July 2026

Standards of Business Conduc

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Table of Contents

ExxonMobil Introduction ...................................................................................................................3

Guiding Principles ...............................................................................................................................4

Ethics Policy .........................................................................................................................................5

Conflicts of Interest Policy .................................................................................................................6

Corporate Assets Policy .....................................................................................................................7

Directorships Policy ............................................................................................................................8

Gifts and Entertainment Policy .........................................................................................................9

Anti-Corruption Policy .................................................................................................................... 10

Political Activities Policy .................................................................................................................. 11

Trade Laws Policy ............................................................................................................................ 12

Antitrust Policy ................................................................................................................................. 13

Insider Trading Policy ...................................................................................................................... 14

Health Policy ..................................................................................................................................... 15

Environment Policy .......................................................................................................................... 16

Safety Policy ...................................................................................................................................... 17

Product Safety Policy ....................................................................................................................... 18

Customer Relations and Product Quality ..................................................................................... 19

Alcohol and Drug Use Policy .......................................................................................................... 20

Equal Employment Opportunity Policy ........................................................................................ 22

Harassment in the Workplace Policy ............................................................................................ 23

Procedures and Open Door Communication .............................................................................. 24

ExxonMobil Standards of Business Conduct Handbook — page 3

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ExxonMobil Introduction

The high quality of the directors, officers, and employees of ExxonMobil is the

Corporation's greatest strength. The resourcefulness, professionalism, and dedication of

those directors, officers, and employees make the Corporation competitive in the short

term and well positioned for ongoing success in the long term.

The Corporation's directors, officers, and employees are responsible for developing,

approving, and implementing plans and actions designed to achieve corporate objectives.

The methods we employ to attain results are as important as the results themselves. The

Corporation's directors, officers, and employees are expected to observe the highest

standards of integrity in the conduct of the Corporation's business.

The Board of Directors of the Corporation has adopted and oversees the administration of

the Corporation's

Standards of Business Conduct

. The policies in the

Standards of

Business Conduct

are the foundation policies of the Corporation. Wholly-owned and

majority-owned subsidiaries of ExxonMobil generally adopt policies similar to the

Corporation's foundation policies. Thus, the Corporation's foundation policies collectively

express the Corporation's expectations and define the basis for the worldwide conduct of

the businesses of the Corporation and its majority-owned subsidiaries.

The directors, officers, and employees of ExxonMobil are expected to review these

foundation policies periodically and apply them to all of their work. The Corporation

publishes from time to time guidelines with respect to selected policies. Those guidelines

are interpretive and administrative and are not part of the

Standards of Business Conduct

Any employee who has questions concerning any aspect of these policies should not

hesitate to seek answers from management or the other sources indicated in the section

below called "Procedures and Open Door Communication."

No one in the ExxonMobil organization has the authority to make exceptions or grant

waivers with respect to the foundation policies. Regardless of how much difficulty we

encounter or pressure we face in performing our jobs, no situation can justify the willful

violation of these policies. Our reputation as a corporate citizen depends on our

understanding of and compliance with these policies.

Darren W. Woods

Chairman

ExxonMobil Standards of Business Conduct Handbook — page 4

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Guiding Principles

ExxonMobil Holdings Corporation (ExxonMobil, The Company, The Corporation) is

committed to being the world's premier petroleum and petrochemical company. To that

end, we must continuously achieve superior financial and operating results while

simultaneously adhering to high ethical standards.

The following principles guide our relationships with our shareholders, customers,

employees, and communities:

Shareholders

- We are committed to enhancing the long-term value of the investment

dollars entrusted to us by our shareholders. By running the business profitably and

responsibly, we expect our shareholders to be rewarded with superior returns. This

commitment drives the management of our corporation.

Customers

- Success depends on our ability to consistently satisfy everchanging customer

preferences. We commit to be innovative and responsive, while offering high quality

products and services at competitive prices.

