How We Work: Our Integrity Guide

LOOKING AFTER OUR BUSINESS AND OUR SHARED FUTURE

MANAGING OUR RELATIONSHIPS

RESPECTING EACH OTHER

WORKING PROFESSIONALLY

OUR INTEGRITY GUIDE

INTEGRITY MATTERS 1

WHAT WE’RE ABOUT 3

IT’S UP TO ALL OF US 4

HOW WE WORK WITH INTEGRITY AT A GLANCE 6

RESPECTING EACH OTHER 8

WORKING PROFESSIONALLY 14

LOOKING AFTER OUR BUSINESS AND OUR SHARED FUTURE 20

MANAGING OUR RELATIONSHIPS 26

WHAT TO DO IF YOU HAVE A CONCERN 32

INDEX 36

Contents

Nexen has a long and proud history of working with integrity. As an upstream oil and gas producer, the work we do is focused on responsibly developing energy resources in some of the world’s most significant basins. From our earliest days in Western Canada, to becoming a global energy producer, our employees have always been focused on working in a safe, ethical and responsible manner. This focus has helped Nexen earn a positive reputation for the way we work.

Integrity matters

As a wholly-owned subsidiary of CNOOC Limited, our commitment to working with integrity remains the foundation of our business. All of our Key Results cannot be delivered without a culture of integrity. It is an investment that not only earns us trust and respect from our employees, customers, partners, communities and host governments, but also builds long term business value.

This Integrity Guide is a reference document that includes practical advice on ethical and legal decision-making as well as Q&As, examples, and stories of how we live and work when we are guided by our values. It also provides links to Nexen policies and other resources that help ensure our employees’ actions are consistent with our commitments.

For me, integrity is part of my cultural heritage and is the foundation for how I conduct myself. This means holding myself and others accountable for making ethical and responsible decisions both at home and at work.

As you read the Integrity Guide, I hope you take away a clear understanding of integrity and a renewed sense of why integrity matters in our lives and in the work we do each and every day.

Fang Zhi

CEO, Nexen Energy

HOW WE WORK: OUR INTEGRITY GUIDE 1

2 HOW WE WORK: OUR INTEGRITY GUIDE

Nexen’s WayOur purposeWe create value by responsibly supplying the energy that fuels people’s lives.

The world needs clean, secure and affordable energy. We meet this need by harnessing our exceptional talent, world class assets and progressive technology to find and develop oil and gas resources around the world. It’s Nexen’s way of building a profitable and responsible business.

Our valuesProtecting people and the environment: We each play a role in protecting the safety and well-being of ourselves, our co-workers and the communities and environment in which we work.

Commitment to excellence: We drive for, and reward, high performance. We are passionate about delivering results and innovative in overcoming obstacles.

Accountability: We each know our responsibilities and are accountable for our decisions, behaviour and actions. We measure our results to validate our individual and shared ownership of Nexen’s successes and shortcomings.

Integrity: We conduct business in an ethical manner and build relationships based on collaboration, honesty and respect.

Courage: We’re not afraid to break from the pack. We have the confidence to speak up and make difficult decisions. We take informed risks based on facts to grow value responsibly.


It’s up to all of us

How We Work: Our Integrity Guide is a resource for all of us. It’s important that everyone – including Nexen Energy ULC’s board of directors, employees and others acting on our behalf – commit to working with integrity. All employees should use the Integrity Guide, along with corporate policies, to help them make decisions and do the right thing.

When conducting business for Nexen, contractors, consultants, agents and partners are expected to observe the same ethical standards as employees. All of us do this by:

This is a workforce that understands our unique culture, meets ethical and legal behaviour expectations and passionately contributes to our success. At Nexen, that’s how we work.

• ensuring we are familiar with the Integrity Guide, policies, laws and regulations that govern our business, especially those relating to our jobs

• participating in our integrity and compliance education programs, including an Integrity Workshop within three months of hire

• acknowledging compliance with the Integrity Guide and other applicable policies annually through the Statement of Compliance process

• promptly reporting any concerns, suspected or actual violations of the Integrity Guide, the policies referenced in it or any applicable law

• reporting issues honestly and in good faith

• cooperating fully and honestly in investigations of alleged illegal or unethical activity

This symbol, found throughout How We Work: Our Integrity Guide, indicates that additional contact and reference information is available on the “Where to Go” sheet at the back of this guide.


Everywhere we operate, our commitment to integrity stays the same. Our culture of integrity is strong and we have robust processes in place to protect the interests of our people, our business and our shared future. Our Integrity Guide provides us with a common framework for managing ourselves and addressing integrity concerns.

Nexen managers have additional responsibilities.

It’s important for managers to demonstrate these additional responsibilities by:

• hiring individuals or firms who do business in a way that’s consistent with Nexen’s values and how we do business

• sustaining an environment where the people who report to us, and others who do business on our behalf, understand the importance of following the Integrity Guide and complying with the policies referenced in it or any applicable law

• ensuring our employees receive applicable integrity and compliance education

• recognizing and reinforcing ethical behaviour

• supporting employees or external stakeholders who report unethical business practices

• encouraging people with concerns to raise them and directing them to seek advice if we’re unable to help them

• preventing retaliation towards any employee or external stakeholder who reports or assists in the investigation of an integrity-related concern

• disclosing to the Integrity and Compliance Group actual or alleged violations of the Integrity Guide and the policies referenced in it

• becoming familiar with the Speaking Up Policy for more information on raising and receiving issues, and preventing retaliation

Speaking Up Policy (A163) It is up to each of us to use the Integrity Guide, combined with our good judgment, to understand and adhere to the ethical business practices explored here. This is important to Nexen. Not complying with these practices may result in corrective action, up to and including termination of employment. Depending on the situation, behaving in a way inconsistent with the Integrity Guide could also result in personal liability or legal sanctions.


