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In this article

Supplier expectations

 * Supplier expectations
 * Regional controls advisor directory
 * Language translations / country-specific

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8 min read

• Nov. 11, 2024
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2024 YEAR END SUPPLIER COMMUNICATIONS

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8 min read

• Nov. 11, 2024


IN THIS ARTICLE

Supplier expectations

Regional controls advisor directory

Language translations / country-specific

Thank you for being a valued supplier of Exxon Mobil Corporationi.

We regularly undertake a thorough review of our business practices and those of
our affiliates. As part of the review process, we believe it is important to
communicate to our goods and services suppliers our expectations for the proper
conduct of business activities with, or on behalf of, ExxonMobil. As guided by
our long-standing Ethics Policy and other policies in our Standards of Business
Conduct, our goal is to ensure we conduct our business in accordance with the
highest standards. In turn, we expect our suppliers are committed to similar
standards. Our standards cover safety, contract awards, personal business
behavior, compliance with all applicable laws, adequate internal controls and
the proper recording and reporting of all transactions.

SUPPLIER EXPECTATIONS

As stated in the ExxonMobil Supplier Expectations, it is expected that
ExxonMobil and our suppliers will comply with all applicable laws, and all
financial settlements, reports and invoicing will correctly reflect the business
transactions between us. Specifically, we expect:

 * Compliance with the anti-corruption, antitrust, and trade laws of the United
   States and every other country in which operations are conducted.
 * No one at ExxonMobil is authorized to ask your organization to take any
   action on our behalf that is contrary to applicable law or ExxonMobil
   policies, including our Anti-Corruption, Antitrust, and International
   Operations Policies.
 * No ExxonMobil employee or supplier is authorized to make an improper payment,
   including facilitating payments to any employee, official, agent, or
   instrumentality of any government, commercial entity, or individual in the
   conduct of ExxonMobil activity or business.

GIFTS AND ENTERTAINMENT POLICY

Another key standard is our policy on the giving and receiving of gifts and
entertainment. Those parties conducting business with, or on behalf of,
ExxonMobil are expected to exercise good judgment in each case. The provision of
gifts and entertainment must not be intended to create an improper advantage.

 * Our employees are restricted from receiving gifts or favors that exceed a
   nominal value or receiving any extravagant or frequent entertainment from
   individuals, companies or firms who do business, or seek to do business with
   us.
 * Likewise, while we do not envision any gifts would be made to third parties,
   you should be equally prudent on the rare occasion you might provide
   appropriate gifts or entertainment to third parties when conducting business
   on behalf of ExxonMobil.
 * If you have not already done so, please ensure you adopt adequate safeguards,
   and you have policies, procedures and/or controls in place to ensure your
   activities related to commercial interactions and interactions with
   government officials fully comply with applicable anti-corruption laws and
   the expectations of ExxonMobil outlined above.

RESPECTING HUMAN RIGHTS

ExxonMobil is committed to respecting human rights, and we expect the same of
our suppliers. Our Supplier Expectations with regards to human rights include
conducting operations and business practices, as well as managing activities, in
a manner consistent with the following key international human rights
frameworks:

 * the International Labour Organization’s 1998 Declaration on Fundamental
   Principles and Rights at Work, covering elimination of child labor, forced
   labor, workplace discrimination, recognition of freedom of association, and a
   safe and healthy work environment; and
 * the United Nations Guiding Principles on Business and Human Rights (UNGPs) in
   effect as of 2011.

PRODUCTIVE WORK ENVIRONMENT

ExxonMobil is committed to a safe, healthy and productive work environment for
our employees, contractor employees and others who access ExxonMobil property,
sites and facilities. Our expectation is that you have and enforce an alcohol
and drug program that, at a minimum, meets the requirements set forth in the
agreement1. Elements of an acceptable contractor’s program should include, but
are not limited to the:

