Ethical Business Conduct

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Our position and commitments

The amounts of money involved and the diversity of the various regions require the oil industry to be particularly vigilant about corruption and fraud.

About 25% of Total’s employees work in countries deemed to be high-risk according to the Transparency International (TI) Corruption Perception Index. Therefore, reinforcing integrity and preventing corruption and fraud are major objectives for the Group and all its employees.

The key principle set out since 2000 in our Code of Conduct regarding Total’s stance on the issue of corruption is :

“Total rejects bribery and corruption in all forms, whether public or private, active or passive”.

The Code of Conduct serves as a reference document for all Group employees. It sets out the principles governing the actions and individual behavior of each person, both in their day-to-day decisions and their relations with stakeholders. In the Code of Conduct, we reiterate our support to the OECD Guidelines for Multinational Enterprises and the Tenth Principle of the United Nations Global Compact, which invites companies to act against all forms of corruption.

Christophe de Margerie, Chairman and Chief Executive Officer, repeats Total’s clear commitment to rejection of corruption on a regular basis, for example in May 2008 in the introduction to the Business Integrity Guide:

“[…] Our commitment to integrity requires each of us to play an active role in ensuring that we all behave in an exemplary manner. That is why we have published a Code of Conduct and made integrity the linchpin of our business principles. Meeting our goal of ‘integrity toward the company and in our business relationships’ means rejecting all forms of corruption, avoiding conflicts of interest and insider dealing and protecting our assets and resources. […]

I know that I can count on your vigilance and your personal involvement in this process, which is critically important for our Group’s business efficiency and sustainable growth.”

This involved the following actions:

In 2008, creation of the Compliance and Social Responsibility Department within the Group Legal Department;

In 2008, publication of the Business Integrity Guide ; an interactive Business Integrity Guide is also available on the Group Intranet sites;

In 2009, approval by the Executive Committee of the Corruption Prevention Policy and Compliance Program, with the creation of an expanded organization dedicated to compliance;