How we work with integrity at a glance

RESPECTING EACH OTHER 8• we provide a healthy and

safe working environment for our people ...................... 9

• we operate a respectful and inclusive workplace .... 10

• we respect human rights ... 12

• we protect the privacy of others and their personal information ......... 13

WORKING PROFESSIONALLY 14• we use social media safely

and respectfully ................... 15

• we use information technology resources responsibly .......................... 15

• we respect confidentiality and safeguard intellectual property ........... 16

• we handle inside information appropriately ....................... 18

• we come to work fit for duty, unaffected by alcohol, drugs and medication ........ 19

LOOKING AFTER OUR BUSINESS AND OUR SHARED FUTURE 20• we compete aggressively

and fairly .............................. 21

• we ensure the accuracy and completeness of our business records ...................22

• we communicate honestly with investors, media and other stakeholders .............. 23

• we protect our assets and maintain a secure work environment .............. 24

• we conduct our business with respect and care for the natural environment .... 24

MANAGING OUR RELATIONSHIPS 26• we proactively avoid

or manage conflicts of interest ............................ 27

• we don’t give or receive inappropriate gifts or entertainment ........ 28

• we do not pay bribes or make improper payments ............ 29

• we engage openly in the communities where we operate ........................... 30

• we speak up when we see violations of policy or laws .................................. 33


MAKING ETHICAL DECISIONS ...........................32

QUESTIONS TO ASK YOURSELF ............................32

SPEAKING UP .......................33

HOW YOU’RE PROTECTED AGAINST RETALIATION ........35

What to do if you have a concern

TALK TO AND CONSULT WITH

OTHERS

CONSIDER YOUR OPTIONS

TEST YOUR DECISION

RECOGNIZE THE ISSUE

TAKE RESPONSIBLE

ACTION

Making decisions based on our values and commitments strengthens our culture of integrity and builds long-term business value. Using conversation to make these key decisions is how we work at Nexen. It allows us to share knowledge, fulfill our commitments and foster a learning culture, while ensuring we are aligned with our mission and values.


RESPECTING EACH OTHERHow respecting and supporting each other impacts our work environment


Our commitment to health and safety isn’t just a corporate obligation; it’s embedded in our corporate culture and is an essential component of how we create long-term value. We provide a healthy and safe work environment aligned with regulations, local laws and industry best practice.

This is how we provide a healthy and safe working environment for our people:

• we meet or exceed regulatory requirements and apply widely-recognized industry standards, codes and best practices in the absence of regulations

• we apply the principles of process safety to ensure operational integrity and maintain safe and healthy working conditions

• we provide our workforce with the necessary information and training to prevent incidents

• our goal is no harm to people, respect for the environment and our stakeholders, and protection of our assets

• we ensure that emergency response capability is in place and periodically tested for all company operations and facilities

Q&AQ: The business unit I work in has been asked to cut costs. My supervisor responded by significantly reducing our maintenance budget, which includes process safety. I’m concerned this could have a negative impact on the safety of our people and the environment. What should I do?A: You should raise the issue. Spending less on process safety doesn’t necessarily mean the safety standard is decreased. However, engaging in dialogue about issues that concern us is an important part of how we work.

Process safety refers to the systems we have in place to prevent, prepare for, mitigate and respond to unplanned or sudden hazardous releases of material.

Since process safety events such as the release of material (gas, oil, steam or H2S) from a process (wells, pipelines, vessels, tanks) can result in harm to people, the environment, property, our business and our reputation, we must carefully consider any changes to process safety programs we have in place.

Having conversations is a good way to do this. While your supervisor should be receptive to your concerns and open to exploring other options, it’s possible that he or she may not be. In that case, you should talk to that person’s manager, your Process Safety Management representative or your Health, Safety, Environment & Social Responsibility (HSE&SR) representative.

We provide a healthy and safe working environment for our people

• we educate employees and contractors on our 12 Life Saving Rules

• we give all employees and contractors the authority to stop work that does not comply with the Life Saving Rules

Health, Safety, Environment & Social Responsibility Policy (A136)Distracted Driving Policy (A174)Human Rights Policy (A105)


In addition to respecting each other’s differences, our people have a right to work in an environment that’s free from harassment and discrimination. Harassment, abusive comments or other inappropriate conduct are unacceptable.

In line with our values of cooperation and teamwork, we are committed to looking out for the well-being of one another. In that spirit, we encourage employees who are concerned they may behave in a way that could negatively impact the work environment to access employee and family assistance programs and/or contact their Integrity Leader or Divisional HR Representative.

This is how we operate a respectful and inclusive workplace:

• we’re open to different points of view and approaches to doing things, seeking to understand and value each other’s perspectives

• we base hiring and promotion decisions on merit, drive, talent, skills and achievements

We operate a respectful and inclusive workplace

A fair and inclusive environment is an important part of how we work. We achieve better business and personal success when we embrace the diversity of each other’s skills, abilities and experiences.

Q&AQ: What is harassment?A: Harassment includes any unwelcome or inappropriate conduct which unreasonably interferes with work performance, diminishes the dignity of any person, or creates an intimidating, hostile or otherwise offensive work environment. Harassment may include unwelcome advances, derogatory or racial comments or jokes, vicious gossip or verbal or physical conduct of a sexual nature. This type of conduct is not tolerated, whether at work or elsewhere.

• we foster an inclusive workplace, supporting diversity and granting requests for reasonable accommodation where appropriate

• we always respect each other, never harassing, bullying, intimidating, threatening or physically harming one another

• we provide cross-cultural training for individuals and work teams to enhance working relationships

Employee Relations Policy (HR217)Respectful Workplace Policy (HR257)


DilemmaDuring an Integrity Workshop, an Integrity Leader encountered an interesting situation. As the group was discussing a case study about working in a group that used offensive language, one of the participants spoke up. He said he was offended by the language his workmates used. Until that point, he had been afraid to speak up. The people in the group were faced with a decision; they could either ignore the man’s comment and not change their behaviour, or they could acknowledge his concern and take action going forward.

OutcomeSomeone in the group apologized, saying that before the individual spoke up, he hadn’t realized the man was offended by the group’s language. As a group, they committed to being more respectful to one another and to talking about concerns when they came up.

This example shows that if we don’t know someone has a concern, it’s hard to change our actions. It highlights the importance of talking about issues, even when doing so is difficult.

This really happened… a Nexen dilemma


In keeping with our reputation and success as a responsible corporate citizen, we respect the universally accepted human rights of individuals and groups in communities where we operate. To support this commitment, we educate our employees on human rights issues and encourage practical approaches, actions and attitudes that respect human rights. We also monitor the impact of our operations in the communities where we work. To reinforce our commitment in this area, we support the United Nations Universal Declaration of Human Rights within our own Human Rights Policy (A105).