 1. Prohibition, while on company premises (including off-duty time) of
    contractor personnel use, possession, sale, manufacture, distribution,
    concealment or transport of any prohibited substance, which would include
    alcohol and potentially impairing medications used without a prescription or
    in a manner inconsistent with the prescription or directions for usage
    (e.g., some prescription drugs or over-the-counter medications or herbal
    medicines).
 2. Prohibition of any (1) drug or alcohol-related paraphernalia used or
    designed for use in testing, packaging, storing, injecting, ingesting,
    inhaling or otherwise introducing into the human body any prohibited
    substance, (2) paraphernalia or substance used or designed for use to
    dilute, substitute or adulterate any alcohol or drug test specimen or to
    otherwise obstruct the alcohol or drug testing process.
 3. Removal of contractor personnel from company activities following
    non-compliance with any aspect of the contractor program or the requirements
    set forth in the alcohol and drug exhibit in the agreement.
 4. Commitment to comply with all applicable drug and alcohol-related laws and
    regulations.

Concerning the alcohol and drug test panel (including screening and confirmation
cutoff levels) – if any - specified by the Alcohol and Drug Exhibit of your
agreement with ExxonMobil, the following must be complied with:

A. For agreements containing the Alcohol and Drug Exhibit requiring that alcohol
and drug testing, at a minimum, be compliant with the U.S. DOT panel, you may
elect to use 1) a panel that meets the U.S. DOT drug panel, 2) a panel that
exceeds the U.S. DOT drug panel or 3) the ExxonMobil drug panel, except to the
extent any of these panels is preempted by local law.

B. For agreements containing the Alcohol and Drug Exhibit requiring that alcohol
and drug testing, at a minimum, be compliant with the ExxonMobil panel, you may
elect to use 1) the ExxonMobil panel or 2) a panel that exceeds the ExxonMobil
panel (including screening and confirmation levels), except to the extent either
of these panels is preempted by local law.

This information is offered only to clarify the relevant language in your
existing agreement(s) and does not create any additional contractual obligation.
Capitalized terms should be understood as those terms are defined in the
relevant A&D Exhibit.

PROVIDING GOODS AND SERVICES

While you may be organized outside of the United States, it is imperative that,
in providing goods and services to ExxonMobil affiliates worldwide, you not deal
with any entities, organizations, persons or vessels with which a U.S. person
could not deal and that you not provide to ExxonMobil any goods or services in
which a U.S. person could not deal, for example goods manufactured or extracted
in a country subject to comprehensive U.S. sanctions.

The countries and territories currently under comprehensive U.S. sanctions are
Cuba, Iran, North Korea, Syria and the non-government controlled regions of
Ukraine. The United States also imposes comprehensive sanctions against persons,
entities and vessels on the U.S. Treasury Department Office of Foreign Assets
Control’s List of Specially Designated Nationals and Blocked Persons (“SDN”),
including any entities or vessels owned directly or indirectly, individually or
in the aggregate, 50% or more by one or more SDNs, and it imposes more limited
sanctions against Russia and Venezuela. We fully expect you to comply with any
applicable sanctions and export controls, including relevant EU, UK or other
applicable sanctions and export controls and, in providing goods or services to
ExxonMobil affiliates worldwide, we expect that you not deal with any sanctioned
party or provide to ExxonMobil any goods or services with which a U.S. person
cannot deal. Should you have any questions about which entities, organizations,
persons or vessels are sanctioned, please consult with an attorney experienced
in such matters.

DATA PROTECTION

ExxonMobil expends considerable resources protecting our data, including
defending our computer network from the increased risk of sophisticated
cyber-attacks and stewarding personal information according to regulatory
requirements.

This communication reinforces our expectation that you take appropriate steps to
protect information (electronic and hardcopy) and information systems in your
control from new and evolving risks of cyber attackers. You should maintain
appropriate data protection and cybersecurity measures based on professional
guidance and best practices.

If there are circumstances where you suspect information related to ExxonMobil
is compromised, you should promptly bring such circumstances to our attention.
Please contact us if you have any suspicions as to whether an email purportedly
from ExxonMobil is actually from our company. Also, we request that you
regularly train your personnel on cybersecurity, including training to be alert
to cybersecurity attacks that rely on personal inattention, such as “phishing”
attacks or other suspicious emails containing attachments or links that could
potentially compromise computer systems.