Employees

- The exceptional quality of our workforce provides a valuable competitive

edge. To build on this advantage, we will strive to hire and retain the most qualified people

available and to maximize their opportunities for success through training and

development. We are committed to maintaining a safe work environment enriched by

diversity and characterized by open communication, trust, and fair treatment.

Communities

- We commit to be a good corporate citizen in all the places we operate

worldwide. We will maintain high ethical standards, obey all applicable laws, rules, and

regulations, and respect local and national cultures. Above all other objectives, we are

dedicated to running safe and environmentally responsible operations.

ExxonMobil aspires to be at the leading edge of competition in every aspect of our

business. That requires the Corporation's resources -- financial, operational, technological,

and human -- to be employed wisely and evaluated regularly.

While we maintain flexibility to adapt to changing conditions, the nature of our business

requires a focused, long-term approach. We will consistently strive to improve efficiency

and productivity through learning, sharing, and implementing best practices. We will be

disciplined and selective in evaluating the range of capital investment opportunities

available to us. We will seek to develop proprietary technologies that provide a competitive

edge.

We aspire to achieve our goals by flawlessly executing our business plans and by adhering

to these guiding principles and the foundation policies that follow.

ExxonMobil Standards of Business Conduct Handbook — page 5

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Ethics Policy

The policy of the Company is to comply with all governmental laws, rules, and regulations

applicable to its business.

The Ethics policy does not stop there. Even where the law is permissive, the Company

chooses the course of highest integrity. Local customs, traditions, and values differ from

place to place, and this must be recognized. But honesty is not subject to criticism in any

culture. Shades of dishonesty simply invite demoralizing and reprehensible judgments. A

well-founded reputation for scrupulous dealing is itself a priceless corporate asset.

The Company cares how results are obtained, not just that they are obtained. Directors,

officers, and employees should deal fairly with each other and with our suppliers,

customers, competitors, and other third parties.

The Company expects compliance with its 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 Company’s directors and officers support, and expect

employees to support, any employee who passes up an opportunity or advantage that

would sacrifice ethical standards.

It is our policy that all transactions will be accurately reflected in its 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 Company’s books and records, and to

be honest and forthcoming with the Company’s internal and independent auditors.

The Company expects candor from employees at all levels and adherence to its policies and

internal controls. One harm which results when employees conceal information from

higher management or the auditors is that other employees think they are being given a

signal that the Company’s policies and internal controls can be ignored when they are

inconvenient. That can result in corruption and demoralization of an organization. The

Company’s system of management will not work without honesty, including honest

bookkeeping, honest budget proposals, and honest economic evaluation of projects.

It is our policy to make full, fair, accurate, timely, and understandable disclosure in reports

and documents that the Company files with the United States Securities and Exchange

Commission (or applicable regulatory bodies), and in other public communications. All

employees are responsible for reporting material information known to them to higher

management so that the information will be available to senior executives responsible for

making disclosure decisions.

ExxonMobil Standards of Business Conduct Handbook — page 6

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Conflicts of Interest Policy

It is the policy of the Company that directors, officers, and employees are expected to avoid

any actual or apparent conflict between their own personal interests and the interests of

the Company. A conflict of interest can arise when a director, officer, or employee takes

actions or has personal interests that may interfere with his or her objective and effective

performance of work for the Company. For example, directors, officers, and employees are

expected to avoid actual or apparent conflict in dealings with suppliers, customers,

competitors, and other third parties. Directors, officers, and employees are expected to

refrain from taking for themselves opportunities discovered through their use of corporate

assets or through their positions with the Company. Consistent with the Insider Trading

Policy, directors, officers, and employees are expected to avoid securities transactions

based on material, nonpublic information learned through their positions with the

Company. Directors, officers, and employees are expected to refrain from competing with

the Company.