This is how we respect human rights:

• we don’t tolerate discrimination or harassment based on ethnic origin, gender, sexual orientation, colour, language, national or social origin, economic status, religion, political or other conscientiously held beliefs

• we assess political, security and social risks – including human rights – before we consider an investment and maintain vigilance after we’ve decided to invest

• we consult with stakeholders and local communities and strive to ensure our operations do not negatively impact the human rights of individuals and groups or indigenous people’s rights

• we share benefits from our operations with local communities through effective engagement and support for sustainable community initiatives

• we implement security arrangements that are consistent with United Nations guidelines and conventions on the use of force

• we speak up if we see behaviour that violates human rights in any of our work locations

Human Rights Policy (A105)Indigenous Peoples Policy (A173)

Q&AQ: What human rights risks are typically associated with our industry?A: Typical human rights risks associated with our industry include:

• unreasonable use of force by government or third party security forces

• failure to consult with communities and address potential concerns related to our operations

• unsafe or unhealthy working conditions for our major suppliers

• resource development may exacerbate an existing conflict

Q: I’m the in-country manager in one of our high-risk locations. We’ve hired local security personnel to help keep our people and assets safe, but I’m concerned that they might be using unnecessary force to do this. What should I do?A: In a situation like this, as with any situation where our operations and the health and safety of our people could be at risk, it is critical that you let executive management, Legal and Corporate Security know about your concerns.

Any security personnel that we employ or contract must respect human rights. Excessive force, torture and cruel, inhumane or degrading treatment is prohibited.

We respect human rights

Nexen’s commitment to human rights stays the same, no matter where we operate. We believe that behaviours and actions respecting human rights help create a supportive environment for investment and operations.


The concept of privacy differs among legal jurisdictions, cultures and individuals but shares basic common themes. We’re committed to complying with data privacy laws everywhere we operate; always taking care to protect the personal information of employees, contractors, partners, suppliers and customers.

This is how we protect the privacy of others and their personal information:

• we recognize when and what information is personal

• we obtain consent when collecting, using or disclosing an individual’s personal information (the individual must understand why we need to collect the information and how it will be used)

• we use personal information only for the business purpose for which it was collected; if it’s needed for another purpose, we obtain additional consent

• we only keep personal information as long as necessary for the business purpose it relates to, then we destroy it in a responsible manner

• we respect the right that individuals have to access their own personal information and to challenge its accuracy

• we appreciate that privacy laws can be complex and differ across our operations; we seek help from the Privacy Officer when we’re in doubt

Privacy of Personal Information Policy (A106)

We protect the privacy of others and their personal information

Q&AQ: What are some examples of personal information we will not disclose?A: Gathering personal information – about employees, contractors and others – is necessary for our business. The following information should not be disclosed without consent from the individual:

• age, income, ethnic origin, blood type, religion

• personal opinions, social status (marital, family, economic)

• employee files, credit records, loan records, medical records

• home address, home phone number

Personal information doesn’t include the name, title, business address, business telephone number, fax or email of our employees.


WORKING PROFESSIONALLYHow the things we do individually affect our business


Business equipment such as the internet, email and intranet systems as well as telephones, voicemail and mobile devices are essential to our ongoing operations. Using this equipment with good judgment helps us maintain a high level of productivity and demonstrates that we use company assets responsibly.

Limited personal use of Nexen’s equipment including information technology (IT) equipment is permitted as long as the use follows our policies and doesn’t interfere with business goals. Excessive personal use, conducting non-Nexen business, downloading or distributing offensive content and illegal activity is not acceptable.

The use of social media requires special care. Nexen allows some access to social media for limited business and personal use. Care should be taken not to expose internal, confidential or restricted business information to external sources.

As the owner of the information technology resources we work with, subject to applicable laws, Nexen has the right to monitor usage and, where appropriate, to conduct reviews. If inappropriate use is encountered, action will be taken. Employees should have no expectation of privacy relating to the use of Nexen IT equipment including accessing web based services such as social media, networking or other online applications.

We use information technology resources responsibly

Q&AQ: I love coaching my daughter’s rugby team. It means quality time with her, but it also means coordinating practices and games with other parents. May I use my Nexen email to communicate with them?A: Yes – as long as it’s reasonable. Personal use of Nexen IT equipment is acceptable as long the duration is limited and doesn’t interfere with work duties and responsibilities. We’re all responsible for using good judgment when using company resources.

Q: A colleague sent me an email containing pictures that I found offensive. What should I do?A: You should raise the issue. Depending on the nature of your relationship with the individual and on the severity of the content, you may decide to raise your concern with your colleague directly.

If the content is very offensive, you should raise the issue with your manager, your Human Resources representative or the other resources available for raising concerns.

You should also save the image in the short term in case it is required for an investigation. Ensure it is not circulated further (don’t ‘forward’ it).

Downloading or distributing offensive materials is prohibited in Nexen’s Acceptable Use of Information Technology Policy (IT200) as is visiting websites or creating messages that are pornographic, degrading or otherwise threatening in nature.

This is how we use information technology resources responsibly:

• we act professionally and are responsible with our use of company resources

• we use business equipment for appropriate business purposes

• we are thoughtful about the electronic communications we send, remembering that email is a business record that can later be used in unintended ways including in litigation against us

• we avoid inflammatory, derogatory or harassing language and other expressions that could be taken out of context or negatively impact an individual’s reputation or Nexen’s reputation

• we speak up when we see misuse of assets to protect Nexen from possible harm

Acceptable Use of Information Technology Policy (IT200)Social Media Policy (A176))Information Classification and Protection Policy (IT201)


Our competitive advantage is generated by the information we create and receive. Much of this information is confidential. To maintain our competitive advantage, it needs to stay that way. Maintaining confidentiality allows us to meet our contractual and ethical obligations and to demonstrate our ability to work professionally.

Competitive advantage is also generated from innovative technologies, strategies and other types of business information. These assets, including intellectual property, need to be treated confidentially.

Disclosing this information to competitors or others could result in litigation and damage our competitive advantage, financial situation and reputation. We have a responsibility to protect this information from unauthorized disclosure and use.

Q&AQ: What kind of information is confidential?A: Confidential information includes any data in Nexen systems and formal or informal records, such as technical data, financial information, business strategy and plans, supply and service information, marketing information, employees’ personal information and customer information. Confidential information may be generated by Nexen or received from a third party.

Q: What is intellectual property?A: Intellectual property includes computer programs, research methods, inventions and discoveries, technical processes, reports or articles that are developed during employment at Nexen.

Q: I took some notes on confidential information I saw in a data room. We’re not going to pursue the deal, but the information looked useful for another deal we’re looking at in that region. Can I use the information for that deal?A: You should check with your manager or the Legal Department. The information you saw in the data room has value to the company that disclosed it to Nexen. Using it outside the purpose for which it was given erodes the value of that information to the disclosing company. Also, use of this information outside the intended purpose may be a breach of the terms of use and confidentiality Nexen agreed to with the disclosing company.

