Global Standards, Corporate Diagrams and Indigenous Agency: ExxonMobil in Russia and Alaska

This paper examines how a transnational corporation (TNC) translates global standards and corporate policies into programs at sites of extraction. We explore this question through a comparative analysis of ExxonMobil’s operations in two different politico-economic contexts: the Sakhalin-1 project in Russia and the Point Thomson project on the North Slope of Alaska, with field work on Sakhalin Island in 2013–2015 and in Alaska in 2015–2018. Theoretically, we use the Deleuzian concept of “diagram” as a lens through which to examine corporate policies, and a governance generating network (GGN) approach to analyze similarities and differences in benefit-sharing programs in both localities. We show that while global commitments and corporate principles contribute to a standardized approach to community engagement, Indigenous movements and associations, the government, and other corporate actors may play important roles in influencing how corporate policies and global standards are implemented at sites of extraction. Moreover, adaptation of community engagement, benefit-sharing, and environmental monitoring in one location may shape how the company’s strategies are implemented in other sites of extraction. Maria S. Tysiachniouk, Laura A. Henry and Leah S. Horowitz 2

network (GGN) approach to analyze the sources of similarities and differences in corporate-community relations. The GGN framework draws attention to negotiations among multiple actors over the meaning of global standards and corporate policies and how they are implemented, including opportunities for feedback and resistance.
We find that, despite starkly different political and economic contexts in Russia's Sakhalin Island and the U.S. state of Alaska, ExxonMobil used markedly similar strategies to engage Indigenous peoples, based on a "diagram" of standardized policies and programs, 6 derived in part from global conventions related to the rights of Indigenous peoples. However, the implementation of these policies in each territory of extraction was shaped by local factors, including differences in national law and ownership, and mediation by Indigenous institutions and resistance and protest by Indigenous communities. The diagram of standardized programs may also change over time. Ultimately, we argue that, while TNCs prefer consistent policies to reduce transaction costs and manage risks, Indigenous movements and associations, governments, and other corporate actors all play important roles in adapting corporate programs based on global standards to specific localities.

Corporate Diagrams within a Governance Generating Network: The Theoretical Approach
Energy companies engaged in extraction pose particularly acute cost-benefit questions for nearby communities. 7 While distant populations benefit from the use of energy resources, communities located proximate to sites of extraction may face disproportionate environmental and health effects and disruptions to traditional ways of life. For Indigenous peoples, extraction may damage traditional cultural and economic activities, such as hunting, fishing, whaling, and foraging. 8 Given a TNC's primary focus on profit and shareholder value, CSR principles are intended to hold TNCs accountable for environmental and social impacts. Resistance and conflict around extraction creates risks of reputational damage which generates pressure for TNCs to adhere to CSR principles. 9 In response, TNCs publicize their commitment to global standards and develop their own corporate policies regarding social and environmental responsibility. Yet whether corporate social responsibility principles go beyond public relations and are implemented as practices on the ground remains under-examined.
Theoretically, we use the concept of a governance generating network (GGN), in conversation with the Deleuzian concept of "diagram", to consider how networks around oil extraction, including transnational energy companies and local subsidiaries, financial institutions, and investors interact with government agencies and civil society actors, such as Indigenous peoples and environmental NGOs, in various forums. 10 The concept of diagram draws our attention to the way in which complex streams of thought around corporate responsibilty interact and produce a simplified, standardized, and generalized orientation toward community and Indigenous relations. A GGN analysis draws attention to how territories of extraction are governed by networks of actors at multiple scales and represents a range of shifting relationships between actors involved in the design, transfer and implementation of new rules. 11 Each GGN consists of three main components: transnational nodes of global governance design, forums of negotiation, and sites of implementation (see Figure 1). The development of rules and standards for the extractive industry takes place in transnational nodes of design. Non-binding conventions, such as the United Nations Declaration on the Rights of

