Student proposed Corporate Compliance Plan

1. Management Team # 1
Julia Dubois
Darlene Fernandez
Ricardo Flores
Jacquelyn Johnston
Melanie Sanchez
Corporate
Compliance
Plan

2. Mission Statement
Exxon-Valdez Subsidiary’s mission is to provide and promote the
delivery of the highest quality petroleum in a safe and efficient
manner which creates value and benefit not only to its
shareholders but its stakeholders, employees, and the community
and greater environment in which it operates.

3. Code of Conduct
Who must follow the code of conduct?
 Every employee, manager, director and independent contractor
of Exxon-Valdez
How can the code of conduct help you?
 If you are faced with a situation where you are concerned about
how to respond, you can turn to the Code of Conduct as the first
resource
Who can you go to with questions?
 The Code of Conduct will be regulated and enforced by an
independent Compliance and Ethics Committee

4. Code of Conduct
What to do if you see a violation?
 Protecting our Company’s reputation is the responsibility of every
employee, manager and director in every location
 If you see or suspect that something is illegal or unethical, you have
the obligation to speak up and share your concerns
 You can directly report the illegal or unethical behavior to your
immediate supervisor, a Human Resources official, a member of the
Compliance and Ethics Committee, a Compliance Officer or to our
Compliance and Ethics Hotline at (888) GO-EXXON
 If you are concerned with providing your identity, all concerns or
information provided through the hotline can be made
anonymously

5. Statement of Values
At Exxon-Valdez, all employees, managers and directors
should share a common set of values which include
honesty, integrity and respect. These values apply to all
relationships with Exxon-Valdez employees, customers and
contractors. In addition, Exxon-Valdez values the trust and
the safety of its employees and environment.

6. Risk Assessment
Risk assessment is important because it protects:
 Exxon-Valdez’ Reputation
 Conduces an environment where employees act with Honesty,
Integrity, & Dependability
 Protects the Environment and the health and safety of all

7. Emergency Training
 The Exxon-Valdez team is required to complete basic
emergency response training
 Training is conducted in compliance with national training
including FEMA courses in Incident Command Systems
 Training should include online courses, in-class seminars and
quarterly drills to review sensitive procedures
 Input from all participants should be considered carefully in
order to improve future trainings and reduce the number of
unforeseen possibilities in the future

8. Oversight
 Standards and procedures will allow Exxon-Valdez to reinforce
its compliance program and code of conduct and ensure its
effectiveness
 This is an ongoing effort involving the entire organization,
demonstrating the importance of compliance
 Exxon-Valdez commits to review and detect compliance
issues in real time and has the processes in place to quickly
remediate them when necessary.
 Exxon-Valdez’s Compliance and Ethics Committees will
promptly and carefully investigate any reports of suspected
misconduct and take corrective action when necessary

9. Acknowledge and
Incentives
 100% of the organization have to adhere to the
compliance program by signing an acknowledge
document once a year
 Compliance and ethics is an integral part of employee’s
evaluations, incentives will be given according to their
commitment to compliance
 Disciplinary measures will be considered for those who
break the compliance and ethics program. Any employee
who witnesses a violation or has first hand knowledge of an
occurrence of a violation of the Code of Conduct and
who does not report it, may also be subject to disciplinary
action.

10. Communication and
Reporting
 Quarterly compliance “newsletter” with key messages and
reminders sent to the entire organization
 “Compliance Hot Line” available for granting
confidentiality and anonymity to raise concerns or seek
guidance regarding potential or actual incidents (888)
GO-EXXON
 Zero Tolerance to retaliation - no retaliation policy in place
 Periodic compliance program status will be reported to
the board

11. Evaluation and Auditing
 Periodic evaluation of program’s effectiveness to question
whether the company's employees are adhering to the
compliance program
 Identification of gaps on a regular and consistent basis
 Specific business component’s auditing activities to detect
criminal conduct will be followed in a particular timeframe
particularly in financial records

12. Leadership
 Exxon-Valdez’ management team is expected to use the
Code of Conduct as a tool to strengthen the relationship
between Exxon and its employees
 The management team leads by example, following Exxon-
Valdez’ procedures to create a safe work environment
 Exxon-Valdez’ management team must create an
environment that will reinforce its values of integrity, respect
and trust
 Each leader is expected to create an open line of
communication amongst employees of all departments and
layers to ensure Exxon operates to its highest level of efficiency,
increasing profit and minimizing risk

13. Mitigating Risk
 The management team must work closely with Human Resources
to ensure that Exxon-Valdez’ code of conduct is followed and
reinforced throughout the company
 Exxon-Valdez’ management team is expected to communicate
potential risk with each designated department in an effort to
conduct business in a safe environment that abides by
regulations and company policies

14. Public Disclosure
 Public disclosure will occur according to all
applicable laws
 Disclosures only to be made by authorized
representatives of Exxon-Valdez
 Any and all information to be disclosed must be
verified for accuracy and must determine if
information is complete and correct
 If an employee is in possession of information,
they are obligated to report to their supervisor
immediately with the information