We respect confidentiality and safeguard intellectual property

We have a responsibility to safeguard Nexen’s intellectual property and maintain the confidentiality of information – even after employment ends.

This is how we maintain confidentiality and safeguard intellectual property:

• we label confidential information properly, keep it secure and limit access to those who need to know this information in order to do their jobs

• we respect the limitations on use and disclosure of confidential information that has been shared with us

• we are conscious of our surroundings and don’t discuss confidential information in public places

• we share sensitive information outside Nexen only with authorized parties who have signed an appropriate confidentiality agreement

• we encrypt emails containing confidential or sensitive information

• we protect inventions, discoveries, proprietary technology and confidential information in every contract and with third parties

• we disclose to Nexen any inventions we conceive while working here

• we destroy confidential information provided to us by others when required to do so

• we respect the prior employment obligations of new and potential employees, never asking them to share the kind of information we wouldn’t want others to request from former Nexen employees

Confidential Information Policy (A161) Information Classification and Protection (IT201)



DilemmaDuring an interview, a candidate was asked about a process he used to accomplish a specific outcome. It turned out the individual had brought along a sample of this work which he wanted to share with the interviewers.

The material he took out of his briefcase was information from his previous company. It was clear to the Nexen managers conducting the interview that the information was strictly confidential and proprietary in nature.

Before the candidate could open the document, one of the managers asked him to put it back in his briefcase as it wasn’t appropriate for him to be showing this information to anyone at another company.

OutcomeNot only did the managers not look at the information, they also told the candidate that his actions were inconsistent with how we work at Nexen and explained why. By doing this, they demonstrated that having difficult conversations if we think someone may be crossing the line is one of the key ways we work through difficult situations here.

You may be wondering if we hired this individual. The answer is yes. This person was an outstanding candidate, and it was clear to these managers that he’d made an error in judgment he wasn’t likely to make again.


Q&AQ: I’m not sure what inside information is. What are some examples?A: Inside information is information which isn’t available to the general public and which could influence a reasonable investor to buy, sell or hold shares or other securities. This information may be either positive or negative.

While it’s not possible to define all categories of material information some general examples are:

• undisclosed financial results

• news of a pending, proposed or completed merger, acquisition or disposition

• news of a discovery, project sanction, joint venture, or other business operation, transaction or development

• an impending bankruptcy or financial liquidity problems

• changes in dividend policy

• new equity or debt offerings

• significant exposure from actual or threatened litigation

• changes in senior management

• changes in corporate structure

We handle inside information appropriately

CNOOC Limited is a publicly-listed issuer. When working, you may become aware of material information about CNOOC Limited, or other companies that we have a business relationship with, that hasn’t been made public. Handling this undisclosed or “inside information” appropriately supports integrity and public confidence in financial markets. The misuse of inside information for financial or other benefit – no matter how small – is inconsistent with how we work at Nexen and may be against the law.

This is how we handle inside information appropriately:

• if we possess inside information that could affect the price or value of the shares of CNOOC Limited or any other company, we don’t buy or sell securities of that company until after the information becomes public

• we keep inside information confidential from others including friends and family

• we comply with “blackout periods” by suspending trading activity in CNOOC Limited securities for the specified time period

• whether we have inside information or not, we never trade in puts, calls, or any other derivatives of a CNOOC Limited share, as it is illegal

• we consult with the Legal Department when we have questions about undisclosed material information

Trading in Securities Policy (A152)

Q&AQ: I have information gained through my employment at Nexen about another publicly traded company. Can I buy that company’s shares or encourage friends and family to buy it?A: No. Any information you have obtained that could affect the price of shares and that is not publically known is considered inside information. Acting through someone else, or giving this information to others for their use –even if you won’t financially benefit from it – is considered “tipping”. This is illegal.


Employees share the responsibility to ensure their own safety and the safety of those affected by their activities

We are committed to providing a safe, healthy and productive work environment. We expect our employees and contractors to be fit for work throughout the workday. Being fit for work includes not being under the influence of alcohol, drugs or medication. This requirement is captured in the 12 Life Saving Rules and Nexen corporate policies.

Nexen is committed to providing a safe, healthy and productive work environment. The use of alcohol, drugs and medications may adversely affect job performance, productivity, business decisions and the safety and well-being of our people and the communities in which we operate.

We’ve created a culture where employees look out for one another’s well-being. In that spirit, we encourage our colleagues to seek help to overcome dependency problems.

This is how we come to work fit for duty, unaffected by alcohol, drugs and medications:

• we do not report for work while under the influence of alcohol or drugs

• we remain fit for duty throughout the workday which means we are able to safely and appropriately perform assigned duties without any limitations due to the use or after-effects of alcohol, drugs or medications

• we are responsible when hosting others and use good judgment if using alcohol (where it’s permitted) while at work-related functions

• we understand the rationale for alcohol and drug testing and agree to co-operate fully with requests made for testing in accordance with our policy

• we speak up when we see someone report not fit for work, including under the influence of alcohol or drugs, to protect their safety and our own

Alcohol and Drug Policy (HR249)

Q&AQ: I’ve noticed that one of my colleagues appears disoriented after breaks. I could be mistaken, but I think he might have an alcohol or drug issue. I’m concerned because I think it could result in harm to other employees or contractors. What should I do?A: You should raise the issue. Judgment that is impaired by alcohol, drugs or medication is detrimental to Nexen’s interests. We are responsible for managing ourselves to ensure we’re fit for duty at all times.

Depending on your relationship with the individual, you may choose to approach him directly. Regardless, you must approach the individual’s supervisor, your supervisor or your Human Resources representative.


LOOKING AFTER OUR BUSINESS AND OUR SHARED FUTUREHow we are responsible for looking after our business to ensure its future success


Healthy competition is part of how we build long-term value. However, our competitive activities must comply with competition and antitrust laws. Generally, these laws protect free enterprise by prohibiting arrangements between individuals or companies that unduly restrain competition in the marketplace. Some activities that may be governed by these laws include arrangements between competitors relating to price-fixing, bid-rigging, fixing or limiting production or supply, and abuse of market dominance.

We compete aggressively and fairly

Q&AQ: Can I pretend to be a customer to obtain pricing information from one of our competitors?A: No. It’s essential that any information we obtain about our competitors is gathered in a legal and ethical manner. This means we avoid any appearance of improper practices, including pretending to be someone else when soliciting information.

