We are writing to draw your attention to actions by EITI Board members that we believe constitute violations of the EITI Code of Conduct and, as such, are grounds for their immediate removal... [W]e urge that the February EITI Board meeting include a discussion about the refusal of ExxonMobil and Chevron to disclose their tax payments through the term of implementation of the EITI Standard in the United States. We believe strongly that the refusal to engage in this most basic aspect of compliance with the EITI Standard constitutes a repeated and willful violation of the EITI Code of Conduct, the EITI Constituency Guidelines... and an act of bad faith that is counter to the spirit of the EITI movement itself. 

... During the December 2015 USEITI MSG Meeting, an ExxonMobil representative [explained]... his company’s decision not to disclose taxes through the USEITI process: “… knowing that income tax reporting will soon be required under Section 1504 of the Dodd-Frank Act, companies may have chosen to wait until that rule was finalized and the requirements more clear. (ExxonMobil representative) added that many of these companies have exercised leadership in EITI around the world, and are very committed to USEITI and to tax reporting, but are awaiting the finalization of the SEC’s rulemaking.”

In the November 2017 statement announcing the end of USEITI implementation, the U.S. Department of Interior falsely suggested that U.S. laws restrict companies from voluntarily disclosing information, including taxes... To the contrary, Dallas-based Kosmos Energy has voluntarily disclosed its U.S. tax payments for years, and BHP Billiton... voluntarily disclosed its tax payments to the U.S. government before it was required to do so by the EU Directives.