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Business Conduct and Ethics Code

Table of Contents

The Values of The Chevron Way....................................................................1 Operational Excellence:


Safety, Health, Environment, Reliability and Efficiency........................ 14
A Message from Dave O’Reilly..................................................................... 2
Protection of Information and Intellectual Property............................. 16
About the Business Conduct and Ethics Code..........................................3 Proper Access and Use.......................................................................... 16
Handling Sensitive or Proprietary Information.................................. 16
Our Role and Responsibility......................................................................... 4
Retaining or Discarding Company Records......................................... 17
Authority................................................................................................... 4
Retrieving Information for Litigation Purposes................................. 17
Guidance................................................................................................... 4
Using Computer Systems and Other Technical Resources............... 17
Compliance............................................................................................... 4
Using Email and the Internet................................................................ 17
Reporting Possible Violations................................................................ 4
Non-Retaliation Policy............................................................................. 4 Data Privacy................................................................................................... 19
Proper Use of Personal Data................................................................. 19
Our Employees................................................................................................ 6
We Respect Diversity............................................................................... 6 Antitrust/Competition Laws........................................................................ 21
We Provide Equal Opportunity............................................................... 6 Agreements and Contacts with Competitors...................................... 21
Employee Compensation and Tenure....................................................7 Relationships with Customers and Suppliers...................................... 21
Controlled Substance and Drugs............................................................7 Consequences of Violations.................................................................. 21
Alcohol.......................................................................................................7
Preventing Workplace Violence and Harassment................................7 Government Affairs and Political Involvement....................................... 23
Engaging in Lobbying Activities.......................................................... 23
Company Records and Internal Controls................................................... 9 Providing Gifts or Making Payments to Public Officials................... 23
Our Shared Responsibility...................................................................... 9 Making Political Contributions............................................................. 23
Internal Controls...................................................................................... 9 Engaging in Political Activities on Our Own...................................... 23
Audits........................................................................................................ 9
Fraud.......................................................................................................... 9 Multinational Operations............................................................................. 25
Bribery Is Always Prohibited................................................................ 25
Avoiding Conflicts of Interest...................................................................... 11 Complying with International Trade Laws.......................................... 25
Avoid Accepting or Giving Gifts, Fees, Favors Understanding Anti-Boycott Laws....................................................... 25
or Other Advantages............................................................................... 11
Insider Trading Is Prohibited................................................................. 12 Human Rights Statement........................................................................... 27

Closing Note.................................................................................................. 28

C hev ro n Bus iness Co nd uc t a nd Ethics Cod e


The Chevron Way
explains who we are,
what we do, what we
believe and what we Values
plan to accomplish.
Our Company’s foundation is built on our Values, which distinguish us and guide our actions.
It establishes a common We conduct our business in a socially responsible and ethical manner. We respect the law, support
understanding not only universal human rights, protect the environment and benefit the communities where we work.
for those of us who work
here, but for all who Integrity Partnership
interact with us.
The
We are honest with others and ourselves. We have an unwavering commitment to being
We meet the highest ethical standards in all a good partner focused on building productive,
business dealings. We do what we say we will collaborative, trusting and beneficial relationships

Chevron do. We accept responsibility and hold ourselves


accountable for our work and our actions.
with governments, other companies, our
customers, our communities and each other.

Way Trust Protecting People and the Environment


We trust, respect and support each other, and we We place the highest priority on the health and
strive to earn the trust of our colleagues and partners. safety of our workforce and protection of our
assets and the environment. We aim to be admired
for world-class performance through disciplined
Diversity 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 and talents they provide. We have an
High Performance
inclusive work environment and actively embrace a We are committed to excellence in everything we
diversity of people, ideas, talents and experiences. do, and we strive to continually improve. We are
passionate about achieving results that exceed
expectations — our own and those of others. We
Ingenuity 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.

Chevro n Bus iness Co nd uc t a nd Ethics Cod e • 1


A Message from Dave O’Reilly

Most people agree that what a person does is in this Code. Simply stated, it’s about “getting
much more important than what he or she says. results the right way.”
This is true for companies as well as individuals.
It is because of the actions of all Chevron Integrity, Trust, Diversity, Ingenuity,
employees that we enjoy such a strong reputation Partnership, Protecting People and the
for honesty and integrity throughout the world. Environment, and High Performance are all
core values of The Chevron Way that play a key
Preserving the trust of our stakeholders is part in our business conduct. At Chevron we
critical to Chevron’s future, and is everyone’s believe not only that we must apply the highest
responsibility. Our Business Conduct and Ethics ethical standards to our most innovative business
Code is designed to help each of us meet that ideas, but that those standards are critical to our
responsibility. It explains Chevron’s policies business success. We believe that when we apply
for how we conduct ourselves and how we our ethical principles to our business decisions, it
do business around the world. Each of us — positions the Company for success.
employees, officers, and members of the Board of
Directors alike — must commit to understanding These values continue to set Chevron apart and
this Code and abiding by its principles. guide our actions as we conduct our business When that test arises, this Code helps each of us
in a socially responsible and ethical manner. As to answer the following questions before we act:
The principles discussed in this Code support a corporation and as individuals we respect the • “Is this legal and in keeping with Company policy?”
full compliance with applicable laws. They also law, support universal human rights, protect the • “Is this consistent with The Chevron Way?” and
represent the practical ways that we put our environment, achieve operational excellence, and • “If this were made public, would I be comfortable?”
strongly held values to work every day. Our benefit the communities where we work. As we
corporate values, known to all employees and strive to live up to this reputation while doing
I encourage you to read and understand the Code
business partners worldwide as The Chevron Way, business in a competitive global environment, we
and most importantly to know where to go to get
serve as the foundation for all of the guidelines will sometimes encounter situations that will test
help, if and when the need arises.
our judgment and integrity.
Dave O’Reilly
Chairman of The Board

2 • C hev ro n Bus iness Co nduc t a nd Ethi cs Cod e


About the Business Conduct and Ethics Code
The Code helps us understand how Chevron’s Values are put into practice everyday.