Q: Can I make an agreement with a competitor that ensures he or she will conduct that company’s operations in a certain market while I focus business operations elsewhere?A: No. Competition laws specifically prohibit arrangements in which competitors divide market share or otherwise allocate sales territories.

Competition laws are complex and you may not be familiar with the details. If your job involves contact with competitors, customers, suppliers or trade associations, or involves selling, pricing or bidding, it’s important that you understand what’s appropriate and what’s not.

This is how we compete aggressively and fairly:

• we are sensitive to situations where anti-competitive information might be exchanged, such as at industry or networking events, association meetings or conferences

• we’re careful when speaking with competitors; we don’t exchange price or product information and we refuse this information if it’s offered to us

• we disclose information we come across that may have been obtained inadvertently or unfairly by bringing it to our respective supervisor and the Legal Department or the Integrity and Compliance Group

• we promote a level playing field for participants of the competitive bid process – both as purchaser and vendor – and refuse to engage in activities that unfairly influence this process

• we talk to our respective manager or the Legal Department if confronted with situations we aren’t sure of or that don’t seem right

Competition and Anti-Trust Policy (A150)


We create and maintain our business records according to the laws of each country where we operate and with proper accounting standards – exceeding them when appropriate. Business records include information created, received and maintained by Nexen or our employees during the course of business. They may include financial information, reserves estimates, safety and environmental data, regulatory filings, time sheets and expense reports.

This is how we ensure the accuracy and completeness of our business records:

• we record our transactions honestly and accurately, never falsifying documents or records

• we commit Nexen to legal obligations and sign contracts only when we have the proper authorization to do so and the contract has been approved by legal or contract specialists

• we only sign business records we believe are complete, accurate and truthful

• we approve an invoice or expense only when the goods or services have been received, in good order, at the right price and for business reasons

• we cooperate fully with our internal and external auditors and investigators allowing them unrestricted access to staff and documents (subject to legal constraints)

• we ensure that no undisclosed or unrecorded account, fund or asset is established or maintained

• we submit expense reports and timesheets that are timely, accurate and complete

• we ensure business records are appropriately stored for efficient retrieval, ensuring they’re properly identified and retained

• we dispose of business records according to policy and legal requirements, destroying them when retention periods expire

• we speak up when we notice inaccurate records to help ensure we maintain accurate business records that transparently reflect business practices

Employee and Business Expenses Policy (F311)Information Classification and Protection Policy (IT201)Estimation and Reporting of Oil and Gas Reserves Policy (A107)

We ensure the accuracy and completeness of our business records

Ensuring the accuracy and completeness of our business records helps us make informed business decisions and allows us to meet our responsibilities to our stakeholders.

Q&AQ: How do I know that my entertainment or other purchasing decisions are appropriate? A: An excellent guideline is whether the purchase is providing a business benefit to Nexen. Employees are encouraged to ask themselves the following questions:

• am I documenting my expenses properly, identifying the people attending and business purpose?

• if I approve credit card statements or expense reports, do I scrutinize them for completeness, receipts, coding and proper spending, and seek clarification when necessary?

• am I taking advantage of corporate or early booking discounts or consolidated procurement agreements?

• how could others perceive this expense?

Managers are expected to lead by example in their use of Nexen assets, talk with employees about expectations and address inappropriate spending decisions.

Q: I was recently at a work function and my boss asked me to pay the tab. Is this okay? A: When members of a team are dining together on Nexen’s tab, the most senior individual must pay. Having the most senior person pay ensures that any attempt to approve your own expenses or cover up inappropriate charges is prevented.

Q: My department is being investigated by a regulator. Our records room is full of documents that are past their retention date, and I think they might have to do with the investigation. Is it okay for me to destroy them now?A: No. Destroying the records now could jeopardize the investigation and may be illegal. It’s important that you cooperate fully with regulators and don’t mislead them in any way.


We are professional in our communications with stakeholders and take care to ensure they are consistent, accurate, fair and timely. The release of understandable information on a timely basis keeps investors, media, partners, employees, suppliers, communities and the public informed about our company. Complying with or going beyond all disclosure regulations is one of the ways we fulfill our commitment to communicating honestly.

To ensure our communications to investors, media and other stakeholders are accurate and that we’re consistent with our messaging, all requests for information or comments should be referred to Corporate Communications.

We communicate honestly with all stakeholders

Communicating honestly with our stakeholders helps us strengthen our global brand and attracts stakeholders including employees, partners and suppliers who appreciate ‘who we are’ as a company.

This is how we communicate honestly with investors, media and other stakeholders:

• we communicate with each other in a respectful, honest and open manner

• we fully disclose information determined by senior management to be in the interest of stakeholders and the public

• we avoid selective disclosure of information that would be an advantage or disadvantage for any individual or group

• when speaking personally, including on blogs or in chat rooms, we do not speak about Nexen business and are careful not to give the impression that we are speaking on Nexen’s behalf

Social Media Policy (A176)

Q&AQ: I’ve been asked to do a presentation at an industry conference. Does someone need to review my slides? A: Yes. Ensuring the consistency of our messaging and visual identity is an important part of how we live our global brand. Corporate Communications will review external presentations to make sure they accurately reflect our business and the image we want to portray. It’s also good practice to have your manager review all presentations you prepare.


Q&AQ: I have trouble remembering my password. Is it okay for me to write it on a sticky note and put it at the bottom of my computer screen? A: No. You must take care to protect your password because it is the key to your electronic signature and you’re responsible for any activity using that signature. Lending your password to co-workers or anyone else is also inconsistent with how we work. Storing a list of your passwords in a locked file cabinet is one way to keep them secure. For electronic options, please contact the Action Centre. By keeping tight control of our passwords and by changing them periodically, we protect our data from unauthorized users.

Q: A consultant is visiting our office and doesn’t have a security pass. She has meetings with different people throughout the day. Can I give her my pass so she can get around the building?A: No. Depending on the nature of the arrangement, you should either arrange for a temporary pass or escort her to her various meetings. We are responsible for visitors to Nexen and must take care to ensure their presence doesn’t jeopardize the security of our operations.

Minimizing the impact of our operations on the environment is one of the cornerstones of our commitment to HSE&SR. We work hard to be a leader in sustainability and to integrate health, safety, environmental and social considerations into the way we do business. This practice supports our mission to grow value responsibly.

