Standards of business conduct
February 2021
The policies, principles and practices described in this booklet define standards of ethical business conduct for Imperial Oil Limited (“Imperial”), ExxonMobil Canada Ltd. and ExxonMobil Business Support Centre Canada ULC (the “ExxonMobil companies in Canada”) and their subsidiaries, affiliates and partnerships. They are fully aligned with the standards of business conduct adhered to by Exxon Mobil Corporation and set the tone for the conduct of business at all ExxonMobil locations worldwide. Imperial is 69.6 percent owned by Exxon Mobil Corporation. Exxon Mobil Corporation holds all of the voting shares of the ExxonMobil companies in Canada.
Nothing in this booklet is intended to override the corporate separateness of individual corporate entities. The terms “company,” “companies,” “affiliate,” “our,” “we” and “its” as used in this booklet may refer to Imperial and the ExxonMobil companies in Canada, and their subsidiaries, affiliates and partnerships. The shorter terms are used merely for convenience and simplicity.
Il existe une version française de la brochure. Contents
Introduction and guiding principles
2 Introduction 3 Guiding principles
Foundation policies
4 Ethics policy 5 Conflicts of interest policy 5 Corporate assets policy 6 Directorships policy 6 Gifts and entertainment policy 7 Political activities policy 7 International operations policy 8 Antitrust/competition law policy 8 Anti-corruption policy 9 Health policy 10 Safety policy 11 Product safety policy 12 Environment policy 13 Customer relations and product quality policy 14 Equal employment opportunity policy 15 Harassment in the workplace policy 16 Alcohol and drug policy
Procedures and open door communication 23 Procedures and open door communication
February 2021 | 1 Introduction
The greatest strength of Imperial and the Employees who have questions concerning ExxonMobil companies in Canada is the high any aspect of the policies contained in this quality of our directors, officers and employees. booklet should not hesitate to seek answers Their resourcefulness, professionalism and from management or the other sources dedication make our companies competitive in indicated in the section entitled “Procedures the short term and well positioned for ongoing and Open Door Communication.” success in the long term. No one in the Imperial or ExxonMobil Our directors, officers and employees are organization has the authority to make responsible for developing, approving and exceptions or grant waivers with respect to implementing plans and actions designed to the foundation policies. Regardless of how achieve corporate objectives. The methods we much difficulty we encounter or pressure we employ to attain results are as important as the face in performing our jobs, no situation can results themselves. Our directors, officers and justify the willful violation of these policies. employees are expected to observe the highest Our reputation as a corporate citizen depends standards of integrity in the conduct of the on our understanding of and compliance with companies’ business. these policies.
The policies that guide our directors, officers and employees are contained in this booklet. They are based on the foundation policies of Exxon Mobil Corporation, which have been adopted by Imperial, the ExxonMobil companies in Canada and their subsidiaries, affiliates and partnerships.
The foundation policies are reviewed periodically by the companies’ directors, officers and employees. From time to time the companies publish guidelines with respect to selected policies. Those guidelines are interpretive and administrative and are not part of the Standards of business conduct
2 | Imperial | Standards of business conduct Guiding principles
Imperial and the ExxonMobil companies Sales associates in Canada are committed to continuously achieving superior financial and operating We work to further our mutual success in the results while simultaneously adhering to high delivery of products and services of superior ethical standards. value through open and honest dealings with our sales associates. The following principles guide our relationships with our shareholders, customers, employees, Suppliers and contractors communities, sales associates, suppliers and contractors, and competitors: We select quality suppliers and contractors on the basis of best total value, considering Shareholders price, specifications, technology, reliability, safety, service, delivery and environmental We are committed to enhancing the long-term performance. Wherever possible, we value of the investment dollars entrusted to us attempt to purchase goods and services by our shareholders. By running our business from Canadian suppliers. profitably and responsibly, we expect our shareholders to be rewarded with superior Competitors returns. This commitment drives the management of our companies. We have an important stake in the maintenance of a healthy state of competition Customers in the Canadian economy. In every aspect of our business, we comply with the letter Success depends on our ability to consistently and spirit of laws governing competition satisfy ever-changing customer preferences. in the marketplace. We commit to be innovative and responsive, while offering high-quality products and Imperial and the ExxonMobil companies in services at competitive prices. Canada aspire to be at the leading edge of competition in every aspect of our business. Employees That requires our resources — financial, operational, technological and human — to be The exceptional quality of our workforce employed wisely and evaluated regularly. provides a valuable competitive edge. To build on this advantage, we strive to hire While we maintain flexibility to adapt to and retain the most qualified people available changing conditions, the nature of our business and to maximize their opportunities for requires a focused, long-term approach. We success through training and development. will consistently strive to improve efficiency We are committed to maintaining a safe and productivity through learning, sharing and work environment enriched by diversity implementing best practices. We will be and characterized by open communication, disciplined and selective in evaluating the trust and fair treatment. range of capital investment opportunities available to us. We will seek to develop Communities proprietary technologies that provide a competitive edge. We commit to be a good corporate citizen in all the places where we operate. We will maintain We aspire to achieve our goals by flawlessly high ethical standards, obey all applicable laws, executing our business plans and by adhering rules and regulations, and respect local to these guiding principles and the foundation cultures. Above all other objectives, we are policies that follow. dedicated to running safe and environmentally responsible operations.
