The five of us who sit on the committee represent the different businesses—the Holding Company, Exploration & Production, Gas & Power, Refining & Marketing and Chemicals. Our job is to educate employees about the principles set out in the Code of Conduct and to make sure that the Code is properly applied. We also act as a review tribunal when ethical issues arise in the course of business. In such cases, we have access to all available information and can ask for any cooperation or assistance we need to investigate the issues referred to us, while remaining independent of Total’s other organizations.

Companies are often criticized for talking a good ethics game while neglecting to incorporate ethics into everyday practice. What’s the situation at Total?

When the Ethics Committee was created in 2001, its priority was acquiring resources and creating reference documents, of which the Code of Conduct is the linchpin. Internal communication was important during the startup phase, especially to spread the word about our ethics principles and practices. But we then took things a step further, since our main goal was to express our Code of Conduct in our workplace practices. By 2002, we had developed a procedure for independent outside assessment of ethical compliance, performed by U.K. ethics accreditation company GoodCorporation. By end-2006, 41 of our companies had already completed the ethical assessment process. We also introduced traveling seminars to help our colleagues better understand what the Code of Conduct means in our work. Approximately 30 seminars involving nearly 2,000 Total managers have been held since 2003. During the seminars, a lot of time is spent in workshops that focus on real-world examples of ethical dilemmas, such as bribery, corruption and facilitation payments, as well as issues related to human rights, competition and human resources. Role-playing puts participants in situations that force them to take a stand, come up with solutions and justify their position. Discussions can become heated. We don’t attempt to feed participants ready-made answers, but encourage them to ask questions, recognize the problems that are out there and stay vigilant. We want to remind them that legislation can be an invaluable aid, even though simply complying with the law may leave some of their questions unanswered. In 2006, we launched a new international seminar on broader social responsibility, with substantial discussion of ethical issues. We also set up a dedicated ethics intranet site to familiarize employees with our principles and practices. It features detailed information on our ethics focuses and provides access to our main reference documents.

Auditing, training, awareness—what’s next?

We’re especially committed to making the Code of Conduct accessible in an increasing number of countries. That means making it easier to understand in all cultures and simplifying local distribution. The Code is currently available in 16 languages and we intend to have it translated into other languages in 2007.

In addition, we’re conducting ethical reassessments in some of our subsidiaries to determine what progress has been made since the initial exercise. Nine units have been reassessed since 2005 and four more will be reassessed in 2007. We’re also continuing to roll out a self-assessment procedure to help our units determine for themselves how well they’re complying with the Code of Conduct. Self-assessment speeds up the process of assessing and analyzing Total’s ethical conduct and enables us to identify best practices, which we’re gradually sharing via the intranet.

Where does Total stand on whistleblowing?

All employees are encouraged to confidentially report perceived violations of the Code of Conduct to the Ethics Committee. Potential issues raised by whistleblowing are frequently discussed in our seminars. A lot of employees want to know what the difference is between informing on colleagues—which nobody likes to do—and whistleblowing when they come across ethically questionable situations, such as violations of rules and standards. Obviously, we don’t encourage malicious behavior, but we do want to do everything possible to encourage employees faced with what they believe to be unethical practices to take their concerns to the Ethics Committee, confidentially and without fear of reprisal.
The Sarbanes-Oxley Act of 2002 on financial and accounting disclosure gives new urgency to the issue for Total, whose shares are listed in the United States. A practical consequence was that starting in 2005 people from outside the company have been able to refer finance, accounting and internal control issues to the Ethics Committee, which forwards them to the Chief Corporate Auditor for investigation. He then reports to the Board of Directors’ Audit Committee.