This is how we conduct our business with respect and care for the natural environment:

• we’re aware of environmental regulations that affect our operations, taking all necessary steps to ensure we meet them and going beyond what’s required when appropriate

• we look for and apply ways to reduce the impact of our operations on air, water, land resources and biodiversity

• we work hard to minimize waste and steward our products throughout their life cycle to protect people and the environment

• when situations arise in which our activities appear to have negatively affected the environment, we follow proper procedures, report them without hesitation and remediate our actions as appropriate

• we manage and steward our environmental performance through consultation and cooperative relationships with key stakeholders

Health, Safety, Environment & Social Responsibility Policy (A136)

We conduct our business with respect and care for the natural environment

Nexen’s strength is built on the value of our assets, in particular our people, our physical assets and the information we hold. Our people are careful not to damage our assets through carelessness, neglect, waste or criminal activity. This is important to how we work because it demonstrates personal responsibility and accountability. It also has a direct impact on our reputation.

We take special care to maintain a secure work environment for our people, both at the locations where we work, and when travelling for business. The safety and security of our people is paramount.

This is how we protect our assets and maintain a secure work environment:

• we take responsibility for our security, consulting with managers and members of the Security Department if we feel we may be at risk

• we’re careful with our security access cards; we don’t loan them to others or grant secure access to people we don’t know

• we promptly report any theft, loss or misuse of company property to the Security Department (including our security access cards and secure ID fobs)

• we accurately track and report the movement of Nexen equipment, materials and inventory

Acceptable Use of Information Technology Policy (IT200)Corporate Security Policy (A140)

We protect our assets and maintain a secure work environment



DilemmaWhile adding anti-freeze to the cooling system of his vehicle, a contractor spilled approximately a litre of it on the ground. After the spill had been cleaned up, the individual wondered whether the event needed to be added to Nexen’s reporting system. He sent an email describing the situation and asked what to do.

OutcomeOne of his colleagues told the individual that the incident must be reported. This person explained that Nexen is committed to reporting all employee and contractor HSE&SR events promptly and accurately in our Environment, Health & Safety event database. These events are investigated based on actual or potential seriousness and are managed until closed out in the database.

Depending on the material spilled, the volume and the jurisdiction, an environmental event may also require Nexen to notify regulatory authorities or other agencies. Because of this, and also because the sharing of learning is so important to how we work at Nexen, our approach is to report all environmental spills.

Tracking and reporting data in a consistent, centralized and systematic way helps us achieve performance excellence. It allows us to identify patterns and trends, plan interventions, improve controls and prevent additional events. It also allows us to enhance decision making and better protect our employees, the environment and our company.


MANAGING OUR RELATIONSHIPSHow we work with suppliers, communities, partners and government


Trust is important to every successful business and personal relationship. Conflict of interest erodes trust. Even the perception of a conflict of interest, when someone thinks you are putting your interests ahead of those of Nexen, can be as damaging as an actual conflict.

This is how we proactively avoid or manage conflicts of interest:

• we disclose any situation that could be perceived as a potential conflict of interest, including personal relationships, financial investments and board membership

• we recognize that there is a basic conflict of interest when we manage someone with whom we have a family or close personal relationship; we don’t have direct reporting relationships with these individuals

• we choose our suppliers and other service providers based on their ability to meet business objectives, not on any personal relationship we may have with them

• we prioritize the interests of Nexen over any outside interest or activity that interferes with the time or attention we are expected to devote to Nexen

Conflicts of Interest Policy (A151)Speaking Up Policy (A163)

We proactively avoid or manage conflicts of interest Q&A

Q: I’m handling the logistics for an offsite meeting. We want to minimize our event’s environmental footprint and know that “buying locally” is a good way to do so. I have a close friend who owns an organic catering company. If I select her company, is it a conflict of interest?A: Yes, if you make the selection. The most important thing to take into account when you think there may be a conflict of interest is whether a relationship conflicts with Nexen’s interests. In this case, it looks like your idea supports Nexen’s commitment to growing value responsibly. But, even the appearance of a conflict of interest can be damaging. Since you have a prior personal relationship with the caterer, you should remove yourself and involve others in the evaluation and decision.


Exchanging gifts and entertainment is an accepted business practice that helps us build strong relationships with our stakeholders. Giving and receiving gifts or entertainment becomes an ethical issue when our judgment is compromised – or appears to be compromised – because of a benefit that we have personally received.

To help employees make appropriate decisions relating to gifts and entertainment, we’ve made a distinction between entertainment and gifts. Entertainment includes meals, receptions, tickets to or participation in leisure, social or sporting events where the business associate is in attendance. When the giver of the hospitality does not attend, the event is defined as a gift.

Nexen has set $250 CDN equivalent as the limit for gifts which don’t require prior approval. A limit has not been set for entertainment. However, employees should be thoughtful and exercise good judgment when making decisions related to entertainment.

We don’t give or receive inappropriate gifts or entertainment Q&A

Q: What are some examples of gifts and entertainment activities that Nexen considers unacceptable?A: Some examples include:

• entertainment or gifts received from a potential supplier before or during a competitive bid process

• entertainment that can’t be utilized in a reasonable period of time

• the intentional solicitation of gifts or entertainment

• honorariums for services that an employee wouldn’t have been asked to provide if it weren’t for her or his Nexen position

Q: A supplier that would like our business has invited me to a football game. What should I do?A: Accepting invitations to sporting events is fine as long as the value isn’t excessive, networking or business development is involved, and the supplier is not currently engaged in a competitive bid process with Nexen. But, frequent or extravagant outings can create the perception of a conflict of interest. In addition, if you aren’t accompanied by the supplier, the tickets are a gift and, depending on the value, may exceed the threshold where prior approval is required.

Knowing how we work ethically with respect to gifts and entertainment is important to maintaining trust with our partners, suppliers and each other.

This is how we work ethically by not giving or receiving inappropriate gifts or entertainment:

• we consider how gifts and entertainment may be perceived; we don’t give or accept them if they seem excessive or extravagant

• we’re sensitive to the gifts and entertainment guidelines of our suppliers; we don’t offer anything we know is inconsistent with how they do business

• we consider the following guidelines when making decisions about gifts and entertainment:

- the exchange of the item occurs infrequently

- the exchange could be easily reciprocated by Nexen

- the benefit arising from the exchange is of limited actual or perceived value

- there’s a genuine business purpose associated with the exchange

- no perceived or actual obligation is created as a result of the exchange

- the item complies with all our policies

• we consult with others when in doubt

Gifts and Entertainment Policy (A108)


Corruption, whether in the private or public sector, is a significant impediment to sustainable economic and social development. It’s also illegal. As a responsible global citizen, we don’t pay bribes or make improper payments. This is one way we work with integrity at Nexen and continue to build trust in the marketplace.