More and more countries around the world are adopting data protection or data
privacy laws, which regulate the collection and processing of information,
including personal information. These laws deal not only with how such
information is collected and stored, but also the purpose(s) for which it is
used. In addition, in many countries, there are also particular restrictions on
how personal information is transferred across national borders and to third
parties.

ExxonMobil is committed to protecting the personal information of our employees,
contractors, vendors, customers and other third parties with whom we deal. If
you have not already done so, please ensure you adopt adequate safeguards to
keep all personal data used pursuant to your agreement with us secure, and that
you have controls and tools in place to ensure compliance with applicable data
privacy laws.

We also ask you to be alert to the potential for Illegal Information Brokering,
where persons approach suppliers offering confidential information that is used
to obtain business through corruption of the competitive bidding process. Such
practice is illegal, and we ask that you report the occurrence of any such
incident.

It is your responsibility to communicate the expectations of the above
paragraphs to all subcontractors that work for you on ExxonMobil projects or
sites.

FINANCIAL DATA

Finally, we expect that all financial data shall be complete and accurately
recorded, and all invoices to ExxonMobil accurately reflect pricing, payment
terms and other provisions as stated in your contract with us. We are committed
that contracts and other awards are made in a fair manner. We encourage you to
contact us if you are aware of any practices that fail to meet these standards
or if you have any concerns in this regard.

For best awareness and understanding of our business standards, we expect you to
bring this communication to the attention of those within your organization who
have business contact with us or our affiliates.

Should you at any time have any questions or concerns as to the application of
these business standards, please let us know by contacting our Controls Advisor
for the applicable region*.


REGIONAL CONTROLS ADVISOR DIRECTORY

Region — Country Controls advisor Email address USA
(incl. Denbury Onshore LLC) Valencia Lee Email Valencia USA - Unconventional
(incl.Pioneer Natural Resources USA Inc.) Kenya Reeves Email Kenya Canada Talita
Páez de Souza Email Talita Argentina Jimena Turanza Email Jimena Argentina -
Unconventional Kenya Reeves Email Kenya Brazil Willy Silva Email Willy Guyana
Preya Rookhum Email Preya Europe - All Tomas Kasa (Acq.)
Gabriela Mickova (PaySo) Email Tomas
Email Gabriela Nigeria Mobolaji Orisadipe
Olusoga A Sofolahan Email Mobolaji
Email Olusoga Angola Leila M Ribeiro Email Leila Mozambique Adrian Tolman Email
Adrian Malaysia Nurshafiza Zulkefli Email Nurshafiza Australia, PNG, Indonesia
(Upstream) Worapan Yiampanichpak Email Worapan Indonesia (Downstream), India
Sonia Dayalu Email Sonia AP (China, Japan, Singapore, South Korea) Lai Li Wong
Email Lai Thailand Setthaphol Kittiyawat Email Setthaphol 

*Alternatively, you may call the ExxonMobil corporate “hot line” at either
1.800.963.9966 (inside the United States) or 1.346.335.6100 (call collect
outside the United States).


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i Corporate Separateness Notice

Exxon Mobil Corporation has numerous affiliates, many with names that include
ExxonMobil, Exxon, Esso and Mobil. For convenience and simplicity in this
communication, the short term “ExxonMobil” is used in this communication to
refer to groups of companies or to specific subsidiaries of Exxon Mobil
Corporation. For all of these, word selection may have been based on convenience
and simplicity, and may not identify reporting relationships, legal entities, or
relationships among legal entities. Nothing in this material is intended to
override the corporate separateness of local entities. Working relationships
discussed in this communication do not necessarily represent a reporting
connection, but may reflect a functional guidance, stewardship, or service
relationship.

1 For Denbury Onshore, LLC, Pioneer Natural Resources USA, Inc., or Pioneer
Water Management LLC vendors, who have not signed the new Master Services
Agreement with ExxonMobil Global Services Company, please refer to the drug and
alcohol requirements in your existing, applicable agreements.

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