Ethics and Standards of Business Conduct

Corporate citizenship at Imperial is integrated in the 17 policies that make up our Standards of Business Conduct. We ensure long-term performance through our management systems, which include System of Management Control Basic Standards, Controls Integrity Management System (CIMS), Operations Integrity Management System (OIMS), and Best Practices in External Affairs (BPEA).

Standards of Business Conduct

Imperial's Standards of Business Conduct form the foundation of our commitment to the highest ethical standards and provide each of our employee and non-employee directors with a common set of ethical standards. The Standards consist of guiding principles, 17 foundation policies and open-door communication procedures. The Standards include clear guidance on ethics, gifts and entertainment, conflicts of interest, antitrust and directorship policies. Responsibilities for authorizing, approving and recording financial transactions are appropriately segregated to reduce risks.

Employees and directors are required to fully comply with the Standards. Disciplinary action is taken against any employee who violates these Standards. The Standards are also reflected in contracts with suppliers and customers. Each year directors, officers and employees review the Standards. In addition, directors and employees in positions of higher risk of exposure to ethical or conflict-of-interest situations are required to sign a statement acknowledging their familiarity with the Standards and that they have made the requisite disclosures to management.

No one at Imperial has the authority to make exceptions or grant waivers with respect to the Standards. Our integrity and reputation depend on our employees’ understanding of and compliance with these policies. Employees, including supervisors and managers, are subject to disciplinary action up to and including termination for violation of our policies. In addition, contractors who violate our policies may be denied site access.

To learn more read our code of ethics document.

Effective February, 2021 the Code of Ethics Procedures and Open Door Communication policy was amended to update the company’s ethics “hotline” that is operated by a third party service provider. The ethics hotline offers confidential, anonymous reporting 24 hours a day, seven days a week. No other changes were made to the Code of Ethics.

Human rights

Imperial does not tolerate violations of human rights in any form in its business. Our Standards of Business Conduct provide a framework for operating responsibly and are consistent with the spirit and intent of the Canadian Charter of Rights and Freedoms and the United Nations’ Universal Declaration of Human Rights as it applies to private companies.

Imperial's statement on labour in the workplace

Read Imperial’s statement on labour in the workplace

Imperial’s report on fighting against forced labour and child labour in supply chains

Read Imperial's Fighting Against Forced and Child Labour Report 2023

Imperial supplier, vendor and contractor expectations

Imperial holds its suppliers, vendors and contractors to stringent compliance, anti-corruption, nonconflict, safety and other guidelines in order to stay in good standing.

Imperial expects its suppliers, vendors and contractors to:

• comply with laws, rules and regulations applicable to their business;
• comply with their contractual obligations and perform their activities balancing economic growth, social development and environmental protection;
• avoid any conflict of interest;
• not offer, pay, directly or indirectly, any bribe or engage in any corrupt practice;
• comply with antitrust and competition laws;
• promote a safe, secure and healthy workplace;
• apply continuous efforts to improve safety, security, health and environmental performance and foster appropriate operating practices and training;
• endeavor to provide positive, productive and supportive work environments;
• conduct operations and business practices in a manner consistent with the Fundamental Principles and Rights at Work of the 1998 International Labour Organization (ILO) Declaration, including the elimination of child labor, forced labor and workplace discrimination and the recognition of freedom of association; and
• manage activities in a manner that respects human rights and is consistent with the United Nations Guiding Principles on Business and Human Rights in effect as of 2011.

The links below provide further information:

• Imperial Code of Ethics and Business Conduct
• Imperial Statement on Labor and the Workplace
• Imperial Sustainability Report
• ILO 1998 Declaration on Fundamental Principles and Rights at Work
• UN Guiding Principles on Business and Human Rights

Control systems

Business control systems are rigorously applied at our operations across Canada. Our System of Management Control Basic Standards defines the basic principles, concepts and standards that make up our business controls. Our Controls Integrity Management System provides a structured approach for assessing financial-control risks, establishing procedures for mitigating concerns, monitoring compliance with standards and reporting results to management. Regular self-assessments and audits ensure that operating controls and standards are met by every operating unit. Our controls meet or exceed the requirements of the Sarbanes-Oxley Act and the NYSE listing standards. An independent assessment carried out annually by registered auditors PricewaterhouseCoopers LLP confirms that our internal controls system is effective.

Operations Integrity Management System

Our Operations Integrity Management System (OIMS) has been in place since 1992 and addresses safety, health, security and environmental risks at our facilities. OIMS provides a systematic, structured, and disciplined approach across our businesses and facilities and enables us to measure progress and management accountability in these areas. It also ensures that we appropriately engage with the communities in which we operate.

OIMS is embedded in day-to-day work processes to establish common expectations that every operating unit must fulfill to proactively manage risk. Over time, it has become a part of our culture and the way our organization works, improving operations reliability and reducing safety, security, health and environmental risks and impacts. OIMS is implemented over the complete life cycle of a project – from exploration and development to production and reclamation – and ensures that management is accountable for results. We expect our business-line managers to comply with all OIMS requirements and conduct OIMS assessments of our operations annually.

Managing operational integrity

The overall effectiveness of OIMS is reviewed every five years and adjusted accordingly. As a result, OIMS has been continuously improved to include behaviour-based safety, security, environmental matters and enhanced community involvement.

In 2010, Lloyd’s Register Quality Assurance, Inc. (LRQA) confirmed that OIMS meets the requirements of the ISO 14001 standard for environmental management systems. LRQA also recognized that OIMS meets all the requirements of the Occupational Health and Safety Assessment Series for health and safety management systems (OHSAS 18001).

Operational integrity assessments

Under OIMS, every operating unit undergoes a regular cycle of improvement with self-assessments each year and external assessments every three to five years. External assessments are conducted by company experts outside the operating unit being assessed.

In each case, opportunities for improvement are identified and addressed, and progress is monitored through regular management reviews.

Responsible Caring^®

Another confirmation of OIMS effectiveness is our participation in Responsible Caring®, an initiative of the Chemistry Industry Association of Canada (CIAC) that requires CIAC members to dedicate themselves, their technology and their business practices to sustainability – the ongoing betterment of society, the environment and the economy. Many of their strict codes of practice govern the safe and environmentally responsible handling of chemicals throughout their life cycle. At Imperial Oil, these codes are met by OIMS. In addition to conducting self-assessments, all CIAC members, as a condition of membership, undergo verification by an external team every three years to determine if they are continuing to meet Responsible Caring® requirements. Companies, for example, are tested for evidence that they:

• have effective personnel and process safety management systems
• are able to manage emergencies
• identify, manage and work to minimize emissions and wastes
• assess the ability of distributors to correctly handle their products
• know community concerns and respond sensitively to them

Best Practices in External Affairs

At Imperial, we are continually working to enhance the quality of our community engagement and external relations. We use a strategic planning and management tool, called Best Practices in External Affairs (BPEA), to develop and carry out comprehensive and robust community awareness plans. This tool enables us to optimize the impact and value of community outreach programs by managing relationships with external stakeholders through better understanding of the viewpoints and concerns of the diverse communities in which we operate. Public Affairs works with different operations to increase their understanding of the tool, to identify local requirements for stakeholder engagement and to help them develop an action plan. Each operation stewards their community relations performance against the plan.