February 2021 | 3 Ethics policy
The policy of Imperial and the ExxonMobil The companies expect candor from employees companies in Canada is to comply with all at all levels and adherence to their policies and governmental laws, rules and regulations internal controls. One harm that results when applicable to their business. employees conceal information from higher management or the auditors is that other The companies’ ethics policy does not stop employees think they are being given a signal there. Even where the law is permissive, the that the companies’ policies and internal companies choose the course of highest controls can be ignored when they are integrity. Local customs, traditions and values inconvenient. That can result in corruption and differ from place to place, and this must be demoralization of an organization. The recognized. But honesty is not subject to companies’ system of management will not criticism in any culture. Shades of dishonesty work without honesty, including honest simply invite demoralizing and reprehensible bookkeeping, honest budget proposals and judgments. A well-founded reputation for honest economic evaluation of projects. scrupulous dealing is itself a priceless corporate asset. It is the companies’ policy to make full, fair, accurate, timely and understandable disclosure The companies care how results are obtained, in reports and documents that the companies not just that they are obtained. Directors, file with applicable securities regulators, and in officers and employees should deal fairly other public communications. All employees with each other and with the companies’ are responsible for reporting material suppliers, customers, competitors and other information known to them to higher third parties. management so that the information will be available to senior management responsible for The companies expect compliance with their making disclosure decisions. standard of integrity throughout the organization and will not tolerate employees who achieve results at the cost of violation of law or who deal unscrupulously. The companies’ directors and officers support, and expect the companies’ employees to support, any employee who passes up an opportunity or advantage that would sacrifice ethical standards.
It is the companies’ policy that all transactions will be accurately reflected in their books and records. This, of course, means that falsification of books and records and the creation or maintenance of any off-the-record bank accounts are strictly prohibited. Employees are expected to record all transactions accurately in the companies’ books and records, and to be honest and forthcoming with the companies’ internal and independent auditors.
4 | Imperial | Standards of business conduct Conflicts of Corporate interest policy assets policy
It is the policy of Imperial and the ExxonMobil It is the policy of Imperial and the ExxonMobil companies in Canada that directors, officers companies in Canada that directors, officers and employees are expected to avoid any and employees are expected to protect the actual or apparent conflict between their assets of the companies and use them own personal interests and the interests efficiently to advance the interests of the of the companies. companies. Those assets include tangible assets and intangible assets, such as A conflict of interest can arise when a confidential information of the companies or director, officer or employee takes actions personal information held by the companies. or has personal interests that may interfere with his or her objective and effective No director, officer or employee should use performance of work for the companies. or disclose at any time during or subsequent For example, directors, officers and to employment or other service to the employees are expected to: companies, without proper authority or mandate, personal or confidential information • avoid actual or apparent conflict in obtained from any source in the course of the dealings with suppliers, customers, companies’ business. Examples of confidential competitors and other third parties information include non-public information • refrain from taking for themselves about the companies’ plans, earnings, financial opportunities discovered through their forecasts, business forecasts, discoveries, use of corporate assets or through their competitive bids, technologies and personnel. positions with the companies • avoid securities transactions based on material, non-public information learned through their positions with the companies • refrain from competing with the companies.
February 2021 | 5 Directorships Gifts and policy entertainment policy
It is the policy of Imperial and the ExxonMobil It is the policy of Imperial and the ExxonMobil companies in Canada to restrict the holding companies in Canada to base commercial by officers and employees of directorships in decisions on commercial criteria. That policy non-affiliated, for-profit organizations and serves the companies’ business interests and to prohibit the acceptance by any officer or fosters constructive relationships with employee of such directorships that would organizations and individuals doing business, involve a conflict of interest with, or interfere or seeking to do business, with the companies. with, the discharge of the officer’s or In many cultures, those constructive employee’s duties to the companies. relationships may include incidental business gifts and entertainment. Any officer or employee may hold directorships in non-affiliated, non-profit organizations, Directors, officers and employees and third unless such directorships would involve a parties acting on behalf of the companies conflict of interest with, or interfere with, the providing or receiving third-party gifts and discharge of the officer’s or employee’s duties entertainment in their corporate capacities to the companies, or obligate the companies to are expected to exercise good judgment in provide support to the non-affiliated, non- each case, taking into account pertinent profit organizations. circumstances, including:
• the character of the gift or entertainment Officers and employees may serve as directors of affiliated companies and such service may be • its purpose part of their normal work assignments. • its appearance
All directorships in public companies held by • the positions of the persons providing employee directors of Imperial are subject and receiving the gift or entertainment to review and approval by the board of • the business context directors of Imperial. All directorships in public companies held by employee directors • reciprocity of Exxon Mobil Corporation are subject to • applicable laws and social norms. review and approval by the board of directors of Exxon Mobil Corporation. In all other cases, Gifts and entertainment must not be intended directorships in non-affiliated, for-profit to create an improper advantage for the organizations are subject to review and companies. All expenditures for gifts and approval by the management of the companies, entertainment provided by the companies as directed by the chairman of Imperial or must be accurately recorded in the books Exxon Mobil Corporation, as the case may be. and records of the companies.
