Ethics

We have an unwavering commitment to high ethical standards and responsible operations everywhere we do business.

Imperial is committed to meeting all applicable government laws, rules and regulations. Our Standards of Business Conduct outline policies and guidelines on such matters as ethics, conflict of interest, health and safety, environmental protection, equal employment opportunity and harassment in the workplace.

Employees and directors are required to fully comply with the Standards of Business Conduct. Each year, employees confirm that they have read and are familiar with the policies set forth in our Standards of Business Conduct, which include a Code of Ethics and Business Conduct to prevent bribery and corruption. It includes clear guidance on ethics, gifts and entertainment, conflicts of interest, antitrust, and directorship policies. Responsibilities for authorizing, approving and recording financial transactions are appropriately segregated to reduce risks.

The Standards are also reflected in contracts with suppliers and customers. The standards are used to define how business should be conducted. Every four years, we conduct business practices reviews, which involve employees in discussions of various business practice scenarios to illustrate cases of policy violations. These scenarios include our policies against harassment and discrimination in the workplace.

Bribery and corruption
As an affiliate of ExxonMobil, Imperial Oil follows ExxonMobil’s Anti-Corruption Legal Compliance Summary, which lays out policies for employee business relationships with consultants, contractors, agents and joint ventures to ensure compliance with the U.S. Foreign Corrupt Practices Act (FCPA) and global anti-corruption conventions. In compliance with the FCPA, Imperial employees are prohibited from making improper payments to, or improper transactions with, Canadian government officials, whether federal, provincial or municipal, to influence the performance of their official duties.

Under the FCPA, Imperial is required to maintain adequate internal controls and to keep accurate and complete records of the transactions in which we engage. Imperial has a thorough compliance program, which enforces the policies through management controls and practices, as well as rigorous internal and external audit functions.

Internal audits
On average, our internal audit department conducts annual audits of a third of our operating units. Approximately 23 trained internal auditors have unrestricted access to all facilities, business units, personnel and records and investigate potential non-compliances with our Standards of Business Conduct.

Reporting and investigating suspected violations
Employees are encouraged to raise any issues, questions or concerns with their managers or human resources advisers. The company has also set up a confidential ethics hotline and mailbox for employees. Correspondence is handled by a Hotline Steering Committee, made up of security, audit, law and human resources personnel, and reported to the Audit Committee on a quarterly basis. We expect persons responding to employee questions, concerns, complaints and suggestions to use discretion to maintain confidentiality and protect anonymity to the greatest extent possible. No action can be taken or threatened against any employee for asking questions, voicing concerns, or making complaints in conformance with company procedures.

Suspected violations are identified through internal control procedures, supervisory reviews, hotline calls, and employee or third-party tips. Internal auditors and management investigate suspected violations of law, business practices or internal control procedures. Violations by employees lead to disciplinary actions up to and including separation from the company. Significant matters are reported to the Audit Committee of the Board. The board makes no exception for cases involving an executive officer or director.