Integrity and Ethics

Maintaining Ethical Standards in Reserves

Reserve estimation requires a rigorous process based on the selection of appropriate estimation methods, use of best geologic and engineering judgment, and review by experienced professionals. To reinforce ethical decision making and maintain recommended practices, Occidental developed and launched the Reserves Ethics training course in May 2012. This web-based program consists of case studies where trainees learn from real situations. More than 370 employees successfully completed Occidental’s Reserves Ethics training course in 2015.

Occidental and its Board are committed to high standards of ethical conduct. The company's Code of Business Conduct (Code) affirms that commitment and reinforces our business ethics, policies and procedures. The Company's Board of Directors adopted the Code and designated the Audit Committee to ensure that the Company maintains appropriate ethics and compliance policies and procedures. The Chief Compliance Officer, with the advice and support of a Corporate Compliance Committee and oversight by the Audit Committee, is responsible for the implementation and enforcement of the Code. In addition to the Chief Compliance Officer and Director of Corporate Compliance, Segment Compliance Officers are assigned to a region or specific business unit to conduct periodic training and monitor compliance with anti-corruption, human rights and other related policies and procedures.

To ensure compliance with our policies, once hired, all new employees receive a copy of the Code and are required to acknowledge that they have reviewed and understand it. The majority of employees also receive periodic training and guidance on the Code. In addition to online training, Occidental's Compliance Officers conduct live training sessions at our global business locations, as appropriate. In 2015, more than 1,300 employees completed the required training covering key provisions of the Code in live or online sessions.

The Code explains the many ways that questions or concerns may be raised throughout Occidental, including reporting to managers/supervisors, Compliance Officers or the Audit Committee. In addition, employees may ask questions or raise concerns anonymously by calling or submitting a web-based report to the company's Integrity Helpline, which is operated by an independent third-party vendor. Occidental has a strict policy prohibiting retaliation against any employee who reports a suspected violation in good faith.

Occidental investigates all credible reports of suspected policy violations, including allegations of bribery and corruption. Occidental's internal audit department, with the assistance of computer data analysis tools, evaluates business units for internal controls, policy compliance and fraud prevention. Furthermore, all employees must certify annually whether they are aware of any non-compliance with the Code or with other company policies. For 2015, more than 12,900 employees submitted an Annual Statement of Compliance and Code of Business Conduct Acknowledgement.