1. CODE
OF
BUSINESS a1
CONDUCT
AND
ETHICS
Hess Corporation
1185 Avenue of the Americas
New York, New York 10036
Printed on recyclable paper

2. Dear Hess Colleague:
The success of our Company depends on the talent,
discipline and drive of each of us, as well as a com-
mitment to the Company, its core values and its cus-
tomers. For us to continue to grow as a leading glob-
al independent energy enterprise, we must not only
create value and consistently achieve outstanding
results in our business units but also excel in other
critical areas, including personal and business
ethics, legal and regulatory compliance, worker
safety and fairness, and protection of the environ-
ment.
This Code of Business Conduct and Ethics sets forth
standards of conduct for anyone who represents the
Company. By taking ownership of and responsibility
for the values and policies described in this Code we
can earn the respect of our shareholders, our com-
petitors, government officials and each other.
Each of us must embrace the highest standards of
business and personal integrity and perform our
duties with careful adherence to applicable policies,
laws and regulations. Our reputation depends on it. I
encourage you to read and understand the Code and
conduct your business in a thoughtful manner
consistent with it. If each of us does this while
striving to achieve outstanding business results, we
can become a great company, the leading global
independent.
Sincerely,
John B. Hess
Chairman of the Board and
Chief Executive Officer

3. INTRODUCTION
I. BUSINESS ETHICS
• Our Values
• Conflicts of Interest
• Corporate Opportunity and Confidential
Information
• Treatment of Employees
• Entertainment and Gifts
• Foreign Corrupt Practices Act
• Political Contributions
II. COMPLIANCE WITH LAWS
• Insider Trading and Other Securities Laws
• Environmental Laws
• Occupational Safety and Health
• Antitrust Laws
• Commodities Laws
• Tax Laws
• Antiboycott Laws
• Prohibited Dealings with Certain Countries
III. EMPLOYEE RESPONSIBILITIES
• Use and Protection of Company Assets
• Assignment Abroad
• Intellectual Property
• Information Security
• Record Creation
• Record Management
• Government Investigations
• Employment of Military and Police Personnel
• Internet Usage
• Drugs / Alcohol
IV. COMPLIANCE PROGRAM
Accounting Compliance
•
Discipline and Penalties
•
Reporting Suspected Violations
•
No Retaliation
•
This Code of Business Conduct and Ethics is also available online at International Calling Instructions
•
www.iHess.com.

4. INTRODUCTION supervisors or, where appropriate, the
Company’s environmental, safety, finance,
This Code sets forth the Company’s core values and human resources and legal representatives
K reporting violations to supervisors or other
ethical standards and explains certain key areas of
the law affecting the Company. This document is Company representatives, as appropriate
intended to make all Company representatives gen-
erally aware of the legal and ethical issues that may The Company acts through its representatives. When a
arise in the course of the Company’s business. It does Company representative acts dishonestly, unscrupu-
not address every situation or set forth rules that will lously or unsafely, the Company’s reputation is
answer each question but instead is intended to pro- harmed. Under certain circumstances, the Company
vide general guidance and assist individuals in mak- can be held liable for a criminal violation by such
ing the right decisions. If you have any questions individuals.
about the Code you should discuss them with your
I. BUSINESS ETHICS
supervisor or the Legal Department.
Representatives of the Company, wherever they
All representatives of the Company and its
subsidiaries including directors, employees, indepen-
may be located, must conduct business with
dent contractors and consultants when acting on
uncompromising honesty and integrity. Each of us
behalf of the Company are responsible for acting at
has an obligation to deal fairly with the Company’s
all times in compliance with the law, with the poli-
customers, suppliers, competitors, officers and
cies set forth in this Code of Business Conduct and
employees. No one should take unfair advantage of
Ethics (formerly, the Business Practice Guide) and
anyone through manipulation, concealment, use of
with other Company policies relevant to such per-
privileged information, misrepresentation of
son’s activities.
material facts or any unfair dealing practice.
