On February 13, 1997, the Board of Directors adopted a comprehensive Code of Business Conduct applicable to all directors, officers and employees. The Code reaffirms Oxy’s commitment to high standards of ethical conduct and embodies Oxy’s business ethics, policies and procedures. As subsequently amended it includes Oxy's policies concerning, among other things, compliance with laws, rules and regulations (including insider trading laws), conflicts of interest (including corporate opportunities), protection of corporate assets and human rights.
As stipulated in our Code of Business Conduct, Oxy has a strict policy against bribery and corruption. We conduct due diligence on prospective business partners, contractors, suppliers and agents as part of our Code of Business Conduct and Human Rights Policy compliance programs. 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 human rights training sessions and risk assessments.
In addition to the Chief Compliance Officer and Corporate Compliance Counsel, Oxy has regional Segment Compliance Officers who monitor anti-corruption policies and procedures, as well as compliance with the Human Rights Policy and other company policies, at their respective business locations.
Key Oxy employees such as officers, attorneys, managers and other employees identified by Oxy’s Compliance Officers participate in mandatory Code of Business Conduct training. In addition to online training, Oxy’s Compliance Counsel and Compliance Officers periodically conduct live training sessions at our global business locations. In 2011, more than 2,350 employees received their scheduled training in online or live sessions covering key provisions of the Code.
The Code explains the various ways that questions or concerns may be raised throughout Oxy, including reporting to supervisors, contacting specified Compliance Officers or using a toll-free compliance hotline. The Audit Committee of the Board is responsible for monitoring compliance with the Code of Business Conduct.
Oxy thoroughly investigates any credible report of suspected bribery or corruption, or other policy violations. All officers, attorneys and managers are required to certify annually whether they are aware of any non-compliance with Oxy’s Code of Business Conduct. More than 7,400 employees submitted annual compliance certifications for 2011. Oxy’s internal audit department investigates business units for compliance on a risk-based schedule.
The Code of Business Conduct also outlines Oxy’s policy with respect to political contributions and lobbying activities. Consistent with the policy, a non-partisan Political Action Committee, OXYPAC, was organized to provide an opportunity for Oxy employees to participate in that arena if they choose.
Funded entirely by employees’ personal, voluntary contributions, OXYPAC contributes to qualified candidates and multicandidate committees, regardless of party affiliation, who share the interests of our company, our employees, our stockholders and the communities in which we operate. OXYPAC activities are transparent and comply with applicable laws. OXYPAC disclosure reports are publicly available on the Federal Election Commission website at www.fec.gov.