Global Standards, Corporate Diagrams and Indigenous Agency
Indigenous peoples (UNDRIP) and the Arctic Council's (AC) Offshore Oil and Gas Guidelines, attempt to foster sustainable production practices that protect the rights of Indigenous peoples from the negative impacts of extraction. The Extractive Industry Transparency Initiative (EITI), IPIECA, and the International Monetary Fund (IMF), the International Financial Corporation (IFC), the World Bank (WB), and the European Bank of Reconstruction and Development (EBRD) also develop standards for TNCs, some as recommendations and others as requirements.
Sites of implementation are locations where energy companies explore for, extract, and transport resources, and construct infrastructure. These sites are where rules and standards are put into practice and adapted to the specific contexts of local communities. Forums of negotiation connect sites of implementation to transnational nodes of design (e.g. TNC corporate offices, investment banks, and/or international institutions). Through these forums, private, state, and civil society actors negotiate changes in global rules and standards or their implementation practices (see Figure 1). Within a GGN, civil society campaigns may transmit grievances from sites of implementation to global institutions, such as international financial institutions or UN forums, and attempt to introduce issues to global agendas or to change practices in sites of implementation. In turn, TNCs both accommodate and foster institutional changes locally as they implement global standards. 12 In adopting global standards and developing their own corporate policies, TNCs themselves become nodes of global governance design. A TNC's standardized approach to developing implementation strategies that adhere to global conventions and their own policies can be understood as a "diagram" -the creation of an abstract "map of relations between forces,'' 13 the development of a repertoire of strategies, and a generalized framing of a problem and series of steps for addressing it. 14 Once created, a diagram can be transferred from one context to another, as long as the "problem" appears similar. 15 For our analysis, we use the concept of diagram to describe the way in which a TNC streamlines and simplifies diverse approaches to issues of corporate-community relations (specifically benefit sharing and environmental management) and develops an abstract set of orientations and policies that both articulate and attempt to "solve" the problem, then applying the diagram in territories of extraction. As nodes of global governance design, TNCs disseminate governance arrangements that shape relations with stakeholders and prescribe programs at sites of implementation. Standardized approaches help TNCs to avoid transaction costs while operating in multiple countries. 16 At the same time, however, TNCs must adapt CSR strategies to the context of sites of implementation. TNCs prefer stable interactions to facilitate long-term risk management, as any disruption or reputation damage could result in a loss of profit. Therefore, economic "actors try to produce a 'local' stable world" that allows them to "reproduce their advantage" 17 from one site of implementation to another. As we demonstrate, such stability requires a TNC not simply to impose a prescribed diagram of community engagement policies but to develop a strategy of adaptation to local political, economic, cultural, and environmental conditions. This adaptation is shaped by pressures from stakeholder groups, including Indigenous communities, environmental activists, and government representatives. We explore the degree to which various institutions and stakeholder groups influence the diagram's adaptation from sites of implementation to forums of negotiation and transnational nodes of design, with a particular focus on benefit-sharing, or the distribution of monetary and non-monetary benefits generated through resource extraction activity. 18

Methodology
Data for this study was gathered by the primary author on Sakhalin Island in 2013-2015 during two periods of field work and on Alaska's North Slope in 2015-2018 during three periods of field work. Qualitative research methodologies, including semi-structured interviews, participant observation, and document analysis, were the primary means of data collection. Separate interview guides were created for Sakhalin and the North Slope for company representatives, Indigenous leaders, NGO representatives, and government officials. Each interview took thirty to ninety minutes. Interviews focused on the interaction between companies and Indigenous people as well as the implementation of global standards and benefit-sharing arrangements. The interviews were transcribed and coded. We also analyzed a variety of documents pertaining to ExxonMobil's CSR policies, Global Reporting Initiative reports, and other publications related to corporate-Indigenous relations, in order to compare ExxonMobil's programs in both Sakhalin and the North Slope.
In Sakhalin, 63 interviews took place with a variety of actors in Yuzhno-Sakhalinsk and villages such as the Okha and Nogliki municipal districts, where Exxon Neftegas Limited (ENL) operates (Appendix A). Interviews were conducted with the following groups: representatives of ENL, Rosneft, and Sakhalin Energy; regional and municipal government officials; NGO representatives; representatives of Indigenous peoples' associations; local residents; and scientists. In Alaska, 67 interviews were conducted in Fairbanks and Anchorage at gatherings of Indigenous peoples, and in North Slope villages. The village of Kaktovik was chosen as the primary research site due to its proximity to ExxonMobil's Point Thomson project. Interviews also were conducted at the regional center Utqiagvik and at Nuiqsut, the village most affected by oil extraction by companies other than ExxonMobil, to better understand the context on the North Slope (Appendix B). Interview subjects included representatives of local, state and federal government agencies; scientists; Indigenous leaders from regional and local village corporations, Indigenous and non-Indigenous community representatives; corporate consultants; and representatives of oil companies that operate on the North Slope, including ExxonMobil, Conoco-Phillips, and British Petroleum.
In addition, interviews were conducted in Houston with representatives from ExxonMobil and Conoco-Phillips.

