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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546
DIVISION OF
CORPORATION FINANCE
Mail Stop 5546
September 29, 2005
David J. O`Reilly, Chief Executive Officer
Chevron Corporation
6001 Bollinger Canyon Road
San Ramon CA 94583
Re: Chevron Corporation
Form 20-F for the Fiscal Year Ended December 31, 2004
Filed March 3, 2005
File No. 001-00368
Dear Mr. Humphrey:
We have limited our review of the above filing to
disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and we will make no further review of
the filing. Our review with respect to this issue does not
preclude
further review by the Assistant Director group with respect to
other
issues. At this juncture, we are asking you to provide us with
supplemental information so that we may better understand your
disclosure. Please be as detailed as necessary in the explanation
you provide for these comments. After reviewing this information,
we
may or may not raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
General
1. We note statements and maps on your website indicating that you
have operations in Syria. Chevron`s Form 10-K makes no mention of
Syria or operations there. For example, see the text and maps
describing worldwide operations in "Review of Ongoing Exploration
and
Production Activities in Key Areas," beginning on page 11. Please
address the accuracy of the disclosure and the current state of
activity in regard to operations in Syria. We note also that a
map
entitled "ChevronTexaco operations in the Middle East" on your
website indicates that you conduct lubricants operations in Syria
(see pdf document available at
http://www.chevron.com/operations/middle%5Feast/default.asp).
Finally, we note an October 2004 media report of a U.S. State
Department news conference during which an administrator stated
that
Pakistan took over Chevron`s oil concessions in Sudan.
In light of the fact that the U.S. State Department has identified
Sudan and Syria as state sponsors of terrorism, and both countries
are subject to U.S. economic sanctions, please describe for us all
previous, current and anticipated contacts with Syria and Sudan,
whether through subsidiaries, joint ventures, affiliates,
investments
or other direct or indirect arrangements.
2. Please discuss the materiality of your contacts with Sudan and
Syria, and whether your contacts with those countries constitute a
material investment risk for your security holders. In preparing
your response please consider that evaluations of materiality
should
not be based solely on quantitative factors, but should include
consideration of qualitative factors that a reasonable investor
would
deem important in making an investment decision, including the
potential impact of corporate activities upon a company`s
reputation
and share value. In this regard, we note that Arizona and
Louisiana
have adopted legislation requiring divestment from, or reporting
of
interests in, companies that do business with U.S.-designated
state
sponsors of terrorism. We note also that Illinois and New Jersey
have adopted legislation requiring divestment from, or reporting
of
interests in, companies that do business with Sudan, and several
other states recently have proposed similar legislation.
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please
understand
that we may have additional comments after reviewing your
amendment
and responses to our comments. Please file your response letter
on
EDGAR.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision. Since the company and its
management are in possession of all facts relating to the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filing; and
the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filing.
Please contact James Lopez at (202) 551-3536 if you have any
questions about the comments or our review. You may also contact
me
at (202) 551-3470.
Sincerely,
Cecilia D. Blye, Chief
Office of Global Security
Risk
cc: Roger Schwall
Assistant Director
Division of Corporation Finance
David J. O'Reilly
Chevron Corporation
September 29, 2005
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