Embedding Standards at All Levels of Our Company

Corruption, whether in the private or public sector, is a significant barrier to sustainable economic and social development. It’s also illegal. As a responsible global citizen, Nexen is committed to doing business free from all forms of corruption.

This commitment is endorsed by our executive management team who emphasize that compliance with our standards of integrity is supported at the highest level of our organization. These standards apply to all of us — every employee, director and officer is required to comply with our policies and is personally responsible for refusing to pay bribes or make improper payments.

Supporting our Culture of Integrity

Nexen’s culture and processes support our commitment in this area. Our Standard for Prevention of Improper Payments requires that all employees comply with applicable laws everywhere we operate. How We Work: Our Integrity Guide for Suppliers sets out expectations for our suppliers regarding high risk behaviours, including those relating to corruption. The Prevention of Improper Payments Policy is periodically reviewed for best practices, vetted by external counsel and reviewed by our Compliance Committee.

The Compliance Committee is comprised of members of our executive management team and provides oversight on potential high risk payments. Approvals required under the Prevention of Improper Payments Policy are dealt with by this Committee, which also receives a report on high risk payments. This information is also reported to the Board of Directors. As an additional control, our internal audit department assesses corruption risk on a periodic basis and conducts investigations if necessary.

Risk-based Prevention of Improper Payments training has been developed that provides employees in high risk positions with guidance on avoiding improper payments.