ExxonMobil on the Ground: Extraction and Indigenous peoples in Sakhalin and Alaska
ExxonMobil is a profit-driven corporation dedicated to maximizing value for shareholders; however, the TNC is also a node of global governance design that claims to pursue a "triple bottom line" focused on profit, people and planet. 19 Scholarly research chronicles the development of ExxonMobil's approach to corporate social responsibility, including its efforts at community engagement 20 and resulting challenges. 21 ExxonMobil has adopted a range of global conventions as well as developed its own corporate policies and codes of conduct to guide its interactions with Indigenous peoples; the TNC frequently reiterates these commitments in its public relations materials. For example, ExxonMobil has committed to the International Finance Corporation (IFC) Performance Standards on Environmental and Social Sustainability, the World Bank Operational Policy and Bank Procedure on Indigenous peoples, and the IPIECA oil and gas industry association's environmental and social performance programs. 22 ExxonMobil implemented ISO Standard 26000 on social responsibility. In addition, corporate documents reference the UN Declaration on the Rights of Indigenous peoples (UNDRIP) and ILO Convention 169 Concerning Indigenous and Tribal peoples which recognizes "the aspirations of [Indigenous] peoples to exercise control over their own institutions, ways of life and economic development." In its policy statement on Indigenous peoples, ExxonMobil declares, "We respect Indigenous peoples and their cultures, commit to conducting meaningful consultations with them, incorporate traditional knowledge and land use information into our plans and seek mutually beneficial longterm relationships." 23 As a node of governance, ExxonMobil's policies apply to its network of whollyowned and majority-owned subsidiaries, connecting sites of implementation around the world, 24 using a diagram of community engagement and benefit-sharing policies. Given that ExxonMobil operates in many countries and regions simultaneously, it faces pressure to adapt its policies to fit the contexts of the various sites of implementation and to comply with national laws and regulations, and take into account informal local practices. It remains an open question how and to what degree this adaptation of corporate policies and programs occurs.
In the sections that follow, we first describe two ExxonMobil projects and the Indigenous communities that live proximate to these sites of extraction. We then determine the degree to which the TNC has applied its diagram of similar policies despite clear differences in each case. Finally, we examine how these varied contexts have shaped local implementation of the company's diagram of community-engagement policies.

Exxon Neftegas Limited in Russia: The Sakhalin-1 project and Indigenous
Communities Sakhalin Island is situated off the east coast of Russia in the Sea of Okhotsk. Sakhalin has a population of roughly 511,000 residents, of whom approximately 3,000 are Indigenous peoples. 25 Villages inhabited by Indigenous peoples in two municipal districts are situated in proximity to extractive infrastructure: Nogliki district which has six villages with 1135 Indigenous residents; and Okha district, which has five villages with 1457 Indigenous residents from the Nivkh, Uilta, Nanai, and Evenk peoples. Some of these Indigenous people participate in an obshchina, an Indigenous organization involved in traditional economic activities, such as fishing, reindeer herding, hunting, foraging, and artistic work.
In 1993, Exxon Neftegas Limited (ENL), a subsidiary of ExxonMobil, began the Sakhalin-1 oil and gas development project in an agreement with the Japanese company SODECO. It is owned by ENL (30%), SODECO (30%), RN-Astra (8.5%) and Sakhalinmorneftegaz-Shelf (11.5%) (both affiliates of state-owned Rosneft Company), and India's Oil and Natural Gas Corporation ONGC Videsh Ltd (20%). Sakhalin-1 represented one of the largest foreign direct investments in Russia at that time. 26 In 1996, the companies and the Russian government signed a production sharing agreement. Construction started in 2004, and the first oil was produced in 2010. 27 As of 2018, the project had exported 100 million tons of crude oil. The complex includes onshore and offshore oil rigs as well as processing facilities and shipment terminals. There is a second large oil and gas consortium on the island: Sakhalin-2, operated by Sakhalin Energy, a partnership of Royal Dutch Shell, Mitsui, and Mitsubishi Corporation. In 2007, Gazprom bought a 50% plus 1 share in Sakhalin Energy from Royal Dutch Shell.

