Code of Business Conduct
??In February, 1997, the Board of Directors adopted a comprehensive Code of Business Conduct applicable to all directors, officers and employees. The Code, which has been amended and updated several times in the past 20+ years, reaffirms Oxy's commitment to high standards of ethical conduct and embodies Oxy’s business ethics, policies and procedures. The Code includes Oxy’s policies concerning, among other things, compliance with laws and regulations (including antitrust, anti-bribery and insider trading laws), conflicts of interest (including corporate opportunities and assets), political contributions and lobbying, human rights and protecting health, safety and the environment. On September 1, 2020, the Code was updated to address Oxy’s expanded operations and to include emerging compliance areas, such as data privacy and use of company information systems.
Oxy has a strict policy against bribery and corruption. We conduct due diligence on prospective business partners, contractors, suppliers, agents and other counterparties as part of our Code and anti-corruption compliance program. We encourage these third parties to review the Code, and we include specific anti-bribery contract provisions as appropriate. These topics also are covered in training sessions and contract reviews.
The Audit Committee of the Board oversees Oxy’s compliance program. In addition to the Chief Compliance Officer and the Director of Ethics and Compliance, Segment Compliance Officers are assigned to a region or specific business unit to monitor compliance with anti-corruption, human rights, and other company policies and procedures. Oxy’s Internal Audit Department, with the assistance of computer data analysis tools, evaluates business units for internal controls, policy compliance and fraud prevention.
New employees receive an electronic copy of the Code and are required to acknowledge they have reviewed and understand the Code during onboarding training. Oxy’s Compliance Officers also periodically conduct live and virtual training sessions for our global business locations. All employees must certify annually whether they are aware of non-compliance with the Code or with other company policies.
The Code explains the many ways that questions or concerns may be raised throughout Oxy, including reporting to supervisors, the Human Resources Department, Compliance Officers, the Chief Compliance Officer or the Corporate Compliance Committee. In addition, employees may use an anonymous toll-free compliance hotline or web reporting option, both of which are managed by an independent third party.
Oxy investigates all credible reports of suspected policy violations. Oxy does not tolerate threats or acts of retaliation for raising a concern in good faith or cooperating in an investigation. All forms of retaliation are prohibited.