6 | Imperial | Standards of business conduct Political International activities policy operations policy
Political contributions Imperial and the ExxonMobil companies in Canada do business in Canada, and it is Imperial: the policy of the companies to comply with Only the chief executive officer of Imperial is all governmental laws, rules and regulations authorized to make political contributions, applicable to their operations in Canada and within the limits of an annual budget approved to conduct those operations to the highest by its directors. This is the only way in which ethical standards. Imperial can donate funds, services or physical assets to political officials or organizations. Where the companies as a consequence of international operations are subject to Exxon Mobil Corporation and the the laws, rules and regulations of foreign ExxonMobil companies in Canada: jurisdictions, they shall comply with such governmental laws, rules and regulations. It is the policy of Exxon Mobil Corporation to refrain from making contributions to political Certain U.S. laws govern international candidates and political parties, except as operations of U.S. companies and U.S. permitted by applicable laws and authorized persons, and which are broadly defined. by the board of directors. This policy applies Accordingly, directors, officers and employees to the ExxonMobil companies in Canada. of the companies should consult with the law department for advice on applicable U.S. laws, Other political activities especially laws regarding boycotts, trade sanctions, export controls and foreign corrupt It is the policy of Imperial and the ExxonMobil practices, as well as Canadian laws relating companies in Canada to communicate to these subjects. information and views on issues of public concern that have an important impact on the companies.
The companies consider that voting, contributing financially to the party or candidate of one’s choice, keeping informed on political matters, serving in civic bodies, and campaigning and officeholding at local, provincial and national levels are important rights and responsibilities of the citizens of a democracy.
Directors, officers and employees engaging in political activities are expected to do so as private citizens and not as representatives of the companies. Personal, lawful political contributions and decisions not to make contributions will not influence compensation, job security or opportunities for advancement.
February 2021 | 7 Antitrust/ Anti-corruption competition policy law policy
It is the policy of Imperial and the ExxonMobil It is the policy of Imperial and the ExxonMobil companies in Canada that directors, officers companies in Canada that directors, officers, and employees are expected to comply with employees and third parties acting on their the antitrust and competition laws of Canada, behalf are prohibited from offering or paying, the United States and with those of any other directly or indirectly, any bribe to any employee, country or group of countries which are official, or agent of any government, applicable to the companies’ business. commercial entity, or individual in connection with the business or activities of the No director, officer or employee should companies. A bribe for purposes of this policy is assume that the companies’ interest ever any money, goods, services, or other thing of requires otherwise. value offered or given with the intent to gain any improper advantage for the companies. It is recognized that, on occasion, there may be legitimate doubt as to the proper interpretation No director, officer, employee, or third party of the law. In such a circumstance, it is required should assume that the companies’ interest that the directors, officers and employees refer ever requires otherwise. the case through appropriate channels to the law department for advice.
8 | Imperial | Standards of business conduct Health policy
It is the policy of Imperial and the ExxonMobil • conduct and support research to extend companies in Canada to: knowledge about the health effects of their operations • identify and evaluate health risks related to their operations that potentially affect their • undertake appropriate reviews and employees, contractors or the public evaluations of their operations to measure progress and to foster compliance with • implement programs and appropriate this policy protective measures to control such risks, including appropriate monitoring of their • provide voluntary health promotion potentially affected employees programs designed to enhance employees’ well being, productivity and personal • communicate in a reasonable manner to safety. These programs should supplement, potentially affected individuals or but not interfere with, the responsibility of organizations and the scientific community employees for their own health care and knowledge about health risks gained from their relationships with personal physicians. their health programs and related studies Information about employees obtained • determine at the time of employment through the implementation of these and thereafter, as appropriate, the medical programs should be considered fitness of employees to do their work confidential and should not be revealed without undue risk to themselves to non-medical personnel except: at the or others request of the employee concerned, when required by law or when dictated by • provide or arrange for medical services overriding public health considerations. necessary for the treatment of employee occupational illnesses or injuries and for the handling of medical emergencies • comply with all applicable laws and regulations, and apply responsible standards where laws and regulations do not exist • work with government agencies and others to develop responsible laws, regulations and standards based on sound science and consideration of risk
February 2021 | 9 Safety policy
It is the policy of Imperial and the ExxonMobil • conduct and support research to companies in Canada to conduct their business extend knowledge about the safety effects in a manner that protects the safety of of their operations, and promptly apply employees, others involved in their operations, significant findings and, as appropriate, customers and the public. The companies will share them with employees, contractors, strive to prevent all accidents, injuries and government agencies and others who occupational illnesses through the active might be affected participation of every employee. The • stress to all employees, contractors and companies are committed to continuous others working on the companies’ behalf efforts to identify and eliminate or manage their responsibility and accountability safety risks associated with their activities. for safe performance on the job and
