Cgevron Texaco Examination
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Letter to Employees
TO ALL EMPLOYEES:
The ChevronTexaco Corporation combines companies with long and
proud histories and worldwide reputations for honesty and integrity - two key
values of The ChevronTexaco Way. These well-deserved reputations not only
underlie our past accomplishments but also will be critical to our future success.
The ChevronTexaco Manual of Compliance Procedures and Guidelines
(the Manual) describes our policies both on the way we conduct ourselves and
on the way we do business around the world. We ask each of you whose jobs
require more detailed guidance than is contained in the companion
ChevronTexaco Business Conduct and Ethics Code to read the Manual and
become familiar with how the various policies relate to your job.
In brief, ChevronTexaco's policy is always to comply fully with both the
spirit and the letter of the law. But beyond that, we should conduct our business
with the highest standards of honesty and integrity -- wherever we operate.
Wherever the law is unclear or seems conflicting or we are in one of those gray
areas, we should conduct our business in such a way that we would be proud to
have all the facts disclosed.
No matter what our jobs may be, each of us may face ethical questions --
in our dealings with supervisors, peers and subordinates; with customers and
suppliers; with unions and governments; and with the communities in which we
live and work. These situations continually test our judgment and integrity in
the face of changing cultural values and increasing competitive pressures.
Often the test is not just what is illegal, but what is proper. Shortcuts, halftruths,
compromises and the expedient never should be allowed to replace what
is ethical and legal. These convenient or perhaps seemingly harmless acts can
hurt our business and harm our reputation, which is one of the cornerstones of
our success. That is why ChevronTexaco will not tolerate any unethical
behavior by employees.
In the final analysis, ChevronTexaco's success will continue to depend on
its ethical business conduct. We count on each of you to continue to conduct
yourselves following the highest standards of The ChevronTexaco Way.
Dave O'Reilly
Chairman of the Board and Chief Executive Officer
Introduction
INTRODUCTION
October 2001
This manual brings together the procedures and guidelines concerning compliance with
particularly complex U.S. laws and regulations (federal, state and local) that call for special
attention. There are, of course, many others that have an impact on ChevronTexaco. For all
these laws, the long-standing policy of unequivocal compliance applies. The potentially
severe civil and criminal penalties resulting for both the employee and ChevronTexaco for
violating these laws underscore the importance of knowing and following the procedures and
guidelines in this manual.
The management of every Corporation department and operating company is responsible for
implementing and enforcing the applicable procedures and guidelines. It is vital that each
employee whose work is affected by these procedures and guidelines have access to the
relevant sections of this manual.
Employees should be aware that violation of the law and of the procedures and guidelines in
this manual may lead not only to legal penalties but also to disciplinary action by the
company, up to and including termination of employment. Each employee is responsible to
make sure that he or she acts in compliance with the letter and spirit of applicable laws, as
well as the procedures and guidelines in this manual. All ChevronTexaco managers and
supervisors have the additional responsibility of making sure that everyone who works for
them understands and fulfills all their compliance obligations.
The ChevronTexaco Corporation Law Department has responsibility for updating and
distributing this manual. Employees with questions or changes may call the Law Department
Compliance Manual Administrator at (925) or CTN 973-4582 or send an e-mail to
jegt@chevrontexaco.com.
NOTE:
THIS "INTRODUCTION" AND THE FOLLOWING "GENERAL INSTRUCTIONS"
FORM AN INTEGRAL PART OF EACH OF THE FOLLOWING SECTIONS. TO THE
EXTENT THAT SECTIONS ARE TO BE SEPARATELY DISTRIBUTED TO
EMPLOYEES, IT IS IMPORTANT THAT COPIES OF THIS "INTRODUCTION" AND
THE "GENERAL INSTRUCTIONS" BE ATTACHED TO EACH SEPARATE SECTION.
General Instructions
GENERAL INSTRUCTIONS*
Revised October 2001
I.
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