ExxonMobil Standards of Business Conduct Handbook — page 7

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Corporate Assets Policy

It is the policy of the Company that directors, officers, and employees are expected to

protect the assets of the Company and use them efficiently to advance the interests of the

Company. Those assets include tangible assets and intangible assets, such as confidential

information of the Company or personal information held by the Company. No director,

officer, or employee should use or disclose at any time during or subsequent to

employment or other service to the Company, without proper authority or mandate,

personal or confidential information obtained from any source in the course of the

Company’s business. Examples of confidential information include nonpublic information

about the Company’s plans, earnings, financial forecasts, business forecasts, discoveries,

competitive bids, technologies, and personnel.

ExxonMobil Standards of Business Conduct Handbook — page 8

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Directorships Policy

It is the policy of the Company to restrict the holding by officers and employees of

directorships in nonaffiliated, for-profit organizations and to prohibit the acceptance by any

officer or employee of such directorships that would involve a conflict of interest with, or

interfere with, the discharge of the officer's or employee's duties to the Company. Any

officer or employee may hold directorships in nonaffiliated, nonprofit organizations, unless

such directorships would involve a conflict of interest with, or interfere with, the discharge

of the officer's or employee's duties to the Company or obligate the Company to provide

support to the nonaffiliated, nonprofit organizations. Officers and employees may serve as

directors of affiliated companies and such service may be part of their normal work

assignments.

All directorships in public companies held by directors of the Corporation are subject to

review and approval by the Board of Directors of the Corporation. In all other cases,

directorships in nonaffiliated, for-profit organizations are subject to review and approval by

the management of the Corporation as directed by the Chairman.

ExxonMobil Standards of Business Conduct Handbook — page 9

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Gifts and Entertainment Policy

It is the policy of the Company to base commercial decisions on commercial criteria. This

policy serves the Company’s business interests and fosters constructive relationships with

organizations and individuals doing business, or seeking to do business, with the Company.

In many cultures, those constructive relationships may include incidental business gifts and

entertainment. Directors, officers, employees, and third parties acting on behalf of the

Company providing or receiving third party gifts and entertainment in their corporate

capacities are expected to exercise good judgment in each case, taking into account

pertinent circumstances, including the character of the gift or entertainment, its purpose,

its appearance, the positions of the persons providing and receiving the gift or

entertainment, the business context, reciprocity, and applicable laws and social norms.

Gifts and entertainment must not be intended to create an improper advantage for the

Company. All expenditures for gifts and entertainment provided by the Company must be

accurately recorded in the books and records of the Company.

ExxonMobil Standards of Business Conduct Handbook — page 10

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Anti-Corruption Policy

It is the policy of the Company that directors, officers, employees and third parties acting

on its behalf are prohibited from offering or paying, directly or indirectly, any bribe to any

employee, official, or agent of any government, commercial entity, or individual in

connection with the business or activities of the Company. A bribe for purposes of this

policy is any money, goods, services, or other thing of value offered or given with the intent

to gain any improper advantage for the Company.

No director, officer, employee, or third party should assume that the Company’s interest

ever requires otherwise.

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Political Activities Policy

It is the policy of the Company to refrain from making contributions to political candidates

and political parties, except as permitted by applicable laws and authorized by the Board of

Directors.

It is the Company’s policy to communicate information and views on issues of public

concern that have an important impact on the Company.

The Company considers that registering and 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, state, 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 Company. Personal, lawful, political

contributions and decisions not to make contributions will not influence compensation, job

security, or opportunities for advancement.

ExxonMobil Standards of Business Conduct Handbook — page 12

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Trade Laws Policy

It is the policy of the Company that its directors, officers, and employees are expected to

comply with all trade laws, rules, and regulations (sanctions, export controls, customs, and

U.S. antiboycott) that are applicable to the Company’s business.

No director, officer, or employee should assume that the Company’s interest ever requires

otherwise.