The Company will report any changes to this Code
either in filings with the U.S. Securities and Our values form the backbone for the way we con-
Exchange Commission (the “SEC”) or on the duct ourselves and our business and each repre-
Company’s website at www.hess.com. Any waiver of sentative should act in accordance with such
this Code for an executive officer or a director may be values while using good judgment and common
made only by the Board of Directors of the Company sense. All representatives are expected to make a
or a Committee of such Board. The Company will dis- commitment to such values when dealing with
close any waivers of this Code made for any executive each other, with customers, partners and govern-
officer or director of the Company in an SEC filing or ment officials and with all other third parties.
on the Company’s website.
OUR VALUES
Compliance depends on each person:
All
K being aware of the legal issues affecting representatives of the Company should shape
the Company, with particular reference to their behavior around the following corporate values:
the laws, rules and regulations that pertain to Integrity: We are committed to the highest level of
the individual’s area of responsibility integrity in all of our relationships.
K seeking and following the advice of
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5. CORPORATE OPPORTUNITY AND
People: We are committed to attracting, retaining
and energizing the very best people by investing in
CONFIDENTIAL INFORMATION
their professional development and providing them
Representatives of the Company may have access to
with challenging and rewarding opportunities for
personal growth.
trade secrets and other proprietary or confidential
Performance: We are committed to a culture of information of the Company. The Company considers
performance that both demands and rewards out- this information to be an asset of the Company which
standing results throughout our business. all representatives must strictly protect and preserve
both during and after their affiliation with the
Value Creation: We are committed to creating
shareholder value based on sustained financial per- Company.
formance and long-term profitable growth. Representatives of the Company owe a duty to the
Social Responsibility: We are committed to meeting Company to advance the Company’s legitimate interests
the highest standards of corporate citizenship by when the opportunity to do so arises and are therefore
protecting the health and safety of our employees, by prohibited from:
safeguarding the environment, and by creating a K taking for themselves opportunities that are
long-lasting, positive impact on the communities discovered through the use of Company property,
where we do business. information or position
Independent Spirit: We are committed to preserving K using Company property, information or position
the special qualities and unique personality that for personal gain
have made us a successful, independent enterprise. K competing with the Company
Furthermore, all employees are subject to the
CONFLICTS OF INTEREST Company’s statement on “Security of Confidential
All Information” and Nondisclosure Agreements they exe-
Company representatives must be scrupulous in
cuted with the Company. Both documents are available
avoiding even the appearance of a conflict of interest
on iHess and are useful guides which should be consult-
with regard to the Company’s interest. A “conflict of
ed by all employees.
interest” exists whenever an individual’s private
interests interfere or conflict in any way with the
TREATMENT OF EMPLOYEES
interests of the Company. If any representative of
The
the Company considers undertaking any transaction
Company is committed to equal employ-
or relationship that reasonably could be expected to
ment opportunity regardless of race, color, sex, age,
give rise to an actual or apparent conflict or dispari-
religion, disability, sexual orientation, marital/family
ty of interest between the representative and the
status, national origin or status as a disabled or
Company, the Company representative must disclose
Vietnam era veteran. The Company adheres to a policy
such activity in advance to the Legal Department for
of affirmative action consistent with applicable legal
review. Individuals should consult the Company’s
guidelines and seeks to provide a work environment
“Statement of Policy Relating to Conflicts of Interest
where employees can realize their potential.
Between Employee and Company” for additional
information and examples of potential conflicts. The The Company firmly prohibits sexual and other forms
policy is available on iHess. of harassment in the workplace. The Company also
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-6-

6. FOREIGN CORRUPT PRACTICES ACT
complies with the Fair Labor Standards Act and with
local employment laws in jurisdictions in which it
The
has operations or offices. United States and other countries in which the
Company or its subsidiaries operate have laws
The U.S. Health Insurance Portability and
restricting or prohibiting the providing of gifts to gov-
Accountability Act (HIPAA) requires the Company’s
ernment officials. Company representatives may not
health plans to protect the privacy of certain health
offer anything of value to a government official for the
information of individuals covered under the plans.
purpose of influencing the recipient to take or refrain
The Company may not receive an individual’s health
from taking any official action or to induce the recip-
information from the health plans without the
ient to conduct business with the Company.
individual’s authorization. In addition, the Company
cannot use health information for employment-
In addition, the Foreign Corrupt Practices Act
related actions or decisions. Employees who receive
(FCPA) prohibits the payment of, or offer to pay, any-
health information in the course of performing their
thing of value, directly or indirectly, to any foreign
duties for the Company (or for the Company’s health
official, foreign political party or foreign political can-
plans) are also required to comply with HIPAA’s
didate, if the purpose of the payment is to cause the
requirements.