Chevron’s Business Conduct and Ethics Code Using the Code


is built on our core values and highlights the
principles that guide our business conduct. It • Read through the entire Code.
provides questions and answers for situations • Think about how the Code applies to your job, and consider how you might handle situations to
that you might encounter on the job, and lists avoid improper, illegal or unethical actions.
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, manager or contact another one of the resources listed
workplace situation or list all of Chevron’s in this Code.
Corporate Policies and Procedures. Use it for
guidance about our ethical standards and where
to take your questions or concerns. Ethical Decision-Making
When each of us follows the Code, we communicate Ethical decision-making is essential to the success of our Company. Some decisions are obvious and easy
our commitment to the values that have made to make; others are not. When faced with a difficult situation, asking ourselves the questions below can
Chevron admired both as a business partner and help us to make the right ethical decisions.
as a valued citizen of the global community. It
Four “yes” answers are required to qualify an action as ethical and in step with Chevron’s Values.
is important to note, however, that violations of
the Code, or the policies referred to in the Code, 1. Is it legal?
could result in discipline, including termination of If you think an action may be illegal, do not proceed. If you need information about which laws
employment or criminal prosecution. apply in a given situation, talk with your supervisor, manager or Chevron’s Law Department.

2. Is it consistent with Company 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.

Chevro n Bus iness Co nduc t a nd Ethics Cod e • 3


Our Role and Responsibility
Each of us has a responsibility to speak up.

All of us must obey the letter and spirit of the law Authority and does not promptly report and correct it may
at all times, wherever we live or work. Each of the be subject to similar consequences.
countries where our Company does business has Besides knowing and understanding this Code,
its own laws, regulations and customs. Sometimes each of us must understand the level of authority The Board Audit Committee, supported by the
there can be significant differences from one place included in our job. We must all be careful to act Corporate Compliance Policy Committee, made
to another and between regions within a single within the limits of that authority. up of senior executives in the Company, governs
country. However, no matter where we work, we our Company-wide Compliance Program. Each
are all responsible for respecting all applicable Guidance reporting unit has its own compliance or audit
laws and following the policies in our Code. committee to manage the responsibilities specific
No code or manual can provide complete answers to that organization. This is also often the case for
to all questions. In the end, we must rely on business units within the reporting units.
our good sense of what our Company’s high
standards require. This includes knowing when
to seek guidance on the proper course of action. Reporting Possible Violations
We should expect timely and specific guidance Each of us must speak up promptly if there is any
from our supervisors, managers, the Chevron Law reason to suspect that anyone in Chevron or its
Department, the Corporate Compliance group or affiliates has violated Company policies or local
our local Compliance Coordinator. laws. We must also report any activity that could
damage the Company’s reputation. One resource
Some of us have jobs that require more detailed available to each of us is the Chevron Hotline.
knowledge of particular compliance topics than You can call or submit a report to the Hotline,
this Code provides. In this case, our managers which operates 24 hours a day, seven days a week.
or supervisors will direct us to the appropriate
information in Corporate Policies and the Manual
of Compliance Procedures and Guidelines. Non-Retaliation Policy
Chevron does not tolerate any form of retaliation
Compliance for reports made in good faith. This includes
blatant actions, such as firing, transferring,
Each of us must comply with this Code, and demoting, or publicly attacking someone, as
with all Company policies. If we fail to do so, we well as more subtle retaliation, such as avoiding
may face disciplinary action, possibly including someone, leaving him or her out of professional
termination. Likewise, any supervisor, manager, or social activities, and so on. It includes actions
officer or director who is aware of any violation taken by managers and employees alike.

4 • Chev ro n Bus iness Co nduc t a nd Ethi cs Cod e


Questions & Answers
Q I observed a situation that I suspect is a
violation of our guidelines. Should I report this
For Additional Guidance:
Corporate Policies
situation even if I am not completely certain that 1: The Chevron Way
there is a problem? 2: Manual of Compliance, Procedures and Guidelines

A Employees are responsible for immediately


reporting possible violations to their supervisors or Additional Resources:
another Company resource. While reporting to your The Chevron Way
supervisor is usually best, you may also call the The Chevron Way explains who we are, what we do, what we believe and what we plan to accomplish.
Chevron Hotline. Your report will be taken seriously It establishes a common understanding not only for those of us who work here, but for all who interact
with us. Visit Chevron’s Intranet at: http://myinside.chevron.com/aboutchevron/chevronway/
and investigated as appropriate. It is better to report a
suspicion that turns out not to be an issue than to ignore Manual of Compliance Procedures & Guidelines
a possible violation of the law or Company policy. Consult the Corporate Manual of Compliance, Procedures and Guidelines (MCPG) for more

Q
information about applicable laws, Company policies, and compliance procedures relating to all subject
matter areas covered in the Business Conduct and Ethics Code. Visit Chevron’s Intranet at
If I see a questionable situation, is it better http://businessconduct.chevron.com/manual_compliance/
for me to call the Chevron Hotline or to talk to my
supervisor? Request Guidance or Voice Concerns

A
Contact your supervisor, your manager, Corporate Compliance or the Compliance liaison or coordinator
for your reporting unit.
You do not have to call the Chevron Hotline
if there is a way to resolve the situation through a Chevron Hotline
discussion with your supervisor, local management, Report any suspected violation of the law or Company policies. There are no negative consequences to
raising concerns in good faith using the hotline, and the Company assures employees that no retaliation
or your local Human Resources business partner.
will take place. Visit Chevron’s Intranet at http://corp-compliance.chevron.com/hotline/ for more information.
But the Chevron Hotline is an option for people who
for some reason are not comfortable discussing the
matter with their supervisor, local management, or
Human Resources business partner.

C hevro n Bus iness Co nd uc t a nd Ethics Cod e • 5


Our Employees
We value the uniqueness of individuals and the various perspectives and talents they provide.

We are our Company’s most valuable resource should ever be subject to illegal discrimination on
and are essential to its success. In the course of the basis of:
our daily work, we use our creativity, experience, • race
technology and perseverance to find innovative • religion
and practical solutions to all challenges that arise.
• color
Our values of Ingenuity and High Performance
would be meaningless if Chevron did not have • national origin
the highest quality workforce possible and • age
continuously work to develop its employees. • sex
• gender identity
We Respect Diversity • disability
Diversity is also a fundamental value at Chevron. • veteran status
As stated in The Chevron Way, this means that • political preference
“we learn from and respect the cultures in which • sexual orientation
we work.” We also value “the uniqueness of
individuals and the various perspectives and In the United States, discrimination is prohibited
talents they provide.” We promote diversity in hiring, rate of pay, promotion, demotion,
within our work force and have an inclusive transfer, layoff or termination. Many other
environment that helps each of us to fully countries have similar anti-discrimination laws.
participate and contribute to Chevron’s success.