encourage safe behaviour off the job Accordingly, the companies’ policy is to: • undertake appropriate reviews and • design and maintain facilities, establish evaluations of their operations to measure management systems, provide training progress and to foster compliance with and conduct operations in a manner that this policy. safeguards people and property • respond quickly, effectively and with care to emergencies or accidents resulting from their operations, in cooperation with industry organizations and authorized government agencies • comply with all applicable laws and regulations, and apply responsible standards where laws and regulations do not exist • work with government agencies and others to develop responsible laws, regulations and standards based on sound science and consideration of risk
10 | Imperial | Standards of business conduct Product safety policy
It is the policy of Imperial and the ExxonMobil • include identification and control of companies in Canada to: potentially adverse health, safety and environmental effects as priority • identify and manage risks associated with considerations in the planning and their products and not manufacture or sell development of products products when it is not possible through proper design, procedures and practices to • conduct and support research to extend provide an appropriate level of safety for knowledge about the health, safety and people and the environment environmental effects of their products, and promptly apply significant findings and, • specify precautions required in handling, as appropriate, share them with their transporting, using and disposing of employees, contractors, customers, the their products and take reasonable scientific community, government agencies steps to communicate them to employees, and the public customers and others who might be affected • undertake appropriate reviews and evaluations of their operations to measure • comply with all applicable laws and progress and to foster compliance with regulations and apply responsible this policy. standards where laws and regulations do not exist • work with government agencies and others, as appropriate, to develop responsible laws, regulations and standards based on sound science and consideration of risk
February 2021 | 11 Environment policy
It is the policy of Imperial and the ExxonMobil • respond quickly and effectively to companies in Canada to conduct their business incidents resulting from their operations, in a manner that is compatible with the in cooperation with industry organizations balanced environmental and economic needs and authorized government agencies of the communities in which they operate. • conduct and support research to improve The companies are committed to continuous understanding of the impact of their efforts to improve environmental performance business on the environment, to improve throughout their operations. methods of environmental protection, and
to enhance their capability to make Accordingly, the companies’ policy is to: operations and products compatible • comply with all applicable environmental with the environment laws and regulations and apply responsible • communicate with the public on standards where laws and regulations do environmental matters and share their not exist experience with others to facilitate • encourage respect for the environment, improvements in industry performance emphasize every employee’s responsibility • undertake appropriate reviews and in environmental performance, and evaluations of their operations to measure foster appropriate operating practices progress and to foster compliance with and training this policy. • work with government and industry groups to foster timely development of effective environmental laws and regulations based on sound science and considering risks, costs and benefits, including effects on energy and product supply • manage their business with the goal of preventing incidents and of controlling emissions and wastes to below harmful levels; design, operate, and maintain facilities to this end
12 | Imperial | Standards of business conduct Customer relations and product quality policy
Imperial and the ExxonMobil companies in Canada recognize customer satisfaction is of primary importance to their success. Mindful of their responsibility to the consumers they serve directly and the customers who resell their products, the companies strive to understand their requirements and concerns and to merit their business by responding effectively to their needs.
Specifically, the companies’ policy is to: • provide high-quality products that meet or exceed equipment specifications and consumer needs under all reasonable circumstances • furnish services that reliably meet responsible standards of performance, efficiency and courtesy • furnish accurate and sufficient information about their products and services, including details of guarantees and warranties, so that customers can make informed purchasing decisions • require truth in advertising and other communications.
In addition, where the companies’ products reach the ultimate consumer through independent parties, such as service station dealers and distributors, the companies’ policy is to actively encourage such parties to achieve standards comparable to those that have been established for the companies’ own performance.
February 2021 | 13 Equal employment opportunity policy
It is the policy of Imperial and the ExxonMobil • develop and offer work arrangements companies in Canada to provide equal that help to meet the needs of the employment opportunity in conformance diverse workforce in balancing work with all applicable laws and regulations to and family obligations individuals who are qualified to perform job • establish company training and requirements. The companies administer their development efforts, policies and personnel policies, programs and practices in programs that support diversity a non-discriminatory manner in all aspects of in the workforce and enhance the the employment relationship, including representation of designated groups recruitment, hiring, work assignment, throughout the company promotion, transfer, termination, wage and salary administration, and selection for training. • assure a work environment free from sexual, racial or other harassment; Managers and supervisors are responsible • make reasonable accommodations for implementing and administering this policy, that enable qualified disabled individuals for maintaining a work environment free from to perform the essential functions of unlawful discrimination, and for promptly their jobs identifying and resolving any problem area regarding equal employment opportunity. • emphasize management responsibility in these matters at every level of Except where identified as a bona fide the organization. occupational requirement, discrimination is prohibited on the grounds of age, sex, race, Individuals who believe they have observed colour, religion, creed, national origin, or been subjected to prohibited discrimination citizenship, language, marital status, family should immediately report the incident to their status, pregnancy and childbirth, sexual supervisor, management, human resources orientation, mental or physical disability and contact or diversity and equity contact handicap, political belief or any other ground Complaints will be investigated and handled of discrimination prohibited by law. as confidentially as possible.
