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Corporate Compliance Plan
Management Team Assignment #3
Josephine Porto
Nathalie Perez
Michael Bergouignan
Michael Meyer
EXXON VALDEZ
Mission Statement

Our mission is to provide the world with a more efficient lifestyle through the fuel that will be
made by the use of our oil. We will comply with all environmental policies to ensure the
safety of all living things and the places they call home. We promise to preserve the
ecosystem through our charitable foundations to ensure its safety. We will provide jobs for
many in a thriving industry ensuring an upward shift in our economy. Let’s keep the world
moving together.

Statement of Values

	 At Exxon-Valdez, all of our personnel, directors and officers share a set of values.
These values include: integrity, honesty, respect and seeking knowledge. We also value the
safety of our environment and personnel. We believe Exxon-Valdez can best recognize and
respond to the needs, opportunities, and concerns related to our mission. 

Code of Conduct Statement

Here at Exxon-Valdez, our goal is to achieve and maintain the highest ethical standards
through promoting integrity along with a strong, moral conduct. It is the duty of all of our
employees and business partners to act with respect and understanding for one another
while taking care to pay high regards for both our communities and the environment alike.
With this said we expect all personnel employed and salaried by Exxon-Valdez to
understand and abide by the Code of Conduct and to keep the best interest of our
company in mind when making decisions both on and off the job.

The Exxon-Valdez Code of Conduct Statement applies to all employees, directors and
officers in the company. The standards promote anti-corruption in the work environment as
well as support human rights and labor values. If there is ever a doubt or uncertainty about
any situation in the workplace, we encourage all of our employees to ask for guidance. All
employees at Exxon-Valdez are expected to comply and to review the standards every year.

	 Our code of conduct is very important to us here at Exxon-Valdez because we strive
to remain reputable and trusted by our shareholders, personnel and the community. In the
EXXON-VALDEZ
event that the Code of Conduct has been violated, there will be repercussions and
disciplinary action will be taken against any employee or director who violates the standard.



Drugs and Alcohol Consumption Policy

Marine personnel will be required to not consume any drugs and alcohol before and during
their shift. All new employees will be put through testing for drug consumption. Every
employee will be subject to random drug testing. If any employee fails to the random drug
test or if the employee is intoxicated in the workplace, this will lead to termination of
employment; except when the use is prescribed by a licensed medical practitioner, who is
familiar with the employee’s medical history and has advised the employer that the
substance will not adversely affect the employee’s ability to safely operate a motor vehicle,
machinery, etc. Medical examiners are required to give careful consideration to the effects
of medications on the employee’s ability to operate a machine, vehicle safely before
rendering the employee qualified.

These regulations are to provide a means to deter the illegal use of substances by marine
personnel and to promote a drug-free and safe work environment for carriage of cargo on
U.S. waterways.

Company Training

All new employees will be required to complete a six week course pertaining to all
situations they can experience on the job. Upon completion of the course they will be
required to pass an examination on the contents learned and only if a satisfactory score is
received will they be allowed to operate in any aspect of the company. After completion of
the course and examination the employee will learn on the job in a mentor program
implemented by the company. This program will allow the new employee to learn from our
most experienced crew members and further polish their skills. The company will also be
committed on improving the skills of their employees by the continuation of education. We
will provide each employee with a refresher course every third year to refine their
knowledge and prevent error.

EXXON-VALDEZ
Managers in each division of the company will also be trained in the process of identifying
problems and resolving them. Once a problem is identified the manager will then be held
responsible for making sure that his/her staff is adequately trained in the process of
resolving the issue at hand. They will be responsible for monitoring each of their employees
to make sure what areas their employees need refining of their skills and implement a
program to educate them. This process will be done in patterns allowing enough personnel
to be staffed as needed per the requirements of the company.

The Exxon-Valdez Corporation realizes that employees can not be held liable for policy,
procedures and legal standards for which they are unaware of. For this reason the company
will make sure that each representative of the company receives adequate education on all
of these topics to prevent errors from occurring.

Communication Efforts

The company will provide an open line of communication between personnel and
management. All employees seeking for answers to questions or reporting potential
violations of the law, should know with whom to speak for answers without fear of
retaliation. In addition, Exxon-Valdez expects that employees will inform the company of
any known or suspected offense. In support of this, the company has developed policies
and orientation programs. It is expected that when comfortable doing so, the concerned
party should report concerns to his or her supervisor. For those instances where the
individual is not comfortable with this avenue, the company has established an anonymous
reporting system called The Hotline .The Hotline is going to be an 800 number that will be
provided to each employee. Another avenue the employee can use is a forum for
communication, which only employees and employers can access this forum and where
they can post their concerns anonymously. No matter which avenue is pursued, Exxon-
Valdez emphasizes that raised concerns will be treated with respect and confidentiality.