We Provide Equal Opportunity


Our policy against discrimination aligns with our
position on diversity. The Company follows the
laws that prohibit discrimination in employment
practices, wherever we do business. It is Chevron’s
policy to provide equal employment opportunities
and to treat applicants and employees without
illegal bias. It is our policy that no one at Chevron

6 • Chev ro n Bus iness Co nd uc t a nd Ethi cs Cod e


Employee Compensation and Tenure equipment, is prohibited unless prior permission with employees in the course of their duties.
has been obtained from appropriate Company Every threat of violence is serious. We must
Our Company has a “pay-for-performance” management. In certain circumstances, such as report any such event immediately.
philosophy. We administer wages, salaries and official Company events, use of alcohol may be
benefits to maintain our competitive position authorized, as long as permission is received in Threats of immediate concern should be
in the marketplace. It allows us to attract and advance from appropriate Operating Company or referred to Global Security and/or your local
retain top-notch personnel, provide incentive, and Corporate Department management. Any person police department.
reward excellence. This approach to compensation under the influence of alcohol is prohibited
supports our value of High Performance. Chevron is also committed to a workplace free
from entering Company premises, engaging
of illegal harassment. If you are confronted with
Chevron does not guarantee employment in a in Company business or operating Company
harassment, you should report your concern to
specific job or for any particular period of time to equipment. Any use of alcohol that causes or
your supervisor, local management, HR business
any employee. contributes to unacceptable job performance or
partner or Chevron’s Hotline.
unusual job behavior is also prohibited.
Controlled Substance and Drugs Where allowed by law, the Company may
The Company prohibits the use, possession, conduct searches and test for drug and alcohol
distribution, purchase or sale of controlled use if necessary.
substances on its premises while conducting business In many locations worldwide, the Company
for the Company or while operating Company makes resources available to assist employees
equipment. Controlled substances include: with drug or alcohol problems. For information
• illegal drugs and narcotics about Employee Assistance and Worklife Services,
• prescription drugs obtained or used without consult the Human Resources web site or contact
a legal prescription or your supervisor or local HR business partner.

• other unlawful substances or materials.


Preventing Workplace Violence
Alcohol and Harassment
The use, possession, distribution, purchase The Company prohibits actual or threatened
or sale of alcohol by any person while on violence against co-workers, visitors or anyone
Company premises, or while operating Company else that is either on our premises or has contact

C hevro n Bus iness Co nd uc t a nd Ethics Cod e • 7


Questions & Answers
Q I posted for a job in a different department
whose staff consists of five males. The manager

Q
made a job offer to a male. (I am a female.) I feel I
may have been discriminated against; what can I do?

A
I 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
Provide consistent feedback to all members of your group. Be fair in your evaluation and document
Resources representative or the Chevron Hotline.

Q
your proof with facts and examples. If you are accused of discrimination, the Company will support you. If you
need help, consult with your local Human Resources business partner.
Yesterday I had an argument with a co-worker
that almost escalated into a physical confrontation
when he challenged me to meet him outside. I believe For Additional Guidance:
he may try to harm me at some point. What can I do? Corporate Policies

A
200: Employment 226: Discipline 263: Drugs/Controlled Substances
Report this incident to your supervisor or 202: Harassment 230: Total Remuneration 264: Alcohol
210: Termination 256: Labor Relations 570: Security
your local Human Resources representative. Threats
of immediate concern should be referred to Global
Security and/or your local police department.

Additional Resources:
Employee Assistance and Worklife Services, which can help resolve personal, family and work-related
concerns or problems, including help with drug or alcohol problems: Visit the HR website at:
http://hr.chevron.com/.

Office of the Ombuds, visit Chevron’s Intranet site at: http://ombuds.chevron.com/.

Global Security web site at: http://globalsecurity.chevron.com/default.asp and


https://cpln-www1.chevron.com/corphes/corp_er.nsf.

8 • Chev ro n Bus iness Co nd uc t a nd Ethi cs Cod e


Company Records and Internal Controls
Fair and accurate books and records are essential for managing Chevron’s business.

Our Shared Responsibility these policies to the Internal Audit department or Company policy and the law and carries severe
the Chevron Hotline. penalties. Those consequences apply to any
Chevron’s books and records must be prepared dishonest or fraudulent activities, including
accurately and honestly, both by our accountants misusing or stealing Company assets or cheating
who prepare records of transactions and by any Internal Controls
on travel and entertainment expense reports,
of us who contribute to the creation of records, Reliable internal controls are critical for proper, among other violations. The Company relies on
for example, by submitting expense reports, job complete and accurate accounting. Each of us its internal controls and the personal integrity
logs, measurements and time sheets. All of our must understand the internal controls relevant of all its employees and directors to protect
books and records must be supported by enough to our positions, and follow the policies and Company assets against damage, theft and other
documentation to provide a complete, accurate, procedures related to those controls. We are all unauthorized use.
valid, and auditable record of the transaction. encouraged to talk to our managers or supervisors
immediately if we ever suspect that a control does
Fair and accurate books and records are essential not adequately detect or prevent inaccuracy, waste
for managing Chevron’s business and maintaining or fraud.
the accuracy and integrity of the Company’s
financial reporting and disclosure. This is true
for both reports filed with the U.S. Securities Audits
and Exchange Commission and for other public Audits performed by our internal and external
communications. Our commitment to the value auditors help ensure compliance with established
of Integrity is fundamental to the truthfulness of policies, procedures and controls. They also
financial reports the Company makes to the public. help identify potential weaknesses so they may
be corrected promptly. All of us are required to
Both Company policy and various laws, such cooperate fully with internal and external audits.
as the Sarbanes Oxley Act of 2002 (SOX), This means always providing clear and truthful
require the completeness and accuracy of our information and cooperating fully during the
records. Any attempt to conceal or misstate audit process.
information in Company records is a serious
offense and may result in disciplinary action and
criminal prosecution. Each of us is responsible Fraud
for reporting any suspected violations of the Engaging in any scheme to defraud anyone — of
Company’s accounting policies and procedures. money, property or honest services — violates
You should report any suspected violation of

C hevro n Bus iness Co nduc t a nd Ethics Cod e • 9


Questions & Answers
Q I am not a manager. Can I be held legally
responsible for failing to report Company information

Q
accurately?