In addition to providing equal employment Individuals will not be subjected to harassment, opportunity, it is also the companies’ policy intimidation, discrimination or retaliation for to undertake special efforts to: exercising any of the rights protected by this policy and human rights legislation. • develop and support educational programs and recruiting sources and practices that facilitate employment of designated groups (women, Aboriginal people, persons with disabilities or handicaps, and persons who are, because of their race or colour, in a visible minority in Canada)
14 | Imperial | Standards of business conduct Harassment in the workplace policy
It is the policy of Imperial and the ExxonMobil Individuals who believe they have been companies in Canada to prohibit any form of subjected to harassment must immediately unlawful harassment based on age, sex, race, report the incident to their manager, higher colour, religion, creed, national origin, management or their designated employee citizenship, language, marital status, family services contact. status, pregnancy and childbirth, sexual orientation, disability/handicap, political All complaints will be promptly and thoroughly belief or any other prohibited ground of investigated. The companies will treat such discrimination. In addition, our harassment complaints as confidentially as possible, policy also prohibits any other form of releasing information only to those with harassment, as outlined in the policy. a need or right to know.
The objective of this policy is to provide a Any employee who observes or becomes work environment that fosters mutual aware of harassment must immediately advise employee respect and working relationships their manager, higher management or their free of harassment. The companies specifically designated employee services contact. No prohibit any form of harassment by or employee should assume that the company is toward employees, contractors, aware of a problem. All complaints and suppliers or customers. concerns are to be brought to the attention of management or employee services personnel Under the companies’ policy, harassment so that steps can be taken to correct them. is any inappropriate conduct that has the Failure to report may result in discipline, up to purpose or effect of: and including termination.
• creating an intimidating, hostile or No retaliation will be taken against any offensive work environment employee because he or she reports a problem (including violence); concerning possible acts of harassment. • unreasonably interfering with an Employees can raise concerns and make individual’s work performance, or reports without fear of reprisal. If you have any questions about what constitutes harassing • affecting an individual’s behaviour, please contact your manager or employment opportunity. employee services contact.
Harassment will not be tolerated. Forms of harassment include, but are not limited to, unwelcome verbal or physical advances and sexually, racially or otherwise derogatory or discriminatory materials, statements or remarks. All employees, including managers, will be subject to corrective action up to and including termination for any act of harassment.
February 2021 | 15 Alcohol and drug policy
Purpose or substance dependence due to the use of alcohol, cannabis, drugs and other substances Introduction and those who do not.
Imperial Oil Limited and the ExxonMobil Where an employee is diagnosed with a companies in Canada (the “company”) are substance abuse or substance dependence committed to the health and safety of problem, the company is committed to employees, the public and the environment. supporting individualized treatment and The company makes every reasonable effort to rehabilitation plans. The company provides minimize risks associated with its operations access to confidential assessment, counselling, and to ensure a safe, healthy and productive referral and aftercare services through the workplace. The use of illicit drugs and the occupational health division (OHD). inappropriate use of alcohol, cannabis, medications or other substances, can have Employees who voluntarily self-declare a serious adverse effects on employee substance abuse or substance dependence performance and fitness for work, safety and problem, prior to a violation of this policy, will well-being, the public or the environment. receive rehabilitation assistance and not be disciplined for requesting help. As a matter of policy the company expects that all employees report and remain fit for work throughout the work day or shift in order to Job category definitions perform their job safely. For purposes of this policy, jobs are categorized Objectives and defined as follows:
The objectives of this policy are to: Safety-sensitive positions • create a safe work environment by Positions that meet both of the following reducing the risk of incidents in which conditions as determined by the company: alcohol, cannabis, drugs and other a) they have a key and direct role in an substances are a potential operation where impaired performance contributing factor could result in a catastrophic incident, • deter the use of alcohol, cannabis, drugs affecting the health or safety of employees, and other substances where such use may the public or the environment; and negatively affect work performance b) they have no direct or very limited and safety supervision available to provide frequent • ensure employees report and remain fit for operational checks. work throughout the work day or shift This category includes all employees who are Declaration, assessment, rehabilitation required to rotate through or temporarily and aftercare principles relieve safety-sensitive positions.
This policy stresses the importance of Safety-sensitive positions are subject to the prevention and early identification of potential work rules for all employees and the additional substance abuse or dependence problems by work rules for employees in safety-sensitive employee self-declaration. The company positions. recognizes that there is a distinction between those who have a diagnosed substance abuse
16 | Imperial | Standards of business conduct
Specified positions of a business trip but does not include routine commuting between home and the normally- Positions that have significant ongoing assigned place of work or personal use of a responsibilities for decisions or actions likely to company-assigned or leased vehicle. In affect the safe operations, finances or determining whether an individual is driving in reputation of the company. the course of employment, it does not matter whether the vehicle is company-owned, leased, Specified positions are subject to the work rented or employee-owned. rules for all employees and the additional work rules for employees in specified positions. Company premises All other positions The term "company premises" refers to all land, facilities, equipment and vehicles owned, All other positions not included in Safety- leased or otherwise controlled by the company, Sensitive or Specified are subject to the work including, but not limited to, land, roads, rules for all employees. parking lots, buildings, plants, terminals, docks, other physical facilities, equipment and Workplace definitions company-owned ships or barges. Operating management may exempt from coverage or set Company business special regulations for company-provided living quarters, remote camps or facilities that are The term "company business" refers to all provided primarily for recreational purposes. structured business activities undertaken by employees in the course of the company's operations, whether conducted on or off Work rules for all employees company premises, including meetings, A violation of these rules may lead to corrective seminars, conventions or training events, and action as defined in this policy: structured business contacts with co-workers, sales associates, contractors, customers, Prohibitions suppliers, public agencies or other parties with whom the company transacts business, All employees are strictly prohibited from the whether or not such activities take place during following while on company business or what is considered to be paid time. company premises.
