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 law, support universal human rights, protect the environment and benefit the
communities where we work.
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
Operational Excellence Management System.
We learn from and respect the cultures in which we
work. We value and demonstrate respect for the
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.
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
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
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?
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
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
for me to call the Chevron Hotline or to talk to
Request Guidance or Voice Concerns
For Additional Guidance
Contact your supervisor, your manager, Corporate
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
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:
• National origin
• Gender identity
• Gender expression
• Genetic information
• 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
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.
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
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
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
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
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
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,
contractors and directors to protect Company assets
against damage, theft and other unauthorized use.
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
the integrity of the transaction, you should feel free
For Additional Guidance
to ask a higher level of management or your reporting
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
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
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:
• 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
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
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
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
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
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
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
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
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
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).
• 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
for political purposes without first obtaining all
legal counsel associated with your reporting unit
320: Government Affairs
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
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