recipient to act, or refrain from acting, so as to assist
ENTERTAINMENT AND GIFTS a company in obtaining or retaining business or in
directing business to any particular person. Payment
Company representatives may not accept cash or any- made indirectly (through a consultant, contractor or
other intermediary) is also prohibited.
thing of more than token value (including entertain-
ment) from any concern that does, or is seeking to do,
Representatives of the Company are not permitted to
business with, or is a competitor of, the Company.
offer gifts of other than minimal value or to provide
Likewise, bribes, kickbacks or other similar gifts or
travel or entertainment to any government employee
payment to or from an individual or company are pro-
without the prior written approval of the Executive
hibited. Furthermore, no Company representative
Vice President and General Counsel or Vice President
should ever accept a gift where it could appear that the
Audit & Compliance.
representative’s business judgment has been compro-
mised. If you have any questions about the appropri-
The FCPA does provide for an exception for facilita-
ateness of accepting a gift please consult the Legal
tion payments, if they are legal and customary in the
Department.
local country. It is the policy of the Company that
With respect to giving gifts, Company representatives these payments be avoided whenever possible. If such
may not give a gift if it could be seen as consideration payments are necessary, they must be approved in
for an official or business favor. Appropriate enter-
advance by the Executive Vice President and General
tainment may be offered by persons authorized to do
Counsel or Vice President Audit & Compliance.
so. As discussed in more detail below, particular care
should be taken when the proposed recipient of
The FCPA applies to all U.S. companies, foreign
entertainment or gifts is a government official since
companies subject to the jurisdiction of the U.S.
entertainment of, or even token gifts to, such officials
Securities and Exchange Commission, and all persons
are prohibited in many jurisdictions.
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7. II. COMPLIANCE WITH LAWS
subject to U.S. jurisdiction. Penalties under the FCPA
include fines and prison terms. Individuals should
The
consult Executive Directive 26 for additional Company is subject to federal, state, local and
information. foreign laws and regulations affecting all aspects of the
Company’s business. All representatives of the
POLITICAL CONTRIBUTIONS Company should respect and comply with all of the
Under laws, rules and regulations of the United States and
federal law, it is a crime for the Company to make other countries in which the Company does business.
a political contribution to any federal candidate (in a Such compliance should include, without limitation,
primary or general election) or to a political party. Federal compliance with the “insider trading” prohibitions
law also restricts corporate contributions to state and applicable to the Company as well as compliance with
local committees in certain circumstances and state laws the other laws referenced below.
also regulate contributions at the state and local level.
INSIDER TRADING AND OTHER
The word “contribute” is broadly defined by federal law. It
includes not only money but also the use of corporate
SECURITIES LAWS
resources and the use of corporate personnel in ways that
Generally, Company policy and the securities laws of
assist the campaigns of federal candidates. In addition,
under federal law, neither a corporation nor its manage-
the United States, the United Kingdom and many other
ment may take measures that have the intention or effect
countries where we do business prohibit trading in the
of coercing an employee into making a contribution; like-
Company’s securities by Company representatives
wise, a corporation may not directly or indirectly reim-
while they are aware of material, non-public informa-
burse an employee for a political contribution or channel
tion from or about the Company whether or not they
a contribution through an employee in order to disguise
are using or relying on that information. This restric-
its true origin.
tion extends to sharing or tipping others about such
information, who may then buy or sell securities based
In order to steer clear of any potential problems it is the
on such information.