"Company business" does not include informal 1. Use, unfit for scheduled work due to use or business contacts primarily of a social nature or after effects of, possession, selling, work-related travel where the employee is a manufacturing, distributing, concealing, or passenger in an air, rail, marine or ground transporting any of the following conveyance. prohibited substances: a) Alcohol Employees are considered to be on company business whenever they are driving or i. Including having a blood alcohol operating mobile equipment in the course of concentration of .04 percent (.04 employment, as defined by the relevant grams per 100 ml) or higher. provincial workers' compensation regulations. ii. For use at company social functions, As a general rule, this includes all driving as part corresponding guidelines apply.
February 2021 | 17
b) Cannabis in any form 4. Testing violations: i. Including having a laboratory based a) Confirmed positive test result for test result for: alcohol, cannabis or specified drug or - urine of 15ng/ml or higher their metabolites. - oral fluid of 2ng/ml or higher b) Refusing to promptly report and ii. Cannabis authorized or prescribed comply with test procedures. for medical use will be subject to the c) Failing to provide specimens when requirements of the Medication required to do so. Disclosure section. d) Switching or adulterating a test c) Potentially impairing medications (e.g., specimen, or the attempt to do so. may be prescription drugs or over-the- counter medication or herbal medicine) e) Obstructing the collector or testing that are: process in any way. i. Used without a prescription where a f) Refusing to consent to disclose test prescription is required. results to management.
ii. Used in a manner inconsistent with Searches the prescription or directions. The company may conduct various types of iii. Used without disclosure per the Medication Disclosure process. unannounced searches for alcohol, drugs or drug paraphernalia, on company owned or d) Illicit drugs means any controlled controlled premises where: substance or drug, illegal to possess, cultivate or traffic, including all forms • There is reasonable cause to suspect that of naturally occurring and synthetic they may be present. drugs that may inhibit the ability of an employee to perform work safely. This Failure to cooperate with a search may lead to includes the presence in the body of corrective action as defined in this policy. these substances or their metabolites. Medication disclosure and employee 2. Operating a company owned or leased responsibilities vehicle while under the influence of alcohol, cannabis, drugs and other All employees have a responsibility to report fit substances. for duty and manage potential impairment and side-effects during working hours due to the 3. Contraband and Paraphernalia: legitimate use of any medication, in a) Any paraphernalia used or designed consultation with their personal physician, for use in testing, packaging, storing, pharmacist or one of the company's health injecting, ingesting, inhaling or centers. The employee should be prepared to otherwise introducing into the human provide evidence that the medication being body any of the above prohibited taken is prescribed if required and, with all substances. medication, that it is being used for appropriate health reasons. b) Any paraphernalia or substance used or designed for use to dilute, substitute, or adulterate any test specimen, or to otherwise obstruct or circumvent the testing process.
18 | Imperial | Standards of business conduct
A list of medication categories and examples Declaration, assessment, rehabilitation are found in the A&D program guidance and aftercare responsibilities document. The list is not intended to capture all medications of concern as the nature and type Employees who suspect or are aware that they of medication available are constantly have an emerging or active substance abuse or changing. substance dependence problem are encouraged and expected to promptly seek In order to fulfill the responsibility of medical advice before a violation of this policy medication management employees must also occurs and before job performance is affected. follow the medication disclosure guidance as follows: Employees may choose to self- declare verbally or in writing, to their supervisor/manager, • The employee should discuss use of human resources, or OHD. medication that may impact fitness for work with their prescribing Health Care • Employees who self-declare will be: Provider and if potential safety concerns - Referred to OHD and if required for an are associated with the medication to a assessment with a company company health professional prior to designated Substance Abuse returning to work. Professional (SAP). • Where the use of medication may - If a substance abuse or substance negatively affect fitness for work and dependence problem is diagnosed, the safety, a company health professional may employee will be supported through a issue medical work limitations requiring company approved treatment and modified work or temporary reassignment. aftercare program. • If a potential safety concern is identified - Employees will receive disability and with the employee’s Health Care Provider, health benefits in accordance with and it is not feasible, due to timely access, existing plans. to discuss the situation with the company Health Professional, the employee should - Assessed for work limitations which declare to his or her supervisor/manager will be appropriately communicated to that he or she is taking a potentially management with employee consent. impairing medication. • Work limitations may result in modified • The specific name of the medication and work, reassignment, or absence for work. the underlying medical condition for which it is being taken does not have to be Employees should understand that accessing disclosed to the supervisor/manager. assistance or declaring a substance abuse or substance dependence problem does not • If the supervisor/manager has any doubt eliminate the requirement to comply with all about an employee's fitness for work, they aspects of this policy. should be sent home and referred to a company health centre as soon as possible. • The employee and manager must make every effort to discuss the situation as soon as reasonably possible and should be completed prior to a return to company premises or company business.