It is recognized that, on occasion, there may be legitimate doubt as to the proper

interpretation of the law or that applicable laws may conflict. In such circumstances, it is

required that directors, officers, and employees refer the case through appropriate

channels to the Law Department for advice.

ExxonMobil Standards of Business Conduct Handbook — page 13

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Antitrust Policy

It is the policy of the Company that directors, officers, and employees are expected to

comply with the antitrust and competition laws of the United States and with those of any

other country or group of countries which are applicable to the Company’s business.

No director, officer, or employee should assume that the Company’s interest ever requires

otherwise.

It is recognized that, on occasion, there may be legitimate doubt as to the proper

interpretation of the law. In such a circumstance, it is required that the directors, officers,

and employees refer the case through appropriate channels to the Law Department for

advice.

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Insider Trading Policy

It is the policy of the Company that all directors, officers, and employees of ExxonMobil and

its subsidiaries are expected to avoid securities transactions based on material non-public

information learned through their positions with the Company. This Insider Trading Policy

(this “Policy”) provides the standards of the Company concerning trading in securities

(including stocks, bonds, notes or other equity or debt securities, whether or not issued by

the Company) while in possession of material non-public information.

It is the policy of the Company to comply with all applicable laws and regulations applicable

to its business, including the securities laws related to the Company trading in its own

securities.

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Health Policy

It is the Company’s policy to:

•

identify and evaluate health risks related to its operations that potentially affect its

employees, contractors or the public;

•

implement programs and appropriate protective measures to control such risks,

including appropriate monitoring of its potentially affected employees;

•

communicate in a reasonable manner to potentially affected individuals or

organizations and the scientific community knowledge about health risks gained from

its health programs and related studies;

•

determine at the time of employment and thereafter, as appropriate, the medical fitness

of employees to do their work without undue risk to themselves or others;

•

provide or arrange for medical services 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;

•

conduct and support research to extend knowledge about the health effects of its

operations;

•

undertake appropriate reviews and evaluations of its operations to measure progress

and to foster compliance with this policy;

•

provide voluntary health promotion programs designed to enhance employees' well-

being, productivity, and personal safety. These programs should supplement, but not

interfere with, the responsibility of employees for their own health care and their

relationships with personal physicians. Information about employees obtained through

the implementation of these programs should be considered confidential and should

not be revealed to non-medical personnel except: at the request of the employee

concerned, when required by law, when dictated by overriding public health

considerations, or when necessary to implement the Alcohol and Drug Use policy.

ExxonMobil Standards of Business Conduct Handbook — page 16

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Environment Policy

It is the Company’s policy to conduct its business in a manner that is compatible with the

balanced environmental and economic needs of the communities in which it operates. The

Company is committed to continuous efforts to improve environmental performance

throughout its operations.

Accordingly, the Company’s policy is to:

•

comply with all applicable environmental laws and regulations and apply responsible

standards where laws and regulations do not exist;

•

encourage concern and respect for the environment, emphasize every employee's

responsibility in environmental performance, and foster appropriate operating practices

and training;

•

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 its 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;

•

respond quickly and effectively to incidents resulting from its operations, in cooperation

with industry organizations and authorized government agencies;

•

conduct and support research to improve understanding of the impact of its business

on the environment, to improve methods of environmental protection, and to enhance

its capability to make operations and products compatible with the environment;

•

communicate with the public on environmental matters and share its experience with

others to facilitate improvements in industry performance;

•

undertake appropriate reviews and evaluations of its operations to measure progress

and to foster compliance with this policy.

ExxonMobil Standards of Business Conduct Handbook — page 17

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Safety Policy

It is the Company’s policy to conduct its business in a manner that protects the safety of

employees, others involved in its operations, customers, and the public. The Company will

strive to prevent all accidents, injuries, and occupational illnesses through the active

participation of every employee. The Company is committed to continuous efforts to

identify and eliminate or manage safety risks associated with its activities.