A Yes. Although top management must sign off


on our Company’s financial reports, every employee
My supervisor told me to destroy documents related to a project that we did last year. Now, the internal
auditors are asking questions as though they are concerned. Since my supervisor told me to do this, I should not
be in trouble, should I?

A
records some transactions and these all affect the
financial reports. Be sure every transaction you
The auditor is not investigating to get anyone “in trouble.” His role is to ensure that our Company
record is accurate.
follows required policies and processes. You are responsible for understanding our document retention

Q Last week, I entered a transaction for an


associate. I had several questions about the way the
policies. If your supervisor told you to destroy documents that should have been retained, blindly following
orders was not the right course of action. The best thing you can do now is to answer the auditor’s questions
completely and honestly.
deal was done and even though my supervisor could
not really answer the questions, she assured me that
it was all “on the up and up” and I should just plug in
For Additional Guidance:
the numbers as requested. What should I have done?
Corporate Policies

A It’s your responsibility to understand every


transaction you enter, since you may need to answer



130: Internal Controls
132: Approval of Expenditures and Payment of Funds
134: Auditing
questions about its accuracy. You were correct to ask 136: Availability of Records
190: Delegation of Authority
your supervisor for advice. Even though she approved
420: Preparation, Approval and Execution of Documents
the transaction, if you still have questions related to
the integrity of the transaction, you should feel free to
ask a higher level of management or your Reporting
Additional Resources:
Unit’s Compliance Coordinator, or report your concern
For more information on SOX, visit Chevron’s Intranet at:
to Internal Audit or the Chevron Hotline. http://dominous2.chevron.com/corp/soxhelp.nsf/?OpenDatabase

10 • C hev ro n Bus iness Co nd uc t a nd Ethi cs Cod e


Avoiding 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 Any activity that has the appearance of a conflict Reporting Units have the responsibility for
in the best interests of the Company. This means of interest — whether or not an actual conflict establishing guidelines for employees on
that business decisions should be made free from exists — must be avoided. If you think you may what is considered “nominal value” for
any conflict of interest. They should also appear be in a situation that could be perceived as a such gifts and entertainment.
impartial. We must make our decisions based on conflict, disclose the potential conflict to your • Give a gift or entertainment to anyone for
sound business reasoning. supervisor or manager immediately. Of course, if the purpose of improperly influencing him
any of us sees a conflict of interest at Chevron, we or her to take action in favor of Chevron.
Conflicts of interest may occur when an must report it.
individual’s outside activities or personal interests
conflict or appear to conflict with his or her Avoiding conflicts of interest in all of our If we ever feel that it may be appropriate to
responsibility to Chevron. An outside activity business decisions is essential to our values of accept a gift of more than nominal value, we
would be considered a conflict of interest if it: Integrity and Trust. should seek guidance from our supervisors.
• Has a negative impact on our business
interests Avoid Accepting or Giving Gifts, Fees,
• Negatively affects Chevron’s reputation or
Favors or Other Advantages
relations with others, or It is also a conflict of interest for a Chevron
• Interferes with an individual’s judgment in employee or director to give or receive
carrying out his or her job duties. extravagant gifts or entertainment to or from
people or companies doing business with
Employees and directors — and members of their Chevron. Therefore, we must not:
immediate families, must never: • Accept fees or honoraria in exchange
• Compete against the Company for services provided on behalf of the
Company.
• Use their position or influence to get an
improper benefit for themselves or others • Provide or accept gifts or entertainment
from anyone doing or seeking business with
• Use Company information, assets or
Chevron or any of its affiliates. Generally,
resources for their personal gain or the
modest forms of gifts and entertainment
improper benefit of others, or
received from vendors are acceptable and
• Take advantage of inside information or do not create conflicts of interest. However,
their position with the Company.

C hevro n Bus iness Co nd uc t a nd Ethics Cod e • 1 1


We must never use material non-public information of any kind for personal gain.

Insider Trading Is Prohibited securities. Some examples of non-public information


that could be considered material include:
It is illegal to purchase or sell Chevron securities
if you have “material non-public information” • financial forecasts
concerning Chevron. Securities include common • changes in sales, market share or
stock or other debt or equity securities, options production
or shares held in Chevron investment and
• changes in debt ratings or analyst upgrades
retirement plans. It is also illegal to purchase
or downgrades of Chevron securities
or sell the securities of another company if you
have material non-public information about that • earnings, dividends or stock splits
company. If you engage in insider trading and are • proposed mergers, acquisitions, or
caught you could lose your job and be subject to divestitures
significant civil and criminal penalties.
• marketing plans
We must never use material non-public • strategic plans
information about Chevron or the companies
doing business with Chevron for personal gain. • new product information
In addition, we must never pass material non-public • changes in top management
information on to others who may purchase or
sell Chevron securities or the securities of other
Whether any particular information could be
companies. If you provide a “tip” to someone
considered “material” by a reasonable investor
who then buys or sells securities, both of you can
depends on specific circumstances. A major factor
be convicted of insider trading.
in determining whether information is material
“Non-public information” is information that is the impact that information could have on the
is known within the Company and has not been Company’s financial condition or stock price.
publicly released. “Material information” is If you are in doubt as to whether non-public
information that a reasonable investor would information you have is material, you should
consider important when deciding to buy or sell seek guidance from your supervisor or your local
Chevron legal counsel.

12 • C hev ro n Bus iness Co nd uc t a nd Ethi cs Cod e


Questions & Answers
Q My father owns a controlling interest in a
Company that has supplied materials to Chevron for
A Yes. This kind of financial news can have
a negative affect on a company’s stock price and
For Additional Guidance:
Corporate Policy
282: Conflict of Interest
many years. I was recently hired and in my new position would certainly be considered material non-public
I now have authority to contract with that same information, or inside information. If you sell Chevron
supplier. Am I faced with a potential conflict of interest? securities on the basis of this information before it

A
becomes public, you are engaging in insider trading.

Even though the supplier is a long-time vendor


of our Company, an appearance of a conflict has
now been created because you are involved in the
Q I accidentally saw a copy of a confidential
memo describing a large contract that our Company
decision making process regarding the selection will soon sign with another company. If I buy some
of the supplier. In this case, the problem could be of the other company’s stock on the basis of this

resolved if an independent decision maker, such as information and before news of the contract is made
public, am I engaging in insider trading?
your manager, acts instead of you. The important
action for you to take is to disclose the potential
conflict to your supervisor or manager so that it may
be resolved.
A Yes. Assuming that the news of this contract
is material non-public information, or insider

Q
information, if you purchase securities of the other
company on the basis of this information before it
I recently learned that our Company will
becomes public you are engaging in insider trading.
announce disappointing financial results for this
quarter. Is this inside information?