Company’s policy not to permit the use of its facilities or
property for campaign activities. Finally, it is the The definition of “material, non-public information” is
Company’s policy not to permit executive personnel to broad. Information is “material” if there is a substantial
solicit political contributions from other employees. likelihood that a reasonable investor would consider
the information important in determining whether to
Individual employees, acting in their individual capacities, trade in the Company’s securities, or if the information,
are of course encouraged to exercise their rights as citi- if made public, could reasonably be expected to affect
zens consistent with the foregoing prohibitions. If you the market price of our securities. Information may be
have any questions about the applicability of this policy to material even if it relates to future, speculative or con-
any conduct that you contemplate, please seek guidance tingent events, and even if it is significant only when
in advance from the Legal Department. considered in combination with publicly available
information. Information is considered to be “non-
public” unless it has been publicly disclosed, and
adequate time has passed for the securities markets to
digest the information. If you have any questions about
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8. whether you possess “material, non-public informa- All Representatives of the Company must comply with
tion” or whether you can trade in the Company’s the Company’s system of disclosure controls and pro-
securities, you should consult the Legal Department cedures to provide reasonable assurances that infor-
before taking any action. Examples of information that mation required to be disclosed by the Company in the
may be confidential material, include, but are not reports that it files publicly is properly authorized,
limited to, the following: executed, recorded, processed, summarized and
reported. These procedures are designed to ensure
K acquisitions or dispositions
that information required to be disclosed by the
K results of drilling operations
Company in its reports is accumulated and communi-
K financial results
cated to the Company’s management, including the
Beyond disciplinary action, a violation of this policy
Chief Executive Officer and Senior Financial Officers,
may lead to civil and criminal penalties against the
as appropriate, to allow timely decisions regarding
Company representative. The penalties also apply to
disclosure.
sharing or tipping, regardless of whether the Company
representative derives any financial benefit from the
ENVIRONMENTAL LAWS
securities trades.
The
Securities laws in the U.S. also require timely public Company is committed to protection of the envi-
disclosure of certain information through press ronment in all areas of its operations and to careful
releases and in periodic reports to the U.S. Securities compliance with procedures designed to reduce or
and Exchange Commission. These releases and eliminate risk of damage to the environment.
reports are coordinated by the Corporate Secretary in
Environmental laws constitute a significant area of
the New York office. The Company is subject to SEC
potential legal liability for the Company. The Company
Regulation FD (“FD” refers to “Fair Disclosure”),
seeks to reduce the environmental impact of its activi-
which prohibits a company from intentionally disclos-
ties through its long-standing commitment to compli-
ing material non-public information selectively to
ance, safety and cleanliness, maintenance of its assets
specified types of securities market professionals and
in first-rate condition and implementation of an
security holders unless the company also publicly dis-
Environmental Management System.
closes the information simultaneously. Accordingly, all
inquiries from the press should be referred to the Vice The Company has an Environment, Health and Safety
President, Investor Relations, and any questions about Policy, and many Company facilities have environ-
what you may or may not disclose should be cleared mental compliance manuals and guidelines that
with the Legal Department. address matters such as:
In addition, a representative of the Company may be K spill prevention and clean-up
called upon to provide necessary information to assure K classification and disposal of hazardous materials
that the Company’s public reports and documents K clean air requirements
filed with the SEC and other public communications
K clean water requirements
by the Company are full, fair, accurate, timely and
K product specifications
understandable. The Company expects its representa-
tives to provide prompt, accurate answers to inquiries All Company representatives must be aware of envi-
related to the Company’s public disclosure require- ronmental concerns and adhere to environmental
ments. compliance guidelines affecting their activities.
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9. OCCUPATIONAL SAFETY HEALTH TAX LAWS
AND
The Many types of taxes, governmental fees and other
Company, through its Safety Management
Program and the implementation of its Environment, similar charges apply to the Company and to its
Health and Safety Policy, is committed to providing a customers, suppliers and products. These taxes may
safe and healthy work environment for its employees. include the following:
Employees must perform their duties in a manner that
K income taxes
will not pose a danger to themselves or others. Use of
K sales, excise and use taxes
safety equipment in certain areas is often required by
K environmental taxes (e.g., Superfund and
law or Company policy. It is our policy to comply with
all applicable safety and health laws and regulations. Oil Spill Liability Trust Fund taxes)
K customs duties
ANTITRUST LAWS
Individual employees are often responsible for ensur-
Antitrust ing that taxes, fees and other charges are paid by the
laws prohibit or restrict practices such as
Company or collected from customers or suppliers and
agreements among, or discussions with, competitors or
that payments and collections are accurately reported.
customers to:
K fix or control prices
ANTIBOYCOTT LAWS
K divide territories or markets
Antiboycott
K allocate customers
laws prohibit U.S. companies from
K limit production or sales participating in one country’s boycott of certain other
countries, companies or individuals. Activities that
Other actions involving competitors, customers or sales
may constitute boycotts include the following:
of the Company’s products may raise antitrust con-
cerns. Supervisors in charge of trading and sales K refusing to do business with certain countries
activities are responsible for knowledge of these con- or persons
cerns and accountable for the careful oversight of K refusing to employ certain classes of persons
employee trading and sales practices.
