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 15 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.
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 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 training sessions and contract reviews.
The Audit Committee of the Board oversees Oxy’s Compliance Program. In addition to the Chief Compliance Officer and Corporate Compliance Counsel, Segment Compliance Officers are assigned to a region or specific business unit to monitor compliance with anti-corruption, Human Rights, and other related policies and procedures.
New employees receive a copy of the Code and are required to acknowledge that they have reviewed it. The majority of employees also participate in mandatory Code training upon hiring, and periodically thereafter. In addition to online training, Oxy’s Compliance Counsel and Compliance Officers conduct live training sessions at our global business locations. In 2012, approximately 10,000 employees received their scheduled training in live or online sessions covering key provisions of the Code, bringing the total number of Code training sessions to nearly 16,500 since 2009.
The Code explains the many ways that questions or concerns may be raised throughout Oxy, including reporting to supervisors, Compliance Officers 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, including allegations of bribery or corruption. All employees who are required to participate in Code training also must certify annually whether they are aware of any non-compliance with the Code or with other company policies. More than 9,700 employees submitted annual compliance certifications for 2012. Oxy’s internal audit department, with the assistance of computer data analysis tools, evaluates business units for internal controls, policy compliance and fraud prevention.