Chevro n Bus iness Co nduc t a nd Ethics Cod e • 1 3


Operational Excellence:
Safety, Health, Environment, Reliability and Efficiency

Chevron’s policy is to maintain the We are committed to working in a way that places the highest priority not only on our own safety
and health, but also on the safety and health of our co-workers and members of the community. We
safety and health of people and the are also committed to protecting the environment by minimizing and mitigating environmental impact
quality of the environment where throughout the lifecycle of our operations. Protecting People and the Environment is a key value at
Chevron. Our policy is to maintain the safety and health of everyone and the quality of the environment
we operate. wherever we operate.

All of us are responsible for complying with laws, regulations and Company policy and for fully
Chevron’s Operational Excellence Management committing to the requirements of the OEMS in our work activities. Corporate Policy 530 commits
System (OEMS) defines the expectations with regard Chevron to comply with the letter and spirit of all environmental, health and safety laws and regulations.
to the systematic management of safety, health,
environment, reliability and efficiency to achieve Each of us has the authority and responsibility to stop — or not start — any work activity if hazards or
world-class performance in operational excellence. risks pose a threat to safety.

14 • C hev ro n Bus iness Co nd uc t a nd Ethi cs Cod e


Questions & Answers
Q My supervisor asked me to follow a procedure that
I believe is environmentally incorrect. What should I do?
Q My worksite has implemented a program to
record, investigate, and correct injury-producing

A
accidents. Part of the site management team’s annual
success sharing is based on its safety performance
Never guess about environmental procedures.
and I know of injuries that are not being reported.
If you are uncertain of the procedure, check with
What should I do?
your supervisor to be sure you have understood
the request. If you still feel the request violates
environmental regulations, report the concern to
local management or the Chevron Hotline.
A It’s important to investigate injury-producing
accidents to determine steps necessary to prevent

Q
similar occurrences. You should always notify
your supervisor when an accident occurs at the
I have a work order that specifically outlines
workplace. If a co-worker is reluctant to report a
a task to be performed. As I began to do the task, I
work-related injury, encourage him or her to report
discovered that conditions are different from those
it. If the practice continues, report your concern to
expected when the job was planned. I have a feeling
local management or the Chevron Hotline.
that continuing the job as outlined in the work order
will be unsafe. What should I do?

A Employees have the responsibility and authority


to stop or not begin work that they believe may be
For Additional Guidance:
Corporate Policy
unsafe. You should communicate your concerns to 530: Health, Environment and Safety
your supervisor. Your supervisor has the responsibility
to investigate, understand and resolve the issue.

Additional Resources:
Visit the Operational Excellence Website at
(https://cpln-www1.chevron.com/corphes/oehome.nsf?OpenDatabase&login) for more information
about safety, health, environment, reliability and efficiency.

Chevro n Bus iness Co nd uc t a nd Ethics Cod e • 1 5


Protection of Information and Intellectual Property
We all have a responsibility to understand the risks when our information assets are compromised.

Chevron’s information assets are vital resources. and handle particular information assets. Typical enforceable intellectual property rights of third
They include both the Company’s paper and examples might include taking your assigned parties, including patents, copyrights, trade secrets and
electronic records and also the systems that Company notebook and/or PDA (Blackberry) other proprietary information. We will not knowingly
store, process or transmit Company information. home or being granted access to specific infringe on or misuse the valid and enforceable
Chevron’s intellectual property, which includes computer systems. Employees unsure of their intellectual property rights of third parties.
the Company’s trade secrets, patents, trademarks, authority should discuss this subject with local
and copyrighted material, is also a key Chevron management for clarification. Improper handling If you have a question about the use of patented
information asset. of information may be grounds for disciplinary or proprietary information including computer
action, including termination. Examples of software of third parties, you should contact
improper handling include unauthorized viewing, the Chevron Law Department. In order to use
Proper Access and Use copyrighted material such as articles, charts,
copying, distributing, removing from the premises,
Chevron policy safeguards our information assets damaging, and altering of information. maps, films and music, we must receive the
against theft, unauthorized disclosure, misuse, permission of the copyright owner, unless such
trespass and careless handling. At times we may activities are allowed under the “fair use”
Handling Sensitive or
be authorized, by local management, to view provisions of the copyright laws. The Chevron
Proprietary Information Law Department Intellectual Property Practice
Group can help you determine whether a use of
We all must be cautious and discreet when using
materials meets the criteria for “fair use.”
information categorized as classified, confidential
or sensitive. Such information should be shared
only with other Chevron employees who have
a legitimate “need to know.” Outside parties
should only have access to such information if
they are under binding confidentiality agreements.
Similarly, when handling sensitive information
that has been entrusted to us by others, we must
always treat it with the utmost care. Doing so can
protect us from potential liability and is also in
keeping with our values of Partnership and Trust.

We must also comply with all laws, regulations and


contractual commitments regarding the valid and

16 • C hev ro n Bus iness Co nd uc t a nd Ethi cs Cod e


Retaining or Discarding Retrieving Information
Company Records for Litigation Purposes
A Company record may serve one of many Sometimes during the course of litigation, we might
purposes. It may: be instructed by Chevron’s legal counsel to provide
• satisfy operating requirements (for example, documents or other evidence. We must always
maintenance logs, service contracts), comply with such instructions. We must consult
counsel if we have any questions, and report non-
• document a Company holding (for example, compliance if we suspect it. All of us are expected
a lease or deed), to treat this process as a priority assignment.
• protect the Company’s interest in legal
actions (for example, a product quality Using Computer Systems
test), or
and Other Technical Resources Using Email and the Internet
• show compliance with governmental
regulations (for example, financial and We are all responsible for helping to make sure We must all ensure that computer and
injury reports). that Chevron’s computer systems and other telecommunication systems are used only for
technical resources are used appropriately. We Company business. Occasional personal use is
must keep access codes (for example, passwords, permitted as long as we never violate Chevron’s
We must all follow Chevron’s retention policy SmartBadge, PINs, etc.) in a secure place and not standards of acceptable behavior. We should not
for all records and other forms of information. share them with others. Anyone with a system assume that any use of Chevron’s communications
Company records must be kept for the set period identity and password is responsible for activities devices or systems is private. Our usage of these
required by the Company’s retention schedule. performed under that identity. may be monitored by the Company, subject to
Documents and other forms of information that local laws and regulations.
do not qualify as Company records, however, Unauthorized use of passwords, computer systems
should not be retained past the time that they or programs may be grounds for disciplinary
serve a business purpose. action, including termination of employment.