K refusing to transport materials to or through
certain countries
COMMODITIES LAWS K furnishing information on a person’s race,
Trading religion, sex or nationality
in petroleum and petroleum product futures
Please consult the Legal Department if you have
and options is regulated by the exchanges on which
any questions about the foregoing.
such trading occurs and by the Commodity Futures
Trading Commission. Only a limited number of
PROHIBITED DEALINGS WITH
employees are authorized to engage in such trading
CERTAIN COUNTRIES
on behalf of the Company, and these employees may
Sanctions imposed by the U.S., certain foreign gov-
not trade for their own account. All other Company
representatives are prohibited from engaging in such
ernments, or the United Nations may restrict or
trading on behalf of the Company.
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10. prohibit business or personal dealings with certain assure that Company assets are properly protected.
countries and with companies or individuals in or Representatives of the Company should assist in the
from those countries. Activities that may be protection of confidential and proprietary informa-
restricted include the following: tion including technical, financial, marketing and
other business information that, if made available to
K transfers of assets
the Company’s competitors or to the public, would
K payment of money be advantageous to such competitors or detrimental
K provision of services to the Company.
K exports of sensitive technology In addition, representatives of the Company should
K travel to the affected countries take appropriate measures to ensure the efficient
use of the Company’s assets, since theft, careless-
Please consult the Legal Department if you have
ness and waste have a direct impact on the
any questions about the foregoing.
Company’s profitability.
III. EMPLOYEE ASSIGNMENT ABROAD
RESPONSIBILITIES
Employees may be offered the opportunity to work
USE AND PROTECTION on an expatriate basis at one of the Company’s offices
OF COMPANY ASSETS outside their home country. Expatriate employees
are ambassadors for the Company, particularly in
We countries where the Company and its activities con-
are all responsible for maintaining and pro-
stitute a significant part of the local economy.
tecting the assets (both tangible and intangible) of
Expatriate employees are expected to maintain stan-
the Company and for conducting ourselves in a pro-
dards of conduct and behavior, even in their off-duty
fessional manner.
hours, which reflect acceptable social standards both
Company assets are to be used for the legitimate
in their home country and in the host country. The
business purposes of the Company and only by
Company reserves the right to repatriate any em-
authorized representatives of the Company or their
ployee whose conduct or behavior has embarrassed,
designees. This includes office equipment, intellec-
or has the potential to embarrass, the Company.
tual property such as pending patent information,
Conduct or behavior of this nature may also result in
trade secrets or other confidential or proprietary
disciplinary action.
information (whether in printed or electronic form)
and electronic media and communication systems.
INTELLECTUAL PROPERTY
Representatives of the Company should not use the
Company’s e-mail, voice mail and telephone systems
Many materials used by the Company, such as com-
in any way that is harmful or embarrassing to the
puter software, journals and other publications, are
Company.
protected under the federal copyright laws or by
Representatives of the Company are responsible for licensing agreements and may not be disclosed or
ensuring that appropriate measures are taken to copied. Certain equipment and processes used by the
Company may be patented.
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11. K intentionally distort or disguise the true nature
INFORMATION SECURITY
of any transaction in recording and document-
Security ing accounting entries;
of information is critical to the success of the
K make a representation, either in a document
Company and maintaining security is the responsibility
of each Company representative. The Company’s infor- or in oral communication, that is not fully
mation security policies are presented in the accurate; or
Information Service section of iHess. In particular, no K establish any undisclosed or unrecorded funds
one should ever give or share a password with anyone. or assets for any purpose.
If a password becomes compromised, the user should
Questions regarding this policy should be addressed
contact the local security administrator to have it reset.
to the Legal Department. Representatives of the
Furthermore, when choosing a password, please follow
Company are encouraged to submit any concerns or
the guidelines in the Password Security Policy on
complaints anonymously or confidentially regarding
iHess. If a Company representative becomes aware of
accounting, internal accounting controls or auditing
a situation that might compromise the Company’s secu-
matters. For more details, see “Reporting Suspected
rity, that person should contact the local IS
Violations”.