A bribe is the direct or indirect offer of anything of value – money, gifts or advantage of any kind – that influences or could influence a decision to give Nexen an unfair business advantage. Bribes to government officials are against the law in every country where we operate. These officials are not just direct employees of the government; they can also be employees of state-owned corporations or people involved in charitable foundations sponsored by the government. For this reason, employees must be extremely careful when making payments or giving gifts of any kind.

This is how we refuse to pay bribes or make improper payments:

• we comply with international anti-corruption laws even when bribery may appear to be an accepted part of local business practice

• we take reasonable steps to avoid making indirect payments to government officials that could constitute a bribe, such as payments to a family member or an organization linked to a government official

• we don’t give or receive kickbacks (a kickback is the payment or receipt of part of a contract payment including a gift of significant value received from, or given to, a contractor as an incentive to award or be awarded a contract)

• we are selective in our use of ‘agents’ and use them only after they’ve passed our thorough due diligence process

• when using agents, we take reasonable steps to ensure they are only engaged on commercially reasonable terms and are aware of, and contractually bound by, our policies on corruption and improper payments

• we carry out a due diligence assessment and follow procedures similar to hiring an agent before hiring contractors to provide services that are high risk for bribery, such as customs or immigration brokering

Prevention of Improper Payments Policy (A153)

We do not pay bribes or make improper payments Q&A

Q: I’m about to head overseas on a Nexen business trip and I know I’ll be expected to entertain a foreign government official. Is this allowed?A: It may be. Employees may provide nominal gifts or reasonable entertainment to government officials provided they are:

• for a legitimate business purpose

• reasonable and appropriate under the circumstances

• incurred in good faith

• consistent with the law or regulations of the public official’s country

Prior to leaving you should ask in-country management or Nexen’s chief compliance counsel about what is considered an appropriate gift or form of entertainment in the country you’re going to.

Knowing how we work ethically with respect to gifts and entertainment is important to maintaining trust with our partners, suppliers and each other.


For us, community involvement goes beyond engaging in formal consultation programs and donations to good causes; it requires long-term participation, support of employee volunteer efforts and follow through on the commitments we make. When challenging situations arise, we act in a way that is consistent with our core values and we seek to resolve issues in a respectful manner.

This is how we engage openly in the communities where we operate:

• we assess the potential impacts of our plans and operations on host communities

• we respect universal human rights and the rights of aboriginal and indigenous peoples

• we take the time to listen to stakeholder and community concerns; we address the issues we can, mitigate others, and for those concerns that can’t be addressed, we explain why

We engage openly in the communities where we operate

We build positive, trust-based relationships with stakeholders and local communities by engaging openly and honestly with people affected by what we do.

• we look for ways to work with local businesses while maintaining standards for safety, environmental protection, and quality

• we communicate our commitment to social responsibility through candid, timely, public disclosure of our HSE&SR performance

• we recognize the differing needs of communities; together we determine opportunities for contributing to registered charities and non-profit organizations that provide important local, national or international services that address issues and challenges and that are compatible with our business objectives

• we support our employee’s contributions to the community through our gift match and volunteer programs

Health, Safety, Environment & Social Responsibility Policy (A136)



TALK TO AND CONSULT WITH

OTHERS

CONSIDER YOUR OPTIONS

• consider the various options

• assess the potential consequences, weighing the risks and rewards

of each option

• choose a course of action taking into account who

may be affected

TEST YOUR DECISION

• determine whether the decision is aligned with our core values

• examine the decision in the context of the Integrity Guide as well as our

policies, relevant laws, and professional standards

RECOGNIZE THE ISSUE• are you faced

with a difficult situation?

• what’s the issue?

• are you unsure about the best course of action?

TAKE RESPONSIBLE ACTION• communicate the decision

and why you made it

• reflect upon any lessons or unintended consequences

• if appropriate, share your story with others

Making ethical decisions

We make decisions every day while at work. Sometimes, there are clearly right and wrong answers and decision-making is easy. Other times, the answers are unclear. Situations arise that require us to carefully consider all the options before deciding what to do. When faced with tough decisions, these actions can help us make the best choice.

What to do if you have a concern

Questions to ask yourself:

• is anyone’s life, health or safety at risk?

• is it legal and consistent with our policies?

• is it fair, honest and respectful?

• is it aligned with our values and long-term business goals?

• could my decision or action negatively impact others?

• how does this decision or action make me feel?

• what would the perception be if this was made public? Could it appear improper?

• will I or others feel obligated by the action? Will my objectivity be affected?

• what would you advise your best friend or child to do in this type of situation?


We strive to create a culture of integrity where everyone is expected to speak up and to help us proactively manage issues, especially people in formal leadership positions.

Direct dialogueIf you know of a violation or reasonably suspect a violation of the Integrity Guide, the policies referenced in it or any applicable law, you must report the issue. If possible and appropriate, approach the person involved or discuss it with your supervisor.

If for any reason you feel uncomfortable or think there may be personal risk in bringing the concern to the attention of your supervisor, raise the concern with your local Integrity Leader, someone in the Integrity and Compliance Group, a Human Resources representative or a member of Corporate Audit, Legal or Security Departments. The important thing to remember is that there is always someone to talk to.

Integrity HelplineWhile Nexen encourages individuals to raise integrity concerns directly with someone at Nexen, there are times when you may prefer to raise your concerns anonymously. If you wish to remain anonymous, you may raise your concern using the Integrity Helpline. The Helpline is administered by an external service provider and available in various languages, 24 hours a day, seven days a week. It enables confidential and anonymous reporting via the internet or by telephone and can be accessed through Nexen’s internal and external websites.

Individuals who want to remain anonymous are encouraged to use the Helpline rather than other means such as an anonymous note or letter. The Helpline allows for two-way dialogue – something that’s critical when resolving integrity-related concerns.

If someone is reluctant to use the reporting methods described above for an integrity issue or compliant regarding accounting, internal accounting controls or auditing matters, a report may be made directly to the Board of Nexen Energy ULC in an envelope labeled: “To be opened by the Board of Nexen Energy ULC only – Submitted pursuant to the Integrity Guide”.

Speaking Up Policy (A163)

Speaking up

Speaking up is an important part of how we work at Nexen; it’s one of the most important ways we address issues and mitigate risks. For this reason, we encourage all of our stakeholders (including external ones) to raise concerns.


Q&AQ: Will my concern be kept confidential and anonymous?A: Nexen keeps all reports of integrity concerns strictly confidential. Information will only be shared to the extent necessary to completely and fairly investigate and resolve a concern, including, if necessary, review by Nexen Energy ULC Board of Directors, external auditors or external legal counsel.

