In recent years, companies have come under increased pressure to demonstrate that they have programs in place to communicate ethical expectations and guidelines to their workforce. The following are ways in which we promote ethical decision making and monitor compliance:

Integrity Education
Informing employees about the importance of integrity at Nexen is done through our integrity education initiatives. All employees and certain contractors are required to take part in integrity education.

At Nexen, we employ a values-based approach to ethics and encourage dialogue as a means of exploring and resolving ethical issues. The intention of integrity education is not to "teach" ethics; rather, it is to provide a set of guidelines and encourage discussion. Our core integrity education initiatives include:

Integrity Workshop
All new employees are introduced to our Integrity Program through a mandatory Integrity Workshop. The workshop is three hours long and covers our views on integrity, our values and our integrity-related policies. Case studies are used to promote dialogue and to help set the tone for ethical decision-making.

Annual Online Integrity Course and Statement of Compliance
Each year, Nexen requires all employees and certain contractors and acknowledge that they have been in compliance with key company policies or to provide details of any violations. Nexen's senior management and Board of Directors support this initiative and complete the same course as Nexen employees.

Recently, this process was automated and an annual integrity course was added to the mandatory policy sign-off. The content of the course changes annually; the intention being to address the areas that are most pertinent to the organization at the time and to encourage thought and stimulate discussion about issues that arise on a fairly regular basis.

While all employees are required to acknowledge their compliance with the Ethics Policy, employees who work in especially integrity-sensitive positions are also required to acknowledge compliance with certain other policies that are applicable to their job functions and level of accountability.

Through the annual statement of compliance process, employees are given the opportunity to report actual or suspected integrity issues that they are aware of. All concerns or reported violations are reviewed with the individual(s) concerned and are followed up with our Chief Legal Officer. A summary report of these disclosures is also presented to our Board of Directors annually.

Prevention of Improper Payments Workshop
Prevention of Improper Payments Workshops are also provided to employees in certain positions; especially those individuals who are working in locations that Nexen has determined to have potentially higher risk. The purpose of these workshops is to give employees the necessary knowledge, skills and access to support when making decisions in business dealings with foreign public officials.

Integrity Policies
Nexen's Integrity Policies provide guidelines for our employees and are the foundation of our Integrity Program. All newly-hired employees and contractors must review and acknowledge they understand and are willing to abide by our Ethics Policy.