Infrastructure Manager or the IS Security Coordinator
at 713-609-4170.
RECORD MANAGEMENT
RECORD CREATION
Records should be maintained to comply with applic-
Employees are responsible for the accuracy and able statutory, regulatory or contractual requirements,
as well as pursuant to prudent business practices. U.S.
completeness of the books and records of the
law prohibits any representative of the Company from
Company. This means that employees must:
assisting or encouraging our independent accountant
K maintain accurate records of transactions, in destroying corporate audit records, such as work-
time reports, expense accounts and other papers, documents that form the basis of an audit or
financial records; review, memoranda, correspondence, communications,
K comply with the Company’s system of internal other documents, and records (including electronic
controls over financial reporting; and records) which are created, sent or received in con-
K report to the Company’s Disclosure Review nection with an audit or review and contain conclu-
Committee any significant deficiencies or sions, opinions, analysis, or financial data relating to
material weaknesses, including corrective such audit or review.
actions, in the design or operation of the
GOVERNMENT INVESTIGATIONS
Company’s internal controls over financial
reporting, which could adversely affect the
If
Company’s ability to record, process, summa- a representative of the Company learns about a pos-
rize and report financial data. sible government investigation or inquiry, inform the
Legal Department immediately. U.S. law prohibits any
Representatives of the Company may not:
representative of the Company from altering, destroy-
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12. ing, mutilating or concealing a record, document, or material that is potentially offensive on the basis of sex,
other object, or attempt to do so, with the intent to race, religion, national origin, sexual orientation or
impair the object’s integrity or availability for use in an disability.
official proceeding. U.S. law also prohibits any repre-
Dissemination of information confidential to individu-
sentative of the Company from otherwise obstructing, als or to the Company is also prohibited. The Company
influencing or impeding any official proceeding or any does not allow the copying or downloading of copyright-
attempts to do so. In connection with these policies, protected Internet material; when ownership is
please consult the Legal Department in the event of lit- unclear, employees must follow policy guidelines to
igation or any investigation or proceeding. determine whether the information is in the public
domain.
EMPLOYMENT OF MILITARY AND Employees are responsible for immediately reporting
POLICE PERSONNEL any new viruses or suspicious e-mail attachments to
In prevent further contamination. To alert the appropri-
some countries where the Company has operations, ate technicians, employees must send an e-mail to the
it may be necessary on occasions for the Company to Virus Team address set up in the e-mail system, briefly
engage the assistance of local military or law enforce- describing the problem and leaving a contact phone
ment personnel for security or operational reasons. number. Shortly afterward a Virus Team member will
This should be avoided whenever possible. Where call the sender for follow up.
avoidance is impossible, prior approval should be
The Company reserves the right to make and enforce
sought under Executive Directive 26. In the case of a
acceptable use policies for its equipment and network.
dire emergency where there is a significant threat to
This includes the right to monitor all network traffic,
Company (or the Company’s contractors’) personnel,
all information transmitted and stored, including
or to significant assets of the Company or its contrac-
e-mail, on the network or in any computer provided by
tors, and immediate protection is necessary, approval the Company, the right to limit use of the network and
to employ local military or law enforcement personnel systems, the right to block access to non-Company
may be given by the highest level of local management computers and the right to examine its equipment,
readily contactable. data files and e-mail at its discretion, without notice.
The Company’s Internet Access Policy is available on
No approval is necessary for employees to summon
iHess.
local police assistance for themselves or their families
when necessary, or for employees to report a crime to
DRUGS / ALCOHOL
the local police.
An
INTERNET USAGE employee will be discharged immediately if found
selling an illegal or controlled substance at any time,
The Company provides employees with Internet either on or off Company property, or possessing/using
access primarily for business activities requiring an illegal substance on the job or on Company property.
document viewing, e-mail, file transfers to Company Disciplinary action, in some circumstances including
computers, and terminal connections to authorized immediate discharge, may follow if an employee is
Internet computers. Employees are not permitted found to be under the influence of illegal substances or
either to access or transmit pornography or other alcohol while at work or has alcohol on Company
20- 21-

13. premises without authorization. Law enforcement offi- dentially or otherwise) to the Audit Committee of the
cials will be notified if illegal substances are found on Board of Directors (which will, subject to its duties
Company property. arising under applicable law, regulations and legal
proceedings, treat such submissions confidentially).