Chevro n Bus iness Co nduc t a nd Ethics Cod e • 1 7


Questions & Answers
Q A colleague in another company recommended
a management training video that he said was helpful to
Q I have been asked to speak at an industry
conference on the subject of our Company’s
Q My work involves confidential information. I
use a laptop computer when traveling on business.
his team. I’d like to show it to my team, but I can’t justify developed technology and its benefits to our What precautions should I take?

A
the cost. Can I borrow his video and make a copy? customers. What should I do?

A Video materials are copyrighted which means


that they cannot be copied, and sometimes even the
A Discuss the content of the presentation with
your supervisor before accepting the invitation.
Keep your laptop computer secure at all
times. Do not check it with the airline or leave it in
any unsecured place. If you travel with confidential
original video cannot be borrowed and re-shown, Industry conferences can be a good opportunity information, be careful where you work on sensitive
without the copyright owner’s prior permission. If you to promote our Company. However, we must use documents. Avoid public places where your
want to show it to your team, then you must buy a extra caution to protect confidential information. information might be seen, such as planes, airports or
legitimate copy of the video. Furthermore, be aware Your presentation material may also need to be restaurants. If traveling abroad, check the Corporate
that some video materials, even when purchased, reviewed by the Corporate Policy, Government and Law web site to ensure any countries you are planning
are available only for a specific use or a one-time Public Affairs Group or Chevron Corporation Law to visit do not have technology restrictions for laptop
showing, so do not assume that further showings Department’s Intellectual Property Practice Group. computers that could result in its being confiscated by
would be acceptable. Verify the rights obtained by the Customs officials.
company before showing the video again.
For Additional Guidance:
Corporate Policies 480: Intellectual Property
360: E
 xternal Speeches and 561: Electronic Mail
Papers, Teaching of Courses 566: Information Retention
and Patent Applications 575: Information Protection

Additional Resources:
Visit the Information Protection website at: http://glirm.chevron.com/programs/inforProtection.aspx.
Visit the Information Management website at http://glirm.chevron.com/programs/inforMgmt.aspx.
Consult the records retention criteria
(http://glirm.chevron.com/programs/recordsRetention/recordsRetention.aspx) and schedule
(http://glirm.chevron.com/programs/retentionSchedule/retentionSchedule.aspx).

1 8 • C hev ro n Bus iness Con d u ct a n d Et h i cs Cod e


Data Privacy
All employees must exercise care and discretion in handling personal data.

Personal data about our employees, customers Proper Use of Personal Data Personal data should only be processed if there
and suppliers is an important information asset. is a legitimate business reason to do so, such as
Many of us handle personal data, or information Chevron has adopted a Company-wide data complying with a legal requirement or in order to
about specific individuals. This includes data privacy policy, which sets expectations for how fulfill a contractual commitment. You should not
about employees, contractors, directors, Chevron employees handle personal data. The use more or different personal data than needed
shareholders, customers, and anyone else with policy reflects the requirements of privacy laws for the task at hand. Finally, you should keep all
whom Chevron does business. The way we handle around the world. Nevertheless, it is important personal data secure and should follow Chevron’s
this data is critical to our success and promotes to remember that where privacy laws are stricter, Information Protection policies and guidelines.
trust. In many cases, there are laws that govern Chevron must comply with those laws.
how we collect, use, and dispose of personal data. When collecting and using personal data, you
For these reasons, we must follow Company should keep several important principles in mind.
policies and guidelines for handling personal data.

Chevron respects the confidentiality of


information relating to individuals, in both paper
and electronic form. This information may not be
used or disclosed improperly or by someone who
is not authorized to so. A strong privacy policy
supports Chevron’s value of Partnership, which
reflects the trusting and beneficial relationships
we enjoy with all of our stakeholders.

Important Note: Privacy laws vary in scope


and complexity, depending on where you
are doing business. Local management must
get legal advice on privacy compliance, and
must communicate the requirements to
all employees and contractors who handle
personal data.

Chevro n Bus iness Co nduc t a nd Ethics Cod e • 1 9


Questions & Answers
Q A colleague who works for another company
asked me to provide the names of some of my
For Additional Guidance:
Corporate Policies
200: Employment
business contacts. My colleague’s company does
575: Information Protection
not compete with our Company. Is it okay to give her 580: Data Privacy
this information?

A Our client information is not only confidential


but also is considered personal data. It should not be
Additional Resources:
Questions about the appropriate use and protection of personal data can be directed to the Chevron
Law Department or Global Information Risk Management’s Privacy Office.
shared with anyone except as required or with the
Visit the Global Information Risk Management Privacy Website
permission of the business contact. If you believe (http://glirm.chevron.com/programs/dataPrivacy.aspx) and the Law Function Privacy Website
your client could use the services of your friend’s (http://lawfunction.chevron.com/law_groups/corp_law/compliance/data_privacy.asp) for privacy information.
company, you might mention it to your client and let
him or her make the contact if interested.

Q I occasionally work at home on my own


computer. I take paper and electronic files containing
customer information home with me and return the
updated electronic files back to the office. Is this okay?

A No. If you must work at home you should


be assigned a Company-issued laptop and follow
appropriate security measures. Your personal computer
should not be used to work on customer information.

20 • C hev ro n Bus iness Co nduc t a nd Ethi cs Cod e


Antitrust/Competition Laws
We always operate not only according to the letter, but also the spirit, of all applicable laws.

“Antitrust” laws, as they are called in the U.S.,


are often known internationally as “competition”
or “antimonopoly” laws. Their purpose is to help
make sure that the free market system works
properly, and that competition among companies
is fair. We must all help ensure that Chevron’s
business is always in compliance with these laws.
Most of the countries where we do business
have such laws. We are committed to complying
with antitrust laws, just as we are committed to
following all laws.

