The Board of Directors adopted the following policy on February 14, 2008:

Any compensation consultant engaged by the Executive Compensation and Human Resources Committee of the Board (the “Committee”) in connection with the discharge of the Committee’s duties and responsibilities shall be independent. For purposes of this Policy, a consultant shall be considered independent if:

a. The individual consultant, and the firm or other organization employing such consultant, does not currently provide, has not for the past 24 months provided, and will not in the next 12 months provide executive compensation services of any kind to Occidental and its affiliates or to any of the executive officers of Occidental, other than to the Executive Compensation and Human Resources Committee; and

b. Any consultant firm or organization which is part of an affiliated group shall not be independent for purposes of this Policy in the event that such affiliates, in the aggregate, have been or are paid by Occidental and its affiliates for services rendered other than to the Executive Compensation and Human Resources Committee by affiliates of the individual compensation consultant firm or organization in an amount which exceeds 1 percent of the affiliated group’s consolidated gross revenues during these time periods

Any compensation consultant to be employed by the Committee shall be given a copy of this Policy and must certify in writing that the consultant is independent pursuant to this Policy. Such certification is to be made prior to commencement of work by the consultant and annually thereafter during the period of engagement.

Management shall inform the Committee if it engages any affiliate of a consultant firm or organization to provide services to Occidental and its affiliates, and any such engagement shall comply with the independence standards established by this Policy.