Accordingly, the Company’s policy is to:

•

design and maintain facilities, establish management systems, provide training and

conduct operations in a manner that safeguards people and property;

•

respond quickly, effectively, and with care to emergencies or accidents resulting from

its 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;

•

conduct and support research to extend knowledge about the safety effects of its

operations, and promptly apply significant findings and, as appropriate, share them with

employees, contractors, government agencies, and others who might be affected;

•

stress to all employees, contractors, and others working on its behalf their responsibility

and accountability for safe performance on the job and encourage safe behavior off the

job;

•

undertake appropriate reviews and evaluations of its operations to measure progress

and to foster compliance with this policy.

ExxonMobil Standards of Business Conduct Handbook — page 18

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Product Safety Policy

It is Company’s policy to:

•

identify and manage risks associated with its products and not manufacture or sell

products when it is not possible through proper design, procedures, and practices to

provide an appropriate level of safety for people and the environment;

•

specify precautions required in handling, transporting, using, and disposing of its

products and take reasonable steps to communicate them to employees, customers,

and others who might be affected;

•

comply with all applicable laws and regulations and apply responsible 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;

•

include identification and control of potentially adverse health, safety, and

environmental effects as priority considerations in the planning and development of

products;

•

conduct and support research to extend knowledge about the health, safety and

environmental effects of its products, and promptly apply significant findings and, as

appropriate, share them with its employees, contractors, customers, the scientific

community, government agencies, and the public;

•

undertake appropriate reviews and evaluations of its operations to measure progress

and to foster compliance with this policy.

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Customer Relations and Product Quality

The Company recognizes customer satisfaction is of primary importance to its success.

Mindful of its responsibility to the consumers it serves directly and the customers who

resell its products, the Company strives to understand their requirements and concerns and

to merit their business by responding effectively to their needs.

Specifically, the Company’s policy is to:

•

provide high-quality products that meet or exceed specifications and customer 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 its 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 Company’s products reach the ultimate consumer through

independent parties, such as service station dealers and distributors, the Company’s policy

is to actively encourage such parties to achieve standards comparable to those which have

been established for the Company’s own performance.

ExxonMobil Standards of Business Conduct Handbook — page 20

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Alcohol and Drug Use Policy

The Company is committed to a safe, healthy, and productive workplace for all employees.

The Company recognizes that alcohol, drug, or other substance abuse by employees will

impair their ability to perform properly and will have serious adverse effects on the safety,

efficiency and productivity of other employees and the Company as a whole. The misuse of

legitimate drugs, or the use, possession, distribution or sale of illicit or unprescribed

controlled drugs on Company business or premises, is strictly prohibited and is grounds for

termination. Possession, use, distribution, or sale of alcoholic beverages on Company

premises is not allowed without prior approval of appropriate senior management. Being

unfit for work because of use of drugs or alcohol is strictly prohibited and is grounds for

termination of employment. While this policy refers specifically to alcohol and drugs, it is

intended to apply to inhalants and all other forms of substance abuse.

The Company recognizes alcohol or drug dependency as a treatable condition. Employees

who suspect they have an alcohol or drug dependency are encouraged to seek advice and

to follow appropriate treatment promptly before it results in job performance problems.

Employee Assistance Program or medical professional staff will advise and assist in

securing treatment. Those employees who follow approved treatment will receive disability

benefits in accordance with the provisions of established benefit plans and medical

insurance coverage consistent with existing plans.

No employee with alcohol or drug dependency will be terminated due to the request for

help in overcoming that dependency or because of involvement in a rehabilitation effort.

However, an employee who has had or is found to have a substance abuse problem will

not be permitted to work in designated positions identified by management as being

critical to the safety and wellbeing of employees, the public, or the Company. Any

employee returning from rehabilitation will be required to participate in a Company-

approved aftercare program. If an employee violates provisions of the employee Alcohol

and Drug Use policy, appropriate disciplinary action will be taken. Such action cannot be

avoided by a request at that time for treatment or rehabilitation. If an employee suffering

from alcohol or drug dependency refuses rehabilitation or fails to respond to treatment or

fails to meet satisfactory standards of effective work performance, appropriate disciplinary

action, up to and including termination, will be taken. This policy does not require and

should not result in any special regulations, privileges, or exemptions from normal job

performance requirements.