Agreements and Contacts


with Competitors
We must be very careful when we have any
contact with our competitors. Antitrust laws
prohibit any agreements with competitors that Relationships with Customers and Suppliers
might “restrain trade.” We do not want to even There are also antitrust concerns related to our customers and suppliers that could be determined to be a
create the appearance that we have entered into “restraint of trade.” Your local Chevron counsel will be able to advise you on the areas of your business
any such agreement. Even communications with that raise concerns.
competitors that feel completely innocent might
give rise to accusations.
Consequences of Violations
Exchanging any information with a competitor can The consequences of violating antitrust/competition laws can be extremely serious for Chevron and its
also give rise to concerns, and it is best to get advice employees. Violations can lead to fines and imprisonment for the individuals involved and to heavier
from your local Chevron counsel before you do so. fines for the Company. In addition to criminal prosecution, we may be subject to very costly civil suits
For this reason, membership in trade associations as well.
must be approved by management in advance.
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 counsel.

C hevro n Bus iness Co nduc t a nd Ethics Cod e • 2 1


Questions & Answers

Q I just received some confidential information about a competitor. I didn’t ask for it, but this kind of
information could be very useful to me. What should I do?

A Before you read or photocopy this information, call the legal department to discuss how the information
was acquired. That will determine whether or not you may use it. If you are allowed to use it, follow the legal
department’s instruction for documenting the source of the information.

Q I have the opportunity to interview someone who currently works for the competition for a position
at our Company. Is it okay to take the opportunity to ask about how the competitor conducts certain aspects of
their business?

A No. Focus on interviewing the person for the position, not on gathering information.

For Additional Guidance:


Corporate Policy
426: Collaborations with Competitors

22 • C hev ro n Bus iness Co nd uc t a nd Ethi cs Cod e


Government Affairs and Political Involvement
Chevron conducts its participation in the political arena according to the highest ethical standards.

In the course of doing business around the world, Providing Gifts to Public Officials Making Political Contributions
Chevron interacts regularly with government
officials. How we conduct ourselves with Under certain circumstances Chevron may provide Political contributions by the corporation
governments and in the political arena can affect gifts to U.S. public officials. Such gifts must always concerning elections of any kind, whether
our reputation, our operations around the world, be in strict compliance with the law, Company monetary or non-monetary (such as allowing
and our ability to work with government officials policy, and the values of The Chevron Way. an employee to work on a campaign while on
and other stakeholders. The Trust that we depend Company time) must be planned, budgeted,
We must seek guidance from Chevron’s Law legally reviewed and approved in advance by
upon from both local and global communities and Department before committing to provide any
governments is essential to our business, and we PGPA, internal and external legal counsel, and in
gifts to U.S. public officials. These include elected certain cases by the Office of the Chairman.
must continually earn it. and appointed officials at the local, state and
Our activities must meet the highest ethical federal levels, as well as government employees
such as public safety officers and public university
Engaging in Political Activities on Our Own
standards and comply with all host government
laws and rules. In all instances, it is imperative for professors. Laws regulating “gifts” typically Chevron encourages us to participate in the
employees to seek proper guidance and obtain the define that term as anything of value, including political and governmental process and, when
required approvals before engaging in government meals, gift certificates, travel expenses, event permitted by a country’s laws and customs, to
or political activities. tickets or honoraria, etc. Any payment made to communicate our personal views to appointed
a third party on behalf of a public official, such and elected officials. However, we cannot identify
as a payment to a hotel for a hotel room used by ourselves as representatives of Chevron or any of
Engaging in Lobbying Activities a public official, is considered a gift to the public its affiliate companies.
Lobbying is an activity aimed at influencing official. Certain gifts may be prohibited by law,
public policy decisions by providing information create reporting obligations, or create conflicts Under no circumstances will the Company
to elected or appointed officials and their of interest. U.S. laws regulating gifts to public reimburse any employee for making a personal
staff. Lobbying activities include both direct officials apply even when the officials are outside political contribution.
communication with public officials and the U.S. For example, U.S. federal law applies
Employees may not engage in personal political
providing support to any person who engages in to the gift of a meal given to a U.S. embassy
activities during paid working hours or when using
such communication. employee outside the U.S.
Company resources (such as email, phone and
Lobbying activities, in the U.S. and elsewhere, are Gifts to non-U.S. officials require advance meeting rooms) without receiving pre-approval
strictly regulated. Prior to engaging in lobbying approval from your Reporting Unit’s Compliance since such activities may be an illegal political
activities, any employee or director must obtain Coordinator or the Corporate Compliance office. contribution by Chevron. Employees must seek
guidance from their local Policy, Government and guidance from their local PGPA manager.
Public Affairs (PGPA) manager.

Chevro n Bus iness Co nduc t a nd Ethics Co d e • 23


Questions & Answers
Q I attended a campaign fundraiser for a
congressman and I’m confident that the Company
Q A government official is coming to speak to
our department about a public policy issue of interest
would like to see him re-elected. I wrote a personal to our Company. I’d like to give him a gift certificate to
check to the congressman’s campaign committee and thank him for his time. May I do this?

A
included the amount in my expense report. Will the
Company reimburse me for this expense?
For U.S. officials, you must seek guidance

A No. If the Company reimburses you for the


contribution, the Company will be the source of
from the Political Law Counsel (Corporation Law)
or the Political Programs Coordinator (PGPA) prior
to providing the gift. For non-U.S. officials, you
the contribution, which would violate U. S. law. In must seek guidance from your local legal counsel,
addition, Company policy requires that all campaign compliance coordinator, or Corporate Compliance
contributions in the U.S. must be planned and budgeted prior to providing the gift.

Q
and have several specific legal and management
approvals prior to making the contribution. Outside Additional Resources:
A co-worker of mine uses Company e-mail to
the U.S., political contributions undergo a rigorous • Within the U.S., consult the Political Law
solicit votes and financial support for his sister, who is
review and approval process. Counsel (Corporation Law) or the Political
running for a local political office. Is this acceptable? Programs Coordinator (PGPA).

A No. Company resources may not be used for


political purposes.
For Additional Guidance:
Corporate Policies
• Outside the U.S., contact Chevron’s Policy,
Government and Public Affairs personnel
in the host country. Also consult your local
320: Government Affairs Chevron legal counsel associated with your
322: Political Contributions Reporting Unit or Business Unit.
324: Payments to Public Officials For additional information visit PGPA’s web site
at: http://pgpa.chevron.com/

24 • C hev ro n Bus iness Co nd uc t a nd Ethi cs Cod e


Multinational Operations
Chevron operates, we respect and comply with the local laws and regulations.

