Code of Business Conduct & Ethics

We are committed to high standards of moral, legal and ethical behavior.

Message from our Chief Compliance and Ethics Officer

At CITGO we believe holding ourselves to the highest moral, legal, and ethical standards is integral to doing business. Our Code of Business Conduct and Ethics is an integral part of our business, and all employees, officers, contractors, business partners, suppliers and third party representatives are expected to read, understand, and strive to uphold the values and principles of the Code.

-- Jack Lynch | Vice President of Legal & Government Affairs and Chief Compliance & Ethics Officer

Upholding our core values

Our full Code of Business Conduct and Ethics outlines the responsibilities of all CITGO Employees, Officers, Contractors, Business Partners, Suppliers and Third Party Representatives to uphold our core values. Principal among these responsibilities is the maintenance of a legal and ethical work environment that upholds safety, security and environmental standards – and is free from harassment and discrimination.

Promoting a positive working environment: Responsibilities to ourselves, others and our surroundings

CITGO is committed to attracting, employing, and retaining a diverse, motivated and productive workforce. CITGO provides equal opportunity for employment without discrimination, and maintains affirmative action programs to ensure equal opportunity. All CITGO employees, officers and contractors are responsible for ensuring the workplace is free from harassment and discrimination, and retaliation will not be tolerated. CITGO is committed to protecting the environment, public health and the safety of its employees, contractors and the public.

Observing high ethical standards: Responsibilities to the Company

All employees of CITGO have a primary business responsibility to always act in the best interests of the Company. They must comply with all applicable laws and regulations, adhere to high moral and ethical standards, and refrain from being involved in outside business or financial activities or interests that may interfere with the proper performance of their employment or harm the best interests of CITGO. Employees may not profit or receive personal gain from information or business opportunities acquired while employed at the Company. Employees must observe sound standards for information security, technology and records management practices.

Adhering to high legal standards: Responsibilities to government and the law

CITGO and its stakeholders have a duty to comply fully with the letter and spirit of the law. The Company’s management is responsible for ensuring that all personnel they supervise comply with all applicable laws, the Code and all other Company policies.

Developing strong partnerships: Responsibility and integrity in procurement

CITGO procurement efforts are governed by high standards of integrity. To that end, CITGO has adopted a series of policies and procedures designed to ensure that procurement and corporate spending is always done in the Company’s best interest. All CITGO counterparties are screened through the CITGO proprietary Compliance Check system and checked against applicable U.S. and international databases. CITGO maintains a Procurement Committee (CPC) to assist the Company in the oversight of key procurement decisions and ensuring that procurement is done in the Company’s overall best interests, including finance and operations.

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