The Hess Substance Abuse policy, available on iHess,
Such submissions may be directed to the attention of
provides a description of Company policy and prac-
the Audit Committee through use of the Company’s
tices, as well as information about the Company’s
U.S. reporting hotline at 800-353-2790. For more
Employee Assistance Program (“EAP”) and other
details, see “Reporting Suspected Violations”.
available resources. Reference should be made by
those employees having a collective bargaining agree-
DISCIPLINE AND PENALTIES
ment to their specific labor agreement regarding this
In order to maintain compliance with the law
subject.
and preserve its reputation, the Company will
IV. COMPLIANCE PROGRAM treat seriously any violation of law or failure to
adhere to the principles set forth in this Code. In
This document is a focal point of the Company’s pro- appropriate circumstances, suspension or dis-
gram for promoting compliance with law and Company missal may result.
policy, but it is only one part of an ongoing effort to pre-
Violations of law can result in criminal or civil penalties
vent and detect violations. All Company representa-
against the Company and the employee, including sub-
tives must sign and return the enclosed form to their
stantial fines and prison terms.
local Human Resources Department, confirming that
they have read this document and understand its
REPORTING SUSPECTED VIOLATIONS
contents. Directors must confirm in writing to the
Corporate Secretary or General Counsel that they have
The Company monitors compliance with the law and
read and understand its contents.
its policies. Representatives of the Company are
J. Barclay Collins, Executive Vice President and encouraged to speak to supervisors, managers or other
General Counsel of the Company, is responsible for the appropriate Company officials when in doubt about
Company’s compliance program. the best course of action in a particular situation. In
addition, employees, officers and directors have an
ACCOUNTING COMPLIANCE obligation to notify their supervisors, the Legal
Department or other appropriate Company officials of
In accordance with the Sarbanes-Oxley Act of 2002, suspected violations of law or failures to adhere to the
the Company is committed to complying with all principles set forth in this Code. Failure to notify can
applicable financial reporting and accounting regula- itself be grounds for discipline. The Company has
tions. If any employee, officer or director of the established two additional channels for reporting vio-
Company has concerns or complaints regarding ques- lations, which may be done anonymously.
tionable accounting or auditing matters of the
The Vice President Audit & Compliance is responsible
Company, then that person is encouraged to submit
for monitoring and investigating suspected violations.
those concerns or complaints (anonymously, confi-
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14. K Call the Company’s reporting hotline at INTERNATIONAL CALLING
INSTRUCTIONS
1-800-353-2790 and a representative from
Global Compliance Services will take your call.
Representatives of the Company who wish to report
K File a report anonymously by e-mail by using
violations from international locations may do so toll
the following secure website:
free by first calling the country operator and placing a
https://www.compliance-helpline.com/
collect call to a United States number 704-731-1402, or
hesshotline.
by e-mail using the following secure website:
If your concern is regarding employee benefits,
https://www.compliance-helpline.com/hesshotline
salary administration or leave of absence issues,
please call the HR Service Center at 1-877-511-4377.
If your concern is regarding customer service at a
retail gas station please call 1-800-437-7645.
NO RETALIATION
Reporting known or suspected violations of the
Company’s legal or ethical obligations is the responsi-
bility of each employee, officer and director.
Employees, officers and directors must never be
discouraged from reporting violations. In no event will
any action be taken against the Company representa-
tive for making a complaint or reporting, in good faith,
known or suspected violations of Company policy. Such
representative of the Company will not lose his or her
job for refusing an order he or she reasonably believes
would violate the provisions of this Code. All reports of
suspected violations of law or failures to comply with
the principles set forth in this document or any other
Company Statement or Policy, whether made anony-
mously or otherwise, will be treated confidentially and
will be investigated promptly, thoroughly and fairly.
Intimidation or retaliation against anyone making
such reports will not be tolerated and any employee,
officer and director who retaliates against another
employee, officer or director will be in violation of
Company policy and subject to disciplinary action
including dismissal.
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