ExxonMobil in Alaska: The Point Thomson Project and Indigenous
Communities Point Thomson is an oil and gas project historically operated by ExxonMobil (with a 62% share), with stakes also held by British Petroleum (32% share) and Conoco Phillips (5% share, sold in 2017), with a handful of other minority shareholders who left the project over the years. 28 Point Thomson is located 60 miles east of Prudhoe Bay and 60 miles west of the village of Kaktovik. The project borders the Arctic National Wildlife Refuge's northwestern corner. Point Thomson has received $4 billion in investment from ExxonMobil. 29 Construction started in 2008, pipelines were built in 2013, production modules were installed in 2014-2016, and production began in 2016. Point Thomson produces natural gas condensate, which then travels by pipeline to the Trans-Alaska Pipeline System. 30 The project is estimated to contain over 226.5 billion cubic feet of natural gas, 25 percent of the North Slope's proven natural gas reserves. 31 Global Standards, Corporate Diagrams and Indigenous Agency 9 Figure 2. Map of Sakhalin Island, Russian federation The village of Kaktovik (Inuuniagviat Qaaqtuvigmiut) is situated on Barter Island, adjacent to the Arctic National Wildlife Refuge (ANWR), and accessible only by air or boat. The Kaktovik Inupiat have been living in the area for thousands of years, but year-round settlement of the area in the modern era began in the 1920s. As of 2016, the village had 262 residents. 32 Through passage of the 1971 Alaska Native Claims Settlement Act (ANCSA), Alaska Native Corporations were granted either surface rights (the Kaktovik Iñupiat Corporation, at the village level) or both surface and subsurface property rights (the Arctic Slope Regional Corporation (ASRC)). 33 However, the federal government retained control of significant portions of land, including the Arctic National Wildlife Refuge. Local residents are simultaneously involved in market and subsistence economies, including tourism related to polar bear viewing 34 and hunting marine mammals, such as bowhead whales, walrus, and seal, as well as caribou. Prior to the Point Thomson installation, Kaktovik residents had not been directly exposed to the effects of oil development.

Adapting Global Standards and Corporate Policies to Local Conditions
ExxonMobil has constructed a diagram of standardized corporate policies that extend from its node of global governance design towards sites of implementation. These policies guide its engagement with Indigenous communities in benefit-sharing. The company's actions in two sites of extraction demonstrate the tensions between maintaining a standardized approach and the need to address local conditions. First, Figure 3. Map of the North Slope of Alaska in both cases the company centers its benefit-sharing around grant programs to support traditional economic activities and Indigenous cultural activities, although these programs are implemented differently in the two sites. In addition, in both cases, ExxonMobil consistently supports STEM education for Indigenous youth through grants, as well as through the provision of resources and equipment for health and education programs from the company directly. Second, ExxonMobil employs Indigenous community liaisons to serve as intermediaries who distribute information on company projects and grant applications, collect grievances, and organize community consultations. However, few Indigenous workers from the villages are hired by the company to work on the extractive projects. Finally, the company employs Indigenous wildlife monitors to assess environmental impacts on Indigenous traditional economic activities -salmon fishing and some reindeer herding on Sakhalin and caribou and whale hunting in Kaktovik.

