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Business ethics

The policy of Exxon Mobil Corporation is one of strict observance of all laws applicable to its business.

The Corporation's policy does not stop there. Even where the law is permissive, the Corporation chooses the course of the highest integrity. Local customs, traditions, and mores differ from place to place, and this must be recognized. But, honesty is not subject to criticism in any culture. Shades of dishonesty simply invite demoralizing and reprehensible judgments. A well-founded reputation for scrupulous dealing is itself a priceless company asset.

Employees are told that they must understand that the Corporation does care how results are obtained, not just that they are obtained. Employees are encouraged to tell higher management all that they are doing, to record all transactions accurately in their books and records, and to be honest and forthcoming with the Corporation's internal and external auditors. The Corporation expects employees to report suspected violations of law or ExxonMobil policies to company management.

The Corporation expects compliance with its standard of integrity throughout the organization and will not tolerate employees who achieve results at the cost of violation of laws or who deal unscrupulously. The Corporation supports, and expects you to support, any employee who passes up an opportunity or advantage that would sacrifice ethical standards.

Equally important, the Corporation expects candor from managers at all levels and compliance with ExxonMobil policies, accounting rules, and controls. One harm which results when managers conceal information from higher management or the

auditors is that subordinates within their organizations think they are being given a signal that company policies and rules can be ignored when they are inconvenient. This can result in corruption and demoralization of an organization. The Corporation's system of management will not work without honesty, including honest bookkeeping, honest budget proposals, and honest economic evaluation of projects.

It is ExxonMobil's policy that all transactions shall be accurately reflected in its books and records. This, of course, means that falsification of its books and records or the creation or maintenance of any off-the-record bank accounts is strictly prohibited."

Antitrust

It is the policy of Exxon Mobil Corporation that all of its directors, officers, and employees shall, in carrying out their duties to the Corporation, comply with the antitrust and competition laws of the United States and with those of any other country or group of countries which are applicable to the Corporation's business.

No director, officer, or employee should assume that the Corporation's interest ever requires otherwise. Moreover, no one in the Corporation has authority to give any order or direction that would result in a violation of this policy.

It is recognized that, on occasion, there may be legitimate doubt as to the proper interpretation of the law. In such a circumstance, it is required that the directors, officers, and employees refer the case through appropriate channels to the Law Department for advice.

Conflict of interest

Exxon Mobil Corporation's policy requires that directors, officers, and employees avoid any conflict between their own interests and the interests of the Corporation in dealing with suppliers, customers and other third parties, and in the conduct of their personal affairs, including transactions in securities of the Corporation, any affiliate, or any nonaffiliated organization.

It is also a conflict of interest for an employee, during or subsequent to employment and without proper authority, to give or make available to anyone, or use for his/her own benefit, information of a confidential nature derived from his/her employment.

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