The Company may conduct unannounced searches for drugs and alcohol on Company

owned or controlled property. The Company may also require employees to submit to

medical evaluation or alcohol and drug testing where cause exists to suspect alcohol or

drug use, including workplace incidents. Unannounced periodic or random testing will be

conducted when an employee meets any one of the following conditions: has had a

substance abuse problem, or is working in a designated position identified by

management, a position where testing is required by law, or a specified executive position.

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A positive test result or refusal to submit to a drug or alcohol test is grounds for disciplinary

action, including termination.

Contractor, common carrier, and vendor personnel are also covered by paragraph one and

the search provisions of paragraph four of this policy. Those who violate the policy will be

removed from Company premises and may be denied future entry.

In addition to the above policy, it is a requirement of the Company that all applicants

accepting offers of regular employment must pass a drug test.

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Equal Employment Opportunity Policy

It is the policy of the Company to provide equal employment opportunity in conformance

with all applicable laws and regulations to individuals who are qualified to perform job

requirements. The Company administers its personnel policies, programs, and practices in

a nondiscriminatory manner in all aspects of the employment relationship, including

recruitment, hiring, work assignment, promotion, transfer, termination, wage and salary

administration, and selection for training.

Managers and supervisors are responsible for implementing and administering this policy,

for maintaining a work environment free from unlawful discrimination, and for promptly

identifying and resolving any problem area regarding equal employment opportunity.

In addition to providing equal employment opportunity, it is also the Company’s policy to

undertake special efforts to:

•

develop and support educational programs and recruiting sources and practices that

facilitate employment of a globally diverse workforce;

•

develop and offer work arrangements that help to meet the needs of the work force in

balancing work and family obligations;

•

establish company training and developmental efforts, practices, and programs that

support global diversity in the work force;

•

foster a work environment free from sexual, racial, or other harassment;

•

make reasonable accommodations that enable qualified disabled individuals to perform

the essential functions of their jobs;

•

emphasize management responsibility in these matters at every level of the

organization.

Individuals who believe they have observed or been subjected to prohibited discrimination

should immediately report the incident to their supervisors, higher management, or their

designated Human Resources Department contacts.

Individuals will not be subjected to harassment, intimidation, discrimination, or retaliation

for exercising any of the rights protected by this policy and the various EEO statutes.

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Harassment in the Workplace Policy

It is the policy of the Company to prohibit any form of harassment in any Company

workplace. The objective of this policy is to provide a work environment that fosters mutual

employee respect and working relationships free of harassment. The Company specifically

prohibits any form of harassment by or toward employees, contractors, suppliers, or

customers.

Under the Company’s policy, harassment is any inappropriate conduct which has the

purpose or effect of:

•

creating an intimidating, hostile, or offensive work environment;

•

unreasonably interfering with an individual's work performance; or

•

affecting an individual's employment opportunity.

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 supervisors and

managers, will be subject to disciplinary action up to and including termination for any act

of harassment.

Individuals who believe they have been subjected to harassment should immediately report

the incident to their supervisors, higher management, or their designated Human

Resources Department contacts. All complaints will be promptly and thoroughly

investigated.

Employees or supervisors who observe or become aware of harassment should

immediately advise their supervisors, higher management, or their designated Human

Resources Department contacts. No employee should assume that the Company is aware

of a problem. All complaints and concerns should be brought to management's or the

Human Resources Department's attention so that appropriate corrective steps can be

taken.

No retaliation will be taken against any employee because he or she reports a problem

concerning possible acts of harassment. Employees can raise concerns and make reports

without fear of reprisal. Questions about what constitutes harassing behavior should be

directed to the employee's supervisor or Human Resources Department contact.