Wherever Chevron operates, we must respect and Complying with International Trade Laws For example, anti-boycott laws in the United
conform to each country’s unique set of customs States penalize U.S. companies if they participate
and business practices. We must also follow its Laws that apply to Chevron operations outside the or cooperate with international boycotts not
laws and regulations. United States include certain United States laws supported by the U.S. U.S. anti-boycott laws also
which govern international operations of a U.S. require these companies to report any request to
When business transactions involve more than Company and U.S. persons, but may also include participate or cooperate in such a boycott. Any
one country, we must find the best way to comply the local laws of countries where our operations employee receiving a request of this sort should
with the laws and follow the customs of one occur. Many countries have laws restricting, or inform Chevron legal counsel immediately.
country without violating the laws or customs otherwise require licensing for, the export and/
of another country. Whenever a possible conflict or import of certain goods and services to other
of laws situation arises, we should always seek countries and to certain parties. Countries may
guidance from our organization’s counsel. also impose various kinds of trade sanctions
against other countries or groups of persons.
Bribery Is Always Prohibited The scope of these trade sanctions and embargoes
Bribery of any government official in any country may vary widely from country to country. They
is strictly against Chevron policy, even if the may range from specific prohibitions on trade in
refusal to make such a payment would result in a specific commodity to a total prohibition of all
the Company losing a business opportunity. commercial transactions. Due to the complexities
of the legal requirements under many of these
Almost every country prohibits the bribery of its international trade laws, we must seek guidance
own officials. In addition, many countries have from Chevron’s legal counsel before exporting, or
laws that make it illegal to bribe officials of other importing goods or services, or transactions that
countries. In the U.S., that law is the Foreign might be affected by trade sanctions.
Corrupt Practices Act (FCPA). Employees with
duties involving trade or travel outside of the U.S. Understanding Anti-Boycott Laws
must be familiar with this act.
Some countries have adopted laws prohibiting
Management approval is required before any gift their people and businesses from participating
or payment can be made to a government or public in or cooperating with international trade
official. In some cases, the gift or payment must also embargoes or sanctions that have been imposed
be approved by your Reporting Unit’s Compliance by other countries.
Coordinator or Corporate Compliance.

Chevro n Bus iness Co nd uc t a nd Ethics Co d e • 25


Questions & Answers

Q I’m planning to host government officials


involved in a business deal with the Company at a
Q I recently met an agent who can assist our
Company in obtaining business in a country where
lunch meeting. Is this allowable under the FCPA? it has been particularly difficult for us to become

A
established. May I engage this agent on behalf of our
Company?
A reasonable cost for a normal business lunch
meeting may not be prohibited under the FCPA, but
is subject to pre-approval by your local Compliance
Coordinator or depending on amount, pre-approval
A Speak with your local Chevron Law
Department and local compliance coordinator to
from your Reporting Unit or Corporate Compliance. ensure that the agent’s contacts and methods are

Q
aligned with both local and U.S. laws. Due diligence
is critical because our Company cannot avoid legal
A port official has told me it will take weeks to
liability by avoiding the facts or by acting through an
deliver materials to a work site unless a payment is
agent or other third-party.
made to help him “expedite” our shipment. Should I
comply with his request?

A No. This payment likely violates the FCPA,


unless the payment qualifies as an allowable
For Additional Guidance:
Corporate Policy
324: Payment to Officials
facilitating payment under the law. This is a legal
determination and you must review the arrangement
with your Chevron legal counsel as well as your Additional Resources:
compliance coordinator before agreeing to make any http://lawfunction.chevron.com/law_groups/corp_law/compliance
payments to government officials.

26 • C hev ro n Bus iness Co nduc t a nd Ethi cs Cod e


Human Rights Statement

Chevron’s Human Rights Statement


Chevron’s values are the foundation of our business. As expressed in the Chevron Way, we conduct our business
reaffirms our long-standing support for in a socially responsible and ethical manner. We support universal human rights, which benefits both our
employees and the communities in which we operate. We condemn human rights abuses.
universal human rights. It is grounded
in The Chevron Way, and it provides Although governments bear primary responsibility for safeguarding human rights, we believe that companies can
play a positive role in contributing to the protection and promotion of human rights. To that end, we engage
guidance to our employees and acts as with key stakeholders — including representatives of governments and civil society — on these issues. We work
a framework for constructive dialogue actively to conduct our global operations in a manner consistent with human rights principles applicable to
business. This includes recognizing and respecting the relevant ideals expressed in the Universal Declaration of
with stakeholders. Chevron’s position on Human Rights.
human rights is clearly laid out in our
In particular, Chevron is committed to supporting human rights:
Human Rights Statement. • for our Employees. We treat our employees with respect and dignity. We adhere to all applicable
domestic laws, and to the internationally accepted labor principles articulated in the International Labor
Organization’s Declaration on Fundamental Principles and Rights at Work and in the Global Sullivan
Principles. These include prohibiting child labor, forced labor, and discriminatory behavior, as well as
recognizing the rights to freedom of association and collective bargaining. We prefer business partners that
treat their employees similarly.
• in the many Communities in which we operate around the world. We value and respect the cultures
and traditions of the many communities in which we work. We consult actively with a diverse range of
knowledgeable stakeholders to build upon our understanding of the human rights issues present in our
operating environments.
• in ensuring Security for our operations. We provide security in a manner consistent with the Voluntary
Principles on Security and Human Rights. When we operate in locations where there is conflict, our
primary responsibility is to preserve the safety of our employees. To the extent feasible, we seek to benefit
the communities in these conflict areas.

Wherever we operate, we will use this Statement as a framework to guide our decision-making and constructive
engagement on human rights issues.

Additional Resources:
http://humanrights.chevron.com/

Chevro n Bus iness Co nduc t a nd Ethics Co d e • 27


Closing Note

Chevron’s 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
the way we do 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, Chevron’s legal counsel or
the Chevron Hotline. The Company’s 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
Company’s 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.

28 • C hev ro n Bus iness Co nduc t a nd Ethi cs Cod e


Chevron Corporation
Corporate Compliance Office
6001 Bollinger Canyon Rd.
San Ramon, CA 94583
corpcomp@chevron.com