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2002 <strong>Chevron</strong>Texaco Corporate Responsibility Report Social IssuesCase Study >Addressing Complex Challenges(Continued)in Nigeriamedical personnel, hired planes fromNigeria and neighboring countries,and airlifted more than 3,000 people –including 2,000 displaced communitymembers – to safety in the neighboringcity of Warri. While these protestswere not directly tied to CNL, theIn early 2003, unrest in the Nigercompany used its resources to evacuateboth employees and communityDelta led <strong>Chevron</strong>Texaco to airliftworkers and 2,000 displacedmembers. The company also madecommunity members to safetyrepeated public calls urging all partiesin nearby Warri.to exercise restraint and to seek inclusivedialogue and peaceful resolution.The difficult situation in the Niger Delta affords us the opportunity tocontribute to the improvement of conditions and learn important lessonsabout the limitations of what can be achieved through our corporateresponsibility efforts. As an individual company, CNL can help providemuch-needed infrastructure, educational, health and other developmentalneeds to the people. However, it cannot solve historic, fundamental governance,security and economic problems. CNL is continuing to collaboratewith others to help improve the living conditions of the people close to ouroperations, while leaving minimal footprints of our activities.EthicsPolicy: Our Business Conduct and Ethics CodeIntegrity is one of <strong>Chevron</strong>Texaco’s core values, and we are committedto meeting the highest ethical standards in all our business dealings.<strong>Chevron</strong>Texaco’s policy is to adhere to the letter and the spirit of thelaw. The <strong>Chevron</strong>Texaco Business Conduct and Ethics (BC&E) Codedescribes the company’s policies for proper business conduct in a rangeof areas, such as conflicts of interest, public policy activities, gifts toofficials, agreements with competitors, privacy of personal information,nondiscrimination, and U.S. export controls and trade sanctions.<strong>Chevron</strong>Texaco’s Manual of Compliance Procedures and Guidelinesprovides greater detail on specific laws and policies related to many ofthe issues addressed in the BC&E Code.Also included in our BC&E Code is <strong>Chevron</strong>Texaco’s policy to complyfully with the letter and spirit of the U.S. Government’s Foreign CorruptPractices Act (FCPA). Payments to international officials or partiesfor the purpose of obtaining or retaining business is strictly against<strong>Chevron</strong>Texaco policy, even if the refusal to make them may cause thecompany to lose business. In instances where officials expect paymentto expedite the proper performance of “routine governmental action” –a practice allowed under the FCPA – <strong>Chevron</strong>Texaco requires all suchrequests to be forwarded to our Corporate Comptroller for reviewand approval.Approach: Rigorous Processes for Operating EthicallyWe use a variety of processes and control systems, up to and includingtermination, to ensure compliance with our ethical policies and guidelinesand accountability for violations.<strong>Chevron</strong>Texaco Directors, employees and contractors are required tocomply with the BC&E Code and the Manual of Compliance Procedures.All employees are required to read and be trained on the code. The AuditCommittee of the Board of Directors helps the Board monitor the company’sadherence to the BC&E Code. <strong>Chevron</strong>Texaco operating companiesand corporate departments have their own Compliance/AuditCommittees. These committees are responsible for overseeing complianceand ensuring that their respective organizations develop, implementand effectively operate processes to provide reasonable assuranceof compliance with all applicable laws and regulations and company policies.Corporate Compliance Audits are conducted by an Internal Auditfunction to help ensure compliance processes are functioning properly.© 2003 <strong>Chevron</strong>Texaco Corporation. All Rights Reserved.11