Presented in a detailed, organized fashion in the Total Code of Conduct, these ethical values and principles are based on four internationally recognized reference documents: the Universal Declaration of Human Rights, the key conventions of the International Labour Organization, the OECD Guidelines for Multinational Enterprises and the ten principles of the United Nations Global Compact.

To help managers and other employees better understand and more effectively apply the Code of Conduct, Total’s Ethics Committee has introduced a dedicated ethics program.

Our position and commitments

Total’s ethics process is based directly on policy statements issued by senior management that define and structure the Code of Conduct’s importance and its role within the Company.

You can read the policy statement of Christophe de Margerie, then Chief Executive Officer, in his Message to Senior Executives (November 2007) and his Introduction to the Code of Conduct (June 2007): “Our growth and long-term viability depend on all of us embracing the shared ethical values and principles that motivate and guide our day-to-day undertakings.”

Implementation

Effectively distributing the Code of Conduct

Implementation of our ethics process hinges on effective distribution of the Code of Conduct.

The Code of Conduct, which is available in 27 languages, including seven bilingual versions, is regularly distributed or discussed at numerous in-house events and is widely available on most Total intranet sites. In 2008, the Code of Conduct was issued in eight new languages: Afrikaans, Bengali, Burmese, Czech, Hindi, Japanese, Urdu and Zulu.

It can also be downloaded from the Total Web site and is widely circulated outside the company, mainly to our partners and suppliers.

Since October 2000, more than 400,000 copies of the Code of Conduct have been distributed, not including versions downloaded from intranet sites and Web sites.

In order to increase awareness of Total’s values, an Ethics Charter was drafted in 2003 summarizing the contents of the Code of Conduct. The document also reaffirms our ethical commitment and responsibilities in our various businesses.

Spelling out the Code of Conduct

If needed, additional documents may be used to make the Code easier to understand and apply. These documents are prepared at management’s request and are often designed to meet the specific needs of a particular region or business.

Some are tailored to local situations, such as Total E&P Myanmar Ethics Charter or Total South Africa Code of Ethics.

Others develop specific topics, as for example the Business Integrity Guide or the Human Rights Internal Guide.

The Business Integrity Guide was published in March 2008 to support application of the integrity principles – rejection of corruption and fraudulent practices, avoidance of conflicts of interests – contained in the Code of Conduct. It provides concrete examples of possible risk situations encountered in our business relations and reiterates Total’s policies with regard to corruption, fraud and conflicts of interest.

The Human Rights Internal Guide was created to provide all employees with support and guidance about human rights and strengthen their vigilance. It was published in June 2011.

Raising employee awareness of our ethics process

Many initiatives are also undertaken to raise employee awareness. We all have to embrace this process so that any issues that arise can be resolved. For that reason, we created an Ethics Committee that can be consulted by any employee, at any time, in complete confidentiality.

The Ethics intranet site, which was launched in 2005, presents Total’s approach and priority actions, as well as the main reference documents.

The intranet site serves two educational objectives. First, it provides access to a wide range of information (90 pages in all, plus 350 links to external sites) and, second, it enables employees to share best practices, order documents and contact the Ethics Committee.

The intranet site is regularly updated and includes pages on specific topics, such as human rights, integrity and transparency. It also publishes policy statements and provides access to documents that support our ethical approach to business.

To promote the intranet site and encourage Total employees to learn more about it and to use it to share their views, a promotion kit was created in 2006.

Ongoing training

Between 2003 and 2005, the Ethics Committee conducted around 30 seminars on ethics, values and cultures around the world, attended by more than 2,000 line and corporate managers. Since 2006, the Committee, with the support of Total University, has developed dedicated training programs:

• “Our Ethical, Environmental and Social Responsibilities”, a traveling seminar for line and corporate managers worldwide.


• “Ethics and Business ”, a one and one-half day retreat for senior executives and line and corporate managers enabling them to better understand the resources and procedures available to help them apply the Code of Conduct. All newly appointed senior executives are required to attend the seminar within two years after taking on their new responsibilities.

In addition to these seminars, the Ethics Committee takes part in more than 30 events each year on average, either at the request of the Group’s business or corporate units or as part of a training program. Every year, around 2,500 Total managers receive ethics training.

Monitoring

Assessing our business units

The Ethics Committee completes the ethics process through the use of ethical assessments to determine how the Code is applied in various business units. These assessments provide units with advice and enable them to implement additional or corrective measures if needed.

The process was introduced in 2002 in partnership with GoodCorporation, an independent UK company that specializes in analyzing and certifying local ethics performance.

Using GoodCorporation’s methodology, a process was developed that covers all ethical aspects of the Code of Conduct through 87 compliance criteria known as evidence points. Each evidence point is assessed to ensure that policies are being correctly applied. The scores obtained make up the unit’s “ethical profile,” providing an outside view of its ethical and corporate responsibility performance.

This support and improvement process has gradually been broadened and deepened with:

• Reassessments to measure progress.


• Modules used by subsidiaries and project groups for self-assessment, assessment and reassessment, which were created on request and are currently being implemented.

To date, more than 80 assessments have been carried out. In 2010, eight affiliates were assessed and for the first time, Total conducted the ethical assessment of an investment project with the assistance of GoodCorporation.

Listening to and advising employees

The Ethics Committee provides employees with assistance in resolving ethical problems that may arise in the course of performing their duties.

All questions and correspondence are treated confidentially, as stipulated in the Code of Conduct (“The Committee’s members shall not reveal the identity of any person requesting their advice and may not disclose information that would make it possible to identify them.”).

A specific whistleblowing policy statement has also been issued to protect employees.

The Ethics Committee handles around 60 cases/questions each year, about half of which are questions from employees. In 2010, 73 cases/questions were raised, the majority by employees. Although this number may seem low, it should be kept in mind that the Ethics Committee is considered the ultimate resort for employees, who are encouraged to first contact their line manager, another manager or a local ethics officer, if this position exists.

Reporting to management bodies

Apart from reporting on special referrals, the Committee Chairman reports on the Committee’s work and objectives to the Executive Committee and the Board of Directors at least once a year.

Recent achievements

This information is collected for purpose of Communication on Progress in line with our UN Global Compact report.

Distributing and adapting the Code of Conduct

• Since 2000, more than 400,000 copies of the Code of Conduct have been distributed.


• Since the Business Integrity Guide was published in March 2008, approximately 50,000 copies have been distributed.


• A Human Rights Internal Guide was published in June 2011 as a complement to the Code of Conduct. It explains Total Human Rights Policy and help employees in decision-making by providing practical examples.

Raising awareness

Each year, the Ethics Committee takes part in more than 30 management meetings, business seminars and training sessions. Together with Total University, the Committee also organizes an average of five dedicated seminars a year in various countries, such as Argentina, Belgium, Canada, China, France, Nigeria, Russia and South Africa.

In 2010, the Committee participated in 41 events including the dedicated seminars.

Assessing

In 2010, ethical assessments of eight affiliates and one investment project were carried out in conjunction with GoodCorporation.

Since 2009, more than 60% of ethics processes are operating satisfactorily, 25 to 30% could use improvement and 10 to 15% are in need of strengthening.

Listening and advising

In 2010, the Committee also handled 34 cases and responded to 39 requests for advice, in particular regarding interpersonal relations and integrity issues.

Reporting

The Committee presented a full-year review to the Executive Committee and the Board of Directors early 2011.