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The Company has well-established “Standards of Business Conduct” consisting of various policies and guidelines that apply to all officers and employees. Officers and employees are expected to review these policies annually and provide written confirmation of compliance. Formal business practice reviews are conducted periodically for all officers and employees to ensure an even greater understanding of these standards. In addition, periodic training sessions are held on specific policies. For example, the Company provides annual training on the anti-corruption policy to employees in designated positions.

The Standards of Business Conduct contain 17 foundational policies as follows:

The Company is committed to the highest standards of business conduct and rigorous anti-corruption compliance. We adopt the Anti-Corruption Legal Compliance Guide of Exxon Mobil Corporation which outlines a commitment to comply with the U.S. Foreign Corrupt Practices Act (FCPA), the United Kingdom Bribery Act, and global anti-corruption standards. It also describes elements of the Company’s anti-corruption compliance program. Employees and contractors acting on behalf of the Company are strictly prohibited from making payments to or engaging in transactions with government officials to improperly influence the performance of their official duties.

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