About EthicsPoint and the Oxy Integrity Helpline

Reporting – General

Reporting Security & Confidentiality

Tips & Best Practices

About EthicsPoint

What is EthicsPoint and how is it related to Oxy’s Integrity Helpline?

EthicsPoint is a third party comprehensive and confidential reporting tool created by NAVEX to assist Oxy in addressing fraud, abuse, and other misconduct in the workplace, and cultivate a positive work environment. Oxy refers internally to this reporting tool as the Oxy Integrity Helpline.

Why do we need a system like EthicsPoint?

Reporting – General

May I report either online or by telephone?

Yes. With EthicsPoint, you have the ability to file a confidential, anonymous report via either the telephone or online through the Integrity Helpline.

What type of situations should I report?

The Oxy Integrity Helpline is designed for employees to report any violation of Oxy’s Code of Business Conduct (Code) or other concern you may have.

If I see a violation, shouldn't I just report it to my manager, security, or human resources and let them deal with it?

When you observe some behavior that you believe violates our Code, we expect you to report it. Ideally, you should bring any concerns forward to your manager or any of Oxy’s other established reporting channels as identified in the Code, including the Oxy Integrity Helpline. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that Oxy has partnered with EthicsPoint to provide the Oxy Integrity Helpline. We would rather you report anonymously than keep the information to yourself.

Why should I report what I know? What’s in it for me?

We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is acting inappropriately. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the integrity and livelihood of an entire company.

Does management really want me to report?

We certainly do. In fact, we need you to report. You know what is going at Oxy - both good and bad. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on Oxy and our people. Also, offering positive input may help identify issues that can improve corporate culture and performance.

Where do these reports go? Who can access them?

Reports are entered through the Oxy Integrity Helpline directly on the EthicsPoint secure server to prevent any possible breach in security. EthicsPoint makes these reports available only to specific individuals within the company who are charged by Oxy’s Chief Compliance Officer with evaluating the report, based on the type of violation and location of the incident. Each of these report recipients has had training in keeping these reports in the utmost confidence.

Isn’t this system just an example of someone watching over me?

The Integrity Helpline concentrates on being a positive aspect of Oxy’s philosophy, and allows us to assure a safe, secure, and ethical workplace. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions, or communicate a concern. Effective communication is critical in today’s workplace and this is a great tool to enhance that communication.

We have carefully chosen the best reporting tool to meet our compliance obligations while maintaining a positive reporting environment.

Reporting Confidentiality

Can I file a report from home and still remain anonymous?

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is totally maintained. Plus, EthicsPoint is contractually committed not to pursue a reporter’s identity.

I am concerned that the information I provide EthicsPoint will ultimately reveal my identity. How can you assure me that will not happen?

The Oxy Integrity Helpline is designed to protect your anonymity. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that the body of the report does not reveal your identity by accident. For example, “From my cube next to Jan Smith…” or “In my 33 years…”.

Is the telephone toll-free hot line confidential and anonymous too?

Yes. You will be asked to provide the same information that you would provide in a web-based report and an interviewer will type your responses into the Oxy Integrity Helpline site. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

There is a section in the report for identifying yourself if you wish.

Tips & Best Practices

I am aware of some individuals potentially engaged in unethical conduct, but it doesn't affect me. Why should I report it?

Oxy chooses to promote ethical behavior. All unethical conduct, at any level, ultimately hurts Oxy and all employees, including you. You only have to consider what happened in recent corporate scandals to see the disastrous effects that a seemingly harmless lapse in ethics can have on an otherwise healthy company. If you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report it.

I am not sure if what I have observed or heard is a violation of Oxy policy, or involves unethical conduct, but it just does not look right to me. What should I do?

File a report. The Oxy Integrity Helpline can help you prepare and file your report so it can be properly understood. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you weren't sure.

What if my manager or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The Oxy Integrity Helpline is designed so that implicated parties are not notified or granted access to reports in which they have been named.

What if I remember something important about the incident after I file the report? Or what if Oxy has further questions for me concerning my report?

When you file a report using the Oxy Integrity Helpline site or through the call center, you receive a unique user name and are asked to choose a password. You can return to the system again either online or by telephone and access the original report to add more detail or answer questions posed by a company representative and add further information that will help resolve open issues. We strongly suggest that you return to the site in the time specified to answer questions. You and Oxy will have entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.

Are these follow-ups on reports as secure as the first one?

All Oxy Integrity Helpline correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.

Can I still file a report if I don’t have access to the Internet?

You can file a report from any computer that can access the Internet. You can file from home. Many public locations, including the public library, have computers connected to the web. If you don’t have access to or are uncomfortable using a computer, you can call the toll-free hotline, which is available 24 hours a day, 365 days a year.