Chevron Business Conduct Ethics Code
Chevron Business Conduct Ethics Code
Table of Contents
About the Business Conduct and Ethics Code......................................3 Antibribery, International Trade and Antiboycott Laws.................... 15
Using the Code......................................................................................................3 Bribery Is Always Prohibited........................................................................... 15
Ethical Decision Making......................................................................................3 Complying With International Trade Laws.................................................. 15
Understanding Antiboycott Laws.................................................................. 15
Our Role and Responsibility..................................................................... 4
Authority................................................................................................................ 4 Government Affairs and Political Involvement.................................... 17
Guidance................................................................................................................. 4 Engaging in Lobbying Activities..................................................................... 17
Compliance............................................................................................................ 4 Providing Gifts to U.S. Public Officials......................................................... 17
Reporting Possible Violations.......................................................................... 4 Making Political Contributions........................................................................ 17
Non-Retaliation Policy........................................................................................ 4 Engaging in Political Activities on Our Own............................................... 17
Closing Note...............................................................................................28
A Message From John Watson
Chevron enjoys a strong reputation for honesty and Performance are all core values of The Chevron Way
integrity throughout the world. Preserving the trust that underpin our business conduct. We believe that
of our stakeholders is the responsibility of every when we apply our ethical principles to our business
individual in the Company. Our Business Conduct decisions, the Company is positioned for success.
and Ethics Code is designed to help each of us meet
Our values guide our actions in conducting business
that obligation.
in a socially responsible and ethical manner and
The Code explains Chevrons policies for how we distinguish Chevron in the eyes of our stakeholders.
conduct business around the world. Each of us As a corporation and as individuals, we respect the
employees, officers and members of the Board of law, support universal human rights, protect the
Directors alike must commit to understanding this environment, achieve operational excellence and
Code and abiding by its principles. benefit the communities where we work.
The principles support full compliance with applicable In a competitive global environment, we will
laws. They also represent the practical ways that sometimes encounter situations that will test our
we put our values to work every day. Our corporate judgment and integrity. When that test arises, we
values outlined in The Chevron Way serve as the can use this Code to help us answer the following
foundation for this Code. Simply stated, its about questions before we act:
I encourage you to read, understand and, most
getting results the right way. Is this legal and in keeping with Company policy,
important, to conduct your actions in keeping with
including our Human Rights Policy?
Integrity, Trust, Diversity, Ingenuity, Partnership, ourBusiness Conduct and Ethics Code. And never
Is this consistent with The Chevron Way?
Protecting People and the Environment and High hesitate to seek help if youre faced with a legal,
If this were made public, would I be comfortable?
compliance or ethical issue.
John Watson
Chairman and Chief Executive Officer
The 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
Chevron communities where we work.
Way Integrity
We are honest with others and ourselves. We
Partnership
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.
Q
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
I observed a situation that I suspect is a
matter with their supervisor, local management or policies. There are no negative consequences to
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
thereis a problem? will take place.
A
For Additional Guidance
Contact your supervisor, your manager, Corporate
Compliance or the Compliance liaison or coordinator Corporate Policies
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
andGuidelines
your local Human Resources representative.
Q
a job offer to a male. (I am a female.) I feel I may have
been discriminated against. What can I do?
I am a supervisor who has only one minority employee. Unfortunately this employee is having performance
A 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
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
Q
Company will support you. If you need help, consult with your local Human Resources representative.
A
202: Harassment 230: Total Remuneration 264: Alcohol
210: Termination 256: Labor Relations 570: Security of Personnel and Assets
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.
Q
134: Auditing
financial reports. Be sure every transaction you record
136: Availability of Records
is accurate. My supervisor told me to destroy documents
190: Delegation of Authority
related to a project that we did last year. Now, the
Q
420: Preparation, Approval and Execution
internal auditors are asking questions as though they
of Documents
Last week, I entered a transaction for an are concerned. Since my supervisor told me to do this,
566: Information Retention
associate. I had several questions about the way the I should not be in trouble, should I?
A
deal was done. Even though my supervisor could not
really answer the questions, she assured me that it The auditor is not investigating to get anyone
was all trustworthy and that I should just plug in the in trouble. The auditors role is to ensure that our
numbers as requested. What should I have done? Company follows required policies and processes.
A
position, I now have authority to contract with that
same supplier. Am I faced with a potential conflict
Yes. This kind of financial news can have
ofinterest?
a negative effect on a companys stock price and
A
anticorruption laws, the NOC partners are deemed
government officials. May we invite them to the
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
and U.S. laws. Due diligence on this agents reputation
A Please consult your compliance coordinator.
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
A
Corporate Policy
No. This payment likely violates local and other 324: Gifts to U.S. Public Officials
A
included the amount in my expense report. Will the
Company reimburse me for this expense?
A meal is considered a gift. For U.S. officials,
Q
and budgeted and have several specific legal
and management approvals prior to making the
A co-worker uses Company email to solicit votes Additional Resources
contribution. Outside the United States, political
and financial support for his sister, who is running for Within the United States, consult the Political Law
contributions undergo an equally rigorous review and counsel (Corporation Law) or the senior analyst,
a local political office. Is this acceptable?
approval process. Political Programs and Compliance (PGPA).
Q My supervisor asked me to perform a task that Q My work site has a program to record,
investigate and correct injury-producing accidents.
I believe violates environmental regulations. What
should I do? Part of the sites annual incentive plan is based on its
A
safety performance, and I know of injuries that are not
being reported. What should I do?
Never guess about environmental regulations. If
you are uncertain, check with your supervisor to be sure
you have understood the request. If you still feel the A Its important to investigate injury-producing
accidents to determine steps necessary to prevent
request violates environmental regulations, report the
concern to local management or the Chevron Hotline. similar occurrences. You should always notify your
supervisor when an accident occurs in the workplace.
Q
If a co-worker or supervisor is reluctant to report a
work-related injury, encourage him or her to report
I 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
A
530: Operational Excellence
Whenever we have any doubt as to whether an action we are considering raises issues under these laws,
we should seek advice from our local Chevron legal counsel.
A
of its business?
A
this information?
A
the cost. Can I borrow his video and make a copy? and still continue to read my company email?
Chevrons legal and ethical obligations go far beyond what is included in this Code of Conduct. We must
comply with both the letter and the spirit of the many laws and regulations that affect our business.
If questions arise about any matter of compliance or ethics, whether covered by this Code or not, we
should consult our supervisor, manager, Corporate Compliance or Chevrons legal counsel or call the
Chevron Hotline if our concerns are not properly addressed. The Companys Manual of Compliance
Procedures and Guidelines is also a valuable resource for guidance on many compliance issues.
The responsibility for meeting our legal and ethical obligations cannot, however, be fully defined or
guaranteed by any set of written rules. There will almost certainly be times when the best course of
action can only be recognized by ensuring our actions are consistent with our Companys values and
ethics. Driven by a passion for excellence in everything we do, we strive to achieve High Performance
and results the right way according to the ethical principles in our Code and in a manner consistent
with our values.
In the end, our confidence must rest, as it always has, on the honesty, integrity and good sense within
each of us.