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Corporate Compliance Plan
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Corporate compliance plan - Project 1

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Student proposed Corporate Compliance Plan

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Corporate compliance plan - Project 1

  1. 1. Management Team # 1 Julia Dubois Darlene Fernandez Ricardo Flores Jacquelyn Johnston Melanie Sanchez Corporate Compliance Plan
  2. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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

Student proposed Corporate Compliance Plan

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