Any false allegations will result in an investigation of the victim and tracking of the employee
who made false allegations. All violators will be subject to disciplinary action. The exact
nature of discipline will depend on the nature, severity and frequency of the allegation. After
the violator has been found, the organization will take reasonable steps to correct the area
of concern.
Oversight Policy

The success of Exxon-Valdez includes a high level of oversight. Oversight requires an
ongoing effort of making sure each employee is doing what he or she is required to do.
Exxon is committed to consistently review to detect any violation to the company’s policy. If
any violation is made to these policies, there are penalties in place in order to deter from
further wrongdoing.

Exxon also encourages whistleblowers. Those who bring forth information about others
wrongdoings in the company will be kept unanimous.

Whistleblower Policy

In Exxon-Valdez, The whistleblower policy is intended to encourage employees, directors,
and any other board members to report any instances that are illegal, unethical and
inappropriate. A whistleblower is expected to report any suspicious event to their superior
as soon as they can. If the whistleblower feels uncomfortable reporting an event, they have
the option to do so anonymously and without retaliation or retribution. In the event that
anyone retaliates against the whistleblower they will be subject to discipline, including
termination of employee status. The Identity of the whistleblower will remain confidential
unless the issue requires investigation by law enforcement.

Adequate Personnel

There should be a minimum of 15 crew members on duty at all times. These crew members
are responsible for the normal operations of the terminal. The crew members must also
have the skills to respond to a number of emergency situations in a timely manner. In order
to prevent tired and fatigued workers, a daily shift must not exceed 10 hours.
Shortage of Equipment

Our company will ensure that all equipment is tested and approved through rigorous testing
to ensure the quality of the product we provide and to ensure that accidents do not occur.
There will be no shortage of equipment in the company, in a situation where a spill occurs,
we will ensure that enough proper equipment is readily available to our employees to make
sure the spill can be contained in enough time as mandated by the government.

	 The company will ensure that sufficient funds are spent annually in the purchasing
and testing of this equipment. We will maintain good relationships with the distributors and
manufacturers to ensure that all equipment is shipped and received by the company
quickly.