While anonymous reports are accepted and can often be resolved efficiently given the two-way dialogue capability of the Helpline, remaining anonymous may make it difficult for Nexen to pursue an investigation. There may also be times (such as in formal harassment allegations) when it’s impossible to resolve a concern without knowing the identity of the person raising it. Regardless of the situation, the source of the report is not divulged without the direct consent of the person involved.

Q: What actually happens when someone contacts the Integrity Helpline?A: If you call the Helpline, you’ll speak with a third-party interviewer who will ask some standard questions and record the details of the situation. You are not required to give your name and the call is not recorded. If you raise your concern online, you’ll be prompted to answer the same standard questions that are asked if you called. Regardless of the method used, you’ll be assigned a password that you must use to check back on the status of your report.

What happens when an integrity-related concern is raised?Investigations are conducted with the utmost respect, discretion and privacy for anyone who is involved to support the fair resolution of the issue. The Chief Legal Officer is responsible for the process of reviewing all integrity issues and works closely with the Integrity and Compliance Group and other relevant groups to investigate and resolve all matters. The services of internal and external experts may be engaged to investigate and resolve issues. Members of Nexen’s senior management team are apprised of relevant issues as necessary. If an investigation uncovers that a violation of the law or company policy has occurred, appropriate action will be taken.

Respect for individualsIntegrity investigations are conducted fairly, impartially and in accordance with applicable laws. They are not intended to prove guilt, but try to determine what the facts are so the best decision can be made. During an investigation, care is taken to balance the interests of the reporter and the individual about whom the concern is being raised. Investigations are conducted with respect and discretion for anyone who is involved to support the fair resolution of the issue.

Investigation Policy (A145)


How you’re protected against retaliation

Trust is eroded when there is a difference between what we do and what we say we believe in. Speaking up is the first step in restoring this trust.

Q&AQ: If I raise an integrity-related concern, will I face negative consequences?A: We strive to create a culture where speaking up and raising concerns is welcomed. Despite this, it is possible that negative action, or retaliation, could take place. Retaliation can happen in many different ways, including denial of a promotion or job benefits, or even a demotion. Subtle forms of retaliation include being excluded from team activities, or gossip.

Retaliation is not acceptable at Nexen. There are also laws in place to protect individuals who raise ethics related concerns honestly and in good faith. If you are concerned you are being retaliated against, raise your concern with your Integrity Leader, a member of the Integrity and Compliance Group, your Human Resources representative or your manager if appropriate.

Q: What should I do if I think I am being retaliated against?A: Retaliation is not acceptable at Nexen. This is outlined in our Speaking Up policy. There are laws in place to protect individuals who raise issues honestly and in good faith. If you think you are being retaliated against, raise this with an Integrity Leader, a member of the Integrity and Compliance Group, your Human Resource representative or, if appropriate, your manager.

Retaliation against an employee or external stakeholder who raises concerns about violations of the Integrity Guide, the policies referenced in it or applicable laws is not acceptable. Employees will not face negative consequences because they refuse to carry out a directive that constitutes corporate fraud,

is a violation of the Integrity Guide, a violation of the law or presents a substantial or specific danger to the individual or the public’s health and safety. Any employee who retaliates against someone reporting an integrity concern will be subject to corrective action up to and including termination.

Speaking Up Policy (A163)


IndexAccountability ............................................3, 24Accounting standards ............................ 22, 24Accuracy ............................................13, 22, 23Alcohol ...........................................................19Anonymity ............................................... 33, 34Anti-trust laws ...............................................21Asset protection ...........................9, 12, 16, 24Bidding ..................................................... 21, 28Bribery ............................................................29Business records ..................................... 16, 22Communications .................................... 15, 23Community relations ............................. 12, 30Competition laws ..........................................21Confidential information ... 16, 17, 18, 21, 25Confidentiality ...........................16, 17, 33, 34Conflicts of interest ............................... 27, 28Cooperation and teamwork .....................1, 10Corrective action .......................................5, 35Corruption .....................................................29Disclosure ..........................................16, 23, 30Discrimination ........................................ 10, 12Drug use .........................................................19Entertainment ...................................22, 28, 29Expenses .........................................................22Family .................................... 10, 13, 18, 27, 29Financial information ............................ 16, 22Fit for duty .....................................................19Friends ............................................................18Gifts ......................................................... 28, 29Government officials ....................................29Harassment .......................................10, 12, 34Health, safety, environment and social responsibility .................... 9, 24, 30

Helpline ................................................... 33, 34Hiring ................................................... 5, 10, 29Human rights ....................................... 9, 12,30Improper payments.......................................29Information technology ........................ 15, 24Inside information ........................................18Insider trading ................................................18Integrity ....................... 1, 3, 4, 5, 7, 29, 33, 34, 35Intellectual property ......................................16Investigations .............................................4, 34Learning ............................................... 7, 25, 32Material information .....................................18Meals ...............................................................28Medication ......................................................19Performance .................1, 3, 10, 19, 24, 25, 30Personal information ............................. 13, 16Privacy ................................................13, 15, 34Professionalism .................................15, 16, 33Purchasing decisions .....................................22Raising concerns .............4, 5, 7, 9, 10, 12, 15, ................................................ 19, 32, 33, 34, 35Recognition ............................ 7, 13, 27, 30, 32Relationships ..... 3, 10, 15, 18, 19, 24, 27, 28, 30Respect ..... 3, 9, 10, 11, 12, 13, 16, 23, 24, 28, .............................................................30, 32, 34Retaliation ...................................................5, 35Safety ......... 3, 9, 12, 19, 22, 24, 25, 30, 32, 35Security ................................................... 12, 24Social Media Policy ........................... 6, 15, 23Suppliers .........................12, 13, 21, 23, 27, 28Trading in company securities .....................18Trust ..................................1, 27, 28, 29, 30, 35Values ................................1, 3, 5, 7, 10, 30, 32Violations .............................................. 4, 5, 35


THANK YOU TO THE MANY NEXEN PEOPLE

WHO HELPED CREATE OUR INTEGRITY GUIDE.

October 2014

By using paper made from 100% post-consumer recycled content, the following resources have been saved: 61 trees for the future, 175 lbs waterborne waste, 25,769 gallons wastewater, 2,851 lbs solid waste, 5,614 lbs net greenhouse gases and 43 million BTUs energy.

www.nexencnoocltd.com

Documents

How We Work: Our Integrity Guide