Ethics

ExxonMobil expects employees to adhere to all company policies and to be responsible for reporting suspected violations of the law or corporate policy to management. Employees are required annually to confirm that they have read and are familiar with the policies set forth in our Standards of Business Conduct which include a Code of Ethics and Business Conduct to prevent bribery and corruption. It includes clear guidance on ethics, gifts and entertainment, conflicts of interest, antitrust, and directorship policies. Responsibilities for authorizing, approving, and recording financial transactions are appropriately segregated to reduce risks. All payments to third parties are expected to comply with the Foreign Corrupt Practices Act and our Guidelines for Payments to Third Parties.

We conduct an Annual Compliance Review at all our majority-owned or managed companies to promote clear understanding of, and compliance with, our Standards of Business Conduct. Every four years, we conduct Business Practices Reviews, which include various business practice scenarios to illustrate cases of policy violations and the actions that employees should have taken or avoided to prevent the violation. These scenarios include our policies against harassment and discrimination in the workplace.

Internal audits.
On average, our internal audit department conducts annual audits of one-third of corporate operating units and business activities (including preparation of the 2007 Corporate Citizenship Report). Approximately 250 specially trained internal auditors have unrestricted access to all facilities, business units, personnel, and records and are empowered to investigate all potential noncompliances with ExxonMobil’s Standards of Business Conduct.

Reporting and investigating suspected violations.
The Corporation provides a number of mechanisms to employees for reporting suspected violations, including a hotline phone number and mailing address. Correspondence is handled by a Hotline Steering Committee, comprised of security, audit, law, and human resources personnel, and reported to the Audit Committee on a quarterly basis. We expect persons responding to employee questions, concerns, complaints, and suggestions to use discretion to maintain confidentiality and protect anonymity to the greatest extent possible. No action can be taken or threatened against any employee for asking questions, voicing concerns, or making complaints in conformance with company procedures.

Suspected violations are identified through internal control procedures, supervisory reviews, hotline calls, and employee or third-party tips. A Hotline Steering Committee, comprising security, audit, law, and human resources personnel, handles suspected violations and provides a report to the Audit Committee on a quarterly basis.

Internal auditors and management investigate suspected violations of law, business practices, or internal control procedures. Violations by employees lead to disciplinary actions up to, and including, separation from the company. Significant matters are reported to the Audit Committee of the Board of Directors. The Board makes no exception for cases involving an executive officer or director.