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Corporate Compliance Plan

  • 1. Corporate Compliance Plan Management Team Assignment #3 Josephine Porto Nathalie Perez Michael Bergouignan Michael Meyer EXXON VALDEZ
  • 2. Mission Statement Our mission is to provide the world with a more efficient lifestyle through the fuel that will be made by the use of our oil. We will comply with all environmental policies to ensure the safety of all living things and the places they call home. We promise to preserve the ecosystem through our charitable foundations to ensure its safety. We will provide jobs for many in a thriving industry ensuring an upward shift in our economy. Let’s keep the world moving together. Statement of Values At Exxon-Valdez, all of our personnel, directors and officers share a set of values. These values include: integrity, honesty, respect and seeking knowledge. We also value the safety of our environment and personnel. We believe Exxon-Valdez can best recognize and respond to the needs, opportunities, and concerns related to our mission. Code of Conduct Statement Here at Exxon-Valdez, our goal is to achieve and maintain the highest ethical standards through promoting integrity along with a strong, moral conduct. It is the duty of all of our employees and business partners to act with respect and understanding for one another while taking care to pay high regards for both our communities and the environment alike. With this said we expect all personnel employed and salaried by Exxon-Valdez to understand and abide by the Code of Conduct and to keep the best interest of our company in mind when making decisions both on and off the job. The Exxon-Valdez Code of Conduct Statement applies to all employees, directors and officers in the company. The standards promote anti-corruption in the work environment as well as support human rights and labor values. If there is ever a doubt or uncertainty about any situation in the workplace, we encourage all of our employees to ask for guidance. All employees at Exxon-Valdez are expected to comply and to review the standards every year. Our code of conduct is very important to us here at Exxon-Valdez because we strive to remain reputable and trusted by our shareholders, personnel and the community. In the EXXON-VALDEZ
  • 3. event that the Code of Conduct has been violated, there will be repercussions and disciplinary action will be taken against any employee or director who violates the standard. Drugs and Alcohol Consumption Policy Marine personnel will be required to not consume any drugs and alcohol before and during their shift. All new employees will be put through testing for drug consumption. Every employee will be subject to random drug testing. If any employee fails to the random drug test or if the employee is intoxicated in the workplace, this will lead to termination of employment; except when the use is prescribed by a licensed medical practitioner, who is familiar with the employee’s medical history and has advised the employer that the substance will not adversely affect the employee’s ability to safely operate a motor vehicle, machinery, etc. Medical examiners are required to give careful consideration to the effects of medications on the employee’s ability to operate a machine, vehicle safely before rendering the employee qualified. These regulations are to provide a means to deter the illegal use of substances by marine personnel and to promote a drug-free and safe work environment for carriage of cargo on U.S. waterways. Company Training All new employees will be required to complete a six week course pertaining to all situations they can experience on the job. Upon completion of the course they will be required to pass an examination on the contents learned and only if a satisfactory score is received will they be allowed to operate in any aspect of the company. After completion of the course and examination the employee will learn on the job in a mentor program implemented by the company. This program will allow the new employee to learn from our most experienced crew members and further polish their skills. The company will also be committed on improving the skills of their employees by the continuation of education. We will provide each employee with a refresher course every third year to refine their knowledge and prevent error. EXXON-VALDEZ
  • 4. Managers in each division of the company will also be trained in the process of identifying problems and resolving them. Once a problem is identified the manager will then be held responsible for making sure that his/her staff is adequately trained in the process of resolving the issue at hand. They will be responsible for monitoring each of their employees to make sure what areas their employees need refining of their skills and implement a program to educate them. This process will be done in patterns allowing enough personnel to be staffed as needed per the requirements of the company. The Exxon-Valdez Corporation realizes that employees can not be held liable for policy, procedures and legal standards for which they are unaware of. For this reason the company will make sure that each representative of the company receives adequate education on all of these topics to prevent errors from occurring. Communication Efforts The company will provide an open line of communication between personnel and management. All employees seeking for answers to questions or reporting potential violations of the law, should know with whom to speak for answers without fear of retaliation. In addition, Exxon-Valdez expects that employees will inform the company of any known or suspected offense. In support of this, the company has developed policies and orientation programs. It is expected that when comfortable doing so, the concerned party should report concerns to his or her supervisor. For those instances where the individual is not comfortable with this avenue, the company has established an anonymous reporting system called The Hotline .The Hotline is going to be an 800 number that will be provided to each employee. Another avenue the employee can use is a forum for communication, which only employees and employers can access this forum and where they can post their concerns anonymously. No matter which avenue is pursued, Exxon- Valdez emphasizes that raised concerns will be treated with respect and confidentiality. Any false allegations will result in an investigation of the victim and tracking of the employee who made false allegations. All violators will be subject to disciplinary action. The exact nature of discipline will depend on the nature, severity and frequency of the allegation. After the violator has been found, the organization will take reasonable steps to correct the area of concern.
  • 5. Oversight Policy The success of Exxon-Valdez includes a high level of oversight. Oversight requires an ongoing effort of making sure each employee is doing what he or she is required to do. Exxon is committed to consistently review to detect any violation to the company’s policy. If any violation is made to these policies, there are penalties in place in order to deter from further wrongdoing. Exxon also encourages whistleblowers. Those who bring forth information about others wrongdoings in the company will be kept unanimous. Whistleblower Policy In Exxon-Valdez, The whistleblower policy is intended to encourage employees, directors, and any other board members to report any instances that are illegal, unethical and inappropriate. A whistleblower is expected to report any suspicious event to their superior as soon as they can. If the whistleblower feels uncomfortable reporting an event, they have the option to do so anonymously and without retaliation or retribution. In the event that anyone retaliates against the whistleblower they will be subject to discipline, including termination of employee status. The Identity of the whistleblower will remain confidential unless the issue requires investigation by law enforcement. Adequate Personnel There should be a minimum of 15 crew members on duty at all times. These crew members are responsible for the normal operations of the terminal. The crew members must also have the skills to respond to a number of emergency situations in a timely manner. In order to prevent tired and fatigued workers, a daily shift must not exceed 10 hours.
  • 6. Shortage of Equipment Our company will ensure that all equipment is tested and approved through rigorous testing to ensure the quality of the product we provide and to ensure that accidents do not occur. There will be no shortage of equipment in the company, in a situation where a spill occurs, we will ensure that enough proper equipment is readily available to our employees to make sure the spill can be contained in enough time as mandated by the government. The company will ensure that sufficient funds are spent annually in the purchasing and testing of this equipment. We will maintain good relationships with the distributors and manufacturers to ensure that all equipment is shipped and received by the company quickly.