S. officials require advance approval meeting rooms) without receiving pre-approval since in lobbying activities, any employee or director must from your reporting unit’s compliance coordinator or such activities may be an illegal political contribution obtain guidance from his or her local PGPA manager. the Corporate Compliance office. by Chevron. Employees must seek guidance from their local PGPA manager. 17 Chevron Business Conduct and Ethics CodeQuestions & Answers QI attended a campaign fundraiser for a QA government official is coming to speak to our congressman, and I’m confident that the Company department about a public policy issue of interest to would like to see him re-elected. I wrote a personal our Company. I’d like to buy him lunch to thank him for check to the congressman’s campaign committee and his time. May I do this? included the amount in my expense report. Will the Company reimburse me for this expense? A A meal is considered a gift. For U.S. officials, you must seek guidance from the Political Law counsel A No. If the Company reimburses you for the (Corporation Law) or the senior analyst, Political contribution, the Company will be the source of Programs and Compliance (PGPA) prior to providing the contribution, which would violate U.S. law. In a gift. For non-U.S. officials, you must seek guidance addition, Company policy requires that all campaign from your local legal counsel, compliance coordinator, contributions in the United States must be planned or Corporate Compliance prior to providing a gift. and budgeted and have several specific legal and management approvals prior to making the Additional Resources QA co-worker uses Company email to solicit votes contribution. Outside the United States, political • Within the United States, consult the Political Law and financial support for his sister, who is running for contributions undergo an equally rigorous review and counsel (Corporation Law) or the senior analyst, a local political office. Is this acceptable? Political Programs and Compliance (PGPA). approval process. • Outside the United States, contact Chevron’s Policy, Government and Public Affairs personnel in For Additional Guidance A No. Company resources may not be used the host country. Also consult your local Chevron Corporate Policies for political purposes without first obtaining all legal counsel associated with your reporting unit 320: Government Affairs required approvals. or business unit. 322: Political Contributions 324: Gifts to U.S. Public Officials 18 Chevron Business Conduct and Ethics CodeOperational Excellence: Safety, Health, Environment, Reliability and Efficiency Protecting People and the Environment is a key value at Chevron. We place the highest priority on the health Chevron’s policy is to protect the safety and safety of our workforce and protection of our assets and the environment. We aim to be admired for world- and health of people and the quality of class performance through disciplined application of our Operational Excellence Management System. the environment and to conduct our All of us are responsible for complying with applicable Company policy and government laws and regulations and operations reliably and efficiently. for fully committing to ALWAYS meeting the requirements of the OEMS in our work activities. Chevron expects compliance with the letter and the spirit of applicable environmental, health and safety laws, regulations and policies, regardless of the degree of enforcement. The Operational Excellence Management System (OEMS) defines the expectations regarding the Each of us has the authority and responsibility to stop – or not start – any work activity if hazards or risks pose a systematic management of process safety, personal threat to safety or the environment. safety and health, environment, reliability and efficiency to achieve world-class performance in operational excellence. 19 Chevron Business Conduct and Ethics CodeQuestions & Answers QMy work site has a program to record, QMy supervisor asked me to perform a task that investigate and correct injury-producing accidents. I believe violates environmental regulations. What Part of the site’s annual incentive plan is based on its should I do? safety performance, and I know of injuries that are not being reported. What should I do? A Never guess about environmental regulations. If you are uncertain, check with your supervisor to be sure A It’s important to investigate injury-producing you have understood the request. If you still feel the accidents to determine steps necessary to prevent request violates environmental regulations, report the similar occurrences. You should always notify your concern to local management or the Chevron Hotline. supervisor when an accident occurs in the workplace. If a co-worker or supervisor is reluctant to report a work-related injury, encourage him or her to report QI have a work order that specifically outlines it. If the injury is not reported then contact local a task to be performed. As I began to do the task, I management or the Chevron Hotline. discovered that conditions are different from those expected when the job was planned. I have a feeling that continuing the job as outlined in the work order For Additional Guidance will be unsafe. What should I do? Corporate Policy 530: Operational Excellence A Employees have the responsibility and authority to stop or not begin work that they believe may be unsafe. You should communicate your concerns to your supervisor. Your supervisor has the responsibility to investigate, understand and resolve the issue. 20 Chevron Business Conduct and Ethics Code

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