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Testing requirements Additional work rules for Reasonable Cause testing: employees in safety-sensitive • All employees are subject to testing for positions alcohol, cannabis and specified drugs A violation of these rules may lead to corrective where reasonable cause exists to suspect action as defined by this policy: alcohol or drug use or possession in violation of this policy. Alcohol requirements
Post-Incident testing: • Employees in safety-sensitive positions are prohibited from consuming any alcoholic • All employees are subject to testing for beverage during working hours, whether alcohol, cannabis and specified drugs after on or off company premises. a significant incident as determined by management. The purpose of this type of • This provision applies to mealtimes and testing is to help eliminate substance use as other personal work breaks, whether or a cause and to determine whether not they are considered to be paid time. substance use was a possible contributing • Employees in safety-sensitive positions are factor in an incident. also required to limit their consumption • It is recognized that a positive post-incident prior to working hours so that there is no test does not independently prove that alcohol in the body while at work. substance use was the "root cause" or the - A safety sensitive employee is only contributing factor in a particular considered unfit for work if their blood incident. As such, it does not relieve the alcohol concentration (BAC) is 0.02 company of the obligation to complete a percent or higher. The employee will thorough investigation. be removed from work and will be subject to further investigation of Aftercare testing: circumstance leading up to the BAC • A full list of requirements, including reading and may be subject to abstinence, are outlined in the aftercare discipline. agreement permitting an employee with a Medication disclosure diagnosed substance abuse or substance dependence problem to enter or return to • Safety-sensitive employees are required to work. report the use of potentially impairing medications (e.g., may be prescription • Testing to monitor required abstinence drugs, over-the-counter medication, or may be conducted on an unannounced alternative medicine) including medically periodic basis as part of a post- authorized cannabis that may impact their rehabilitation monitoring program. fitness for work to the appropriate • An employee in aftercare will be removed company health centre or their supervisor/ from work if their blood alcohol manager before commencing work. concentration is 0.02 percent or higher and • The process for medication disclosure is may receive corrective action as defined in outlined in the work rules for all employees. this policy.
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• Employees in safety-sensitive positions Safety-sensitive position certification and must check with their personal physician or testing requirements the appropriate company health center if there is any doubt about the potential Certification process for safety-sensitive impact of a particular medication on their positions fitness for work. • Employees transferring or being promoted Safety sensitive position declaration, to safety-sensitive positions are required to complete a certification process before assessment, rehabilitation and aftercare entering a safety-sensitive position. All responsibilities incumbents must recertify every two years • Employees in, or candidates for, safety- to remain in their safety-sensitive positions sensitive positions are required to notify (recertification). their supervisor/manager before a violation • Candidates for employment in safety- of this policy occurs and before job sensitive positions will be required to performance is affected if they have a complete certification with employment substance abuse or substance dependence conditional upon successful completion of problem or if they have had a substance the process. abuse or substance dependence problem within the past 6 years ("a past problem"). • The certification process includes: • The process to self-declare is outlined in - a test for alcohol, cannabis and the work rules for all employees. specified drugs (except for recertification); • An employee will not be permitted to enter or remain in a safety-sensitive position if - a mandatory medical evaluation to the individualized medical assessment verify fitness for safety-sensitive indicates that he or she is currently unfit for duties; and work because of a current or past problem. - management assessment that • Such employees may not enter or re-enter the individual meets all requirements a safety-sensitive position until they have for employment in a safety- applied for and successfully completed an sensitive position. individualized reinstatement review • An employee who undertakes the process. certification/recertification process but is • Where an employee must be reassigned or unable to complete it successfully will be work modified, a reasonable effort will be denied entry to or removed immediately made to offer an alternative position. from the safety-sensitive position.
In addition to the testing requirements outlined in the work rules for all employees section, safety-sensitive employees are also subject to:
Random testing • Employees in safety-sensitive positions are subject to unannounced random testing for alcohol, cannabis and specified drugs.
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Additional work rules for • The process for medication disclosure is employees in specified positions outlined in the work rules for all employees. • Employees in specified positions must A violation of these rules may lead to corrective check with their personal physician or the action as defined by this policy: appropriate company health centre if there is any doubt about the potential impact Testing and medical exam requirements of a particular medication on their fitness • Candidates for employment in, or transfer for work. or promotion to, specified positions are subject to pre-assignment testing for Corrective action alcohol, cannabis and specified drugs. A violation of this policy may result in corrective • Candidates for employment in, or transfer or promotion to, specified positions are action up to and including termination of required to submit to a medical employment. If an employee violates the examination by a company-designated provisions of this policy, an investigation will be health professional. Incumbents are subject conducted before corrective action is taken. to periodic mandatory medical The appropriate corrective action in a particular examinations every two years. case depends on the nature of the policy violation and the circumstances surrounding it. • Random testing: In addition to the testing requirements outlined in the work rules for all employees Where to go for information section, employees in specified positions Local management is responsible for are subject to unannounced random administering the alcohol and drug policy. testing for alcohol, cannabis and Questions or advice regarding the policy specified drugs. should be directed to your supervisor/manager. In addition, the alcohol and drug program Medication disclosure administration group (ADPAG) is available to • Specified employees are required to report assist employees, supervisors and managers in the use of potentially impairing medications interpreting the policy. (e.g., may be prescription drugs, over-the- counter medication, or alternative medicine) and medically authorized cannabis that may impact their fitness for work to the appropriate company health centre or their supervisor/manager before commencing work.