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Procedures and Open Door Communication

The Company encourages employees to ask questions, voice concerns, and make

appropriate suggestions regarding the business practices of the Company. Employees are

expected to report promptly to management suspected violations of law, the Company’s

policies, and the Company’s internal controls, so that management can take appropriate

corrective action. The Company promptly investigates reports of suspected violations of

law, policies, and internal control procedures.

Management is ultimately responsible for the investigation of and appropriate response to

reports of suspected violations of law, policies, and internal control procedures. Internal

Audit has primary responsibility for investigating violations of the Company’s internal

controls, with assistance from others, depending on the subject matter of the inquiry. The

persons who investigate suspected violations are expected to exercise independent and

objective judgment.

Normally, an employee should discuss such matters with the employee's immediate

supervisor. Each supervisor is expected to be available to subordinates for that purpose. If

an employee is dissatisfied following review with the employee's immediate supervisor,

that employee is encouraged to request further reviews, in the presence of the supervisor

or otherwise. Reviews should continue to the level of management appropriate to resolve

the issue.

Depending on the subject matter of the question, concern, or suggestion, each employee

has access to alternative channels of communication, for example, the Finance

Department; Internal Audit; the Human Resources Department; the Law Department; the

Safety, Health and Environment Department; the Security Department; and the Treasurer's

Department.

Suspected violations of law or the Company’s policies involving a director or executive

officer, as well as any concern regarding questionable accounting or auditing matters,

should be referred directly to the General Auditor of the Company. The Nominating and

Governance Committee of the Board of Directors of the Company will initially review all

issues involving directors or executive officers and will then refer all such issues to the

Board of Directors of the Company.

Employees may also address communications to individual nonemployee directors or to

the nonemployee directors as a group by writing them at ExxonMobil, 22777 Springwoods

Village Parkway, Spring, Texas 77389, U.S.A., or such other addresses as the Company

may designate and publish from time to time.

Employees wishing to make complaints without identifying themselves may do so by

telephoning 1-800-963-9966 or 1-346-335-6100, or by writing the Global Security

Manager, Exxon Mobil Corporation, P. O. Box 7537, Spring, Texas 77387, U.S.A., or such

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other telephone numbers and addresses as the Company may designate and publish from

time to time. All complaints to those telephone numbers and addresses concerning

accounting, internal accounting controls, or auditing matters will be referred to the Audit

Committee of the Board of Directors of the Company.

All persons responding to employees' questions, concerns, complaints, and suggestions are

expected to use appropriate discretion regarding anonymity and confidentiality, although

the preservation of anonymity and confidentiality may or may not be practical, depending

on the circumstances. For example, investigations of significant complaints typically

necessitate revealing to others information about the complaint and complainant. Similarly,

disclosure can result from government investigations and litigation.

No action may be taken or threatened against any employee for asking questions, voicing

concerns, or making complaints or suggestions in conformity with the procedures

described above, unless the employee acts with willful disregard of the truth.

Failure to behave honestly, and failure to comply with law, the Company’s policies, and the

Company’s internal controls may result in disciplinary action, up to and including

separation.

No one in the Company has the authority to make exceptions or grant waivers to the

Company’s foundation policies. It is recognized that there will be questions about the

application of the policies to specific activities and situations. In cases of doubt, directors,

officers, and employees are expected to seek clarification and guidance. In those instances

where the Company, after review, approves an activity or situation, the Company is not

granting an exception or waiver but is determining that there is no policy violation. If the

Company determines that there is or would be a policy violation, appropriate action is

taken.

ExxonMobil Standards of Business Conduct Handbook

Prompt to Clone This ExxonMobil Standards of Business Conduct Handbook

Apply this example's core structure, strategic pacing, and structural hierarchy directly to your own topic.

What are you generating today?