22 | Imperial | Standards of business conduct Procedures and open door communication
Imperial and the ExxonMobil companies Employees can also contact one of the in Canada have always encouraged employees following to provide assistance in matters to ask questions, voice concerns and make related to business ethics at Imperial appropriate suggestions regarding the or the ExxonMobil companies in Canada: business practices of the companies. Employees are expected to report promptly Ethics Adviser to management suspected violations of the Imperial Oil Limited/ law, company policies or internal controls, ExxonMobil Canada Ltd. so that management can investigate and 505 Quarry Park Blvd SE, take appropriate corrective action as soon Calgary, Alberta T2C 5N1 as possible. www.integritycounts.ca/org/ImperialEthics 1-877-390-5373 (Live Agent) Management is ultimately responsible for the investigation of and appropriate responses to In addition, the controller and general auditor reports of suspected violation of law, policies of Imperial are available to assist employees and internal control procedures. Internal audit, and managers of each of the companies in with assistance from others, is primarily interpreting policy or in reporting items responsible for investigating violations of of concern. internal controls. Investigators are expected to exercise independent and objective judgment. Controller Imperial Oil Limited Several ways to obtain 505 Quarry Park Blvd SE, Office P5C.176 information and advice Calgary, Alberta T2C 5N1 587-476-3941 There are several ways for employees to obtain information and advice, or to report ethics General Auditor concerns. All are treated with discretion. Imperial Oil Limited 505 Quarry Park Blvd SE, Office P4A.075 Normally, employees should discuss such Calgary, Alberta T2C 5N1 matters with their immediate supervisor. 587-476-4085 Supervisors are expected to assist employees in these matters. If an employee is dissatisfied Suspected violations involving with the discussion with his/her supervisor, the a director or executive officer employee is encouraged to pursue the matter with the next level of management, with or Suspected violation of the law or company without the supervisor present. The issue policies involving a director or executive officer, should continue to be reviewed to the level as well as any concern regarding questionable of management appropriate to resolve it. accounting or auditing matters, should be referred directly to the respective general auditor of Imperial or Exxon Mobil Corporation. The audit committee of the Imperial board of directors or the board affairs committee of the Exxon Mobil Corporation board of directors will initially review all issues involving directors or executive officers, and will then refer all issues to their respective board of directors.
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Employees may also address communications Exxon Mobil Corporation to individual non-employee directors or to the Global Security Manager non-employee directors as a group by writing P.O. Box 142106 to them at: Irving, Texas 75014 USA
Name of Director All complaints concerning accounting, internal Imperial Oil Limited accounting controls or auditing matters will 505 Quarry Park Blvd SE, Office P5A.121 be referred to the audit committee of the Calgary, Alberta T2C 5N1 board of directors of either Imperial or Exxon Mobil Corporation. Name of Director Exxon Mobil Corporation Persons responding to employees’ questions, 5959 Las Colinas Boulevard concerns, complaints and suggestions are Irving, Texas 75039 USA expected to use appropriate discretion regarding anonymity and confidentiality, Confidential ethics and although the preservation of confidentiality complaints reporting may not always be practical, depending on the circumstances. For example, investigations of Employees wishing to make complaints without significant complaints typically necessitate identifying themselves may use our third party revealing to others information about the vendor in Canada, Integrity Counts, or the complaint and complainant. Similarly, disclosure Exxon Mobil Corporation “hotline”. Integrity can result from government investigations and Counts provides a private and secure litigation. messaging system that maintains the anonymity of the person reporting. Employees No action will be taken against employees may also send their complaints to the for voicing concerns in good faith. companies in writing. No action may be taken or threatened To report a complaint: by management against any employee for asking questions, voicing concerns, Imperial Oil Limited or making complaints or suggestions in www.integritycounts.ca/org/ImperialEthics conformity with the procedures described 1-877-390-5373 ( Live Agent) above, unless the employee acts with
willful disregard of the facts. Exxon Mobil Corporation
Dallas Confidential Line It is expected that employees will act in Call 1-800-963-9966 or good faith. Failure to act honestly, and failure to 1-972-444-1990 comply with the law, company policies and
internal controls may result in disciplinary To report a complaint by letter: action, up to and including termination Confidential Complaints of employment. Attention: Corporate Security Imperial Oil Limited 505 Quarry Park Blvd SE Calgary, Alberta T2C 5N1
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