Benefit-Sharing Policies
A broad view of benefit-sharing encompasses transfers of resources from extractive industries to Indigenous peoples in forms ranging from the distribution of tax revenues to employment and community grants. Some benefit-sharing arrangements fulfill commitments made in a TNC's global node of governance design, while others are developed at the request of local stakeholders. We review these areas below.
Taxation is one aspect of benefit-sharing. The Sakhalin-1 project has generated over $16 billion for the Russian government in the form of lease, tax and royalty payments, including more than $6.6 billion to the Sakhalin regional budget. 35 ExxonMobil pays taxes to the U.S. federal and Alaskan state governments and to the North Slope Borough (NSB) for its infrastructure in Prudhoe Bay. In both sites, significant tax revenue flows to regional governments --in Alaska to the NSB, and in Sakhalin, ExxonMobil and Sakhalin Energy signed a production sharing agreement which provides funding to the regional government instead of the federal until their initial investments are paid.
Indigenous organizations are more directly involved in the distribution of tax revenues in the North Slope than in Sakhalin. Kaktovik residents receive tax revenue from oil companies, including ExxonMobil, through redistribution by the NSB and the state of Alaska. In 2019 the NSB spent $77.8 million on infrastructure and services -such as airports, landfills, natural gas infrastructure -for eight villages, including Kaktovik. 36 The NSB also provides emergency services, road maintenance, utilities and medical services, finances village schools and a college in Utqiagvik. 37 Employment is one possible ancillary benefit for communities at sites of extraction. However, employment numbers tend to be modest in both cases. ENL asserts that since 2002, almost 300 Russian citizens, mostly from the city of Yuzno-Sakhalinsk have been trained and hired as technicians on Sakhalin. As mentioned above, the company also employs Indigenous people as community liaisons and environmental monitors of the salmon and gray whale populations. In Alaska, with the exception of wildlife monitors, ExxonMobil only employs four Indigenous people from Kaktovik. 38 Central to the diagram designed to implement ExxonMobil's corporate governance commitments are benefit-sharing programs in the form of grant programs in both locations. The programs to channel resources to the communities are similar in principle, but take slightly different forms in the two regions. In Sakhalin, a grant program overseen by a tripartite partnership (comprised of representatives from the company, the Sakhalin regional government, and the Indigenous peoples) has developed over time, suggesting that regional government officials play a more significant role in company-community relations in Russia than in Alaska. In Kaktovik, ExxonMobil helped found the Kaktovik Community Foundation (KSF), run by an Indigenous manager based in Anchorage to play a similar role in channeling funding for community projects. Anyone can contribtue to the KCF, but in practice ExxonMobil has primarily used it to transfer resources to the community.
In Sakhalin, the grant program developed over time as ENL's initial focus on compensation for damages shifted first to an informal funding arrangement between the company and the Association of Indigenous Peoples of Sakhalin Oblast [Region] and finally developed into a tripartite system of consultation between the company, government officials, and Indigenous representatives. ENL employs six Indigenous liaisons (two from Yuzhno-Sakhalinsk and four from nearby villages) to facilitate the grant program and to serve as intermediaries between the company and local community. Since the start of the Sakhalin-1 project, the consortium has contributed over $35 million for more than 1500 social projects (Sakhalin-1). 39 Indigenous representatives participate in the grant awarding committee, which consists of representatives from the government, the company and Indigenous Peoples. Routine participation in grant decisions has facilitated the institutionalization of Indigenous organizations over time, and stimulated growth in the number and capacity of Indigenous NGOs and obshchinas. 40 For example, the NGO Kihk-Kikh, which is formally registered as a non-profit, receives grant funding itself and also serves as an intermediary to channel resources to other small Indigenous culture groups. In Sakhalin the consortium contributed significantly to transportation and social infrastructure during the early stages of the Sakhalin-1 project, including the construction and/ or modernization of roads, bridges, hospital equipment, and an airport in Nogliki, some of which the company needed to support its own operations. 41 The Sakhalin-1 consortium, including ENL, provides charitable support for education, healthcare and culture, 42 with all companies contributing to STEM education (a global priority for ExxonMobil) such as the Eureka project for high school students and annual participation in the All-Russia School Olympic games. 43 As mentioned above, KCF was established by ExxonMobil prior to the start of the Point Thomson project to channel resources to the area. 44 The foundation, which is technically independent but relies on ExxonMobil as its primary funder, for example, used $120,000 from the company to install new storage cellars for the community to preserve traditional foods as warming temperatures and coastal erosion have threatened traditional ice cellars. 45 Currently, the KCF supports local college students by providing approximately six scholarships annually for two-or four-year degree or vocational training programs. 46 Students who receive a STEM education have the opportunity to seek employment at the Point Thomson project. The KCF also plans to construct a new museum and cultural center. 47 Villagers mention several important benefits that the community receives from ExxonMobil, including donated funds for education, a seismic test to identify gravesites on the western edge of the island, and support for the community's Nalukatak celebrations following successful whaling expeditions.
The Point Thomson project also employs a local community liaison who works part-time, assisting with meetings and relaying concerns. 48 According to one municipal leader, representatives from the Point Thomson project work with the community more effectively than other oil companies. However, the same leader also points out that "We always are very meticulous in talking to oil corporations, because they are prone to giving false promises." 49 Despite numerous meetings held between the Native Village of Kaktovik, the incorporated city of Kaktovik, and Alaska Native Corporations to discuss oil development in Kaktovik, a community leader who is generally satisfied with the interaction with ExxonMobil suggests there is a need for even more communication. 50 ExxonMobil often publicizes its commitment to respecting Indigenous cultures. ENL, as a subsidiary, has highlighted its role in revitalizing Indigenous cultures by sponsoring festivals and holidays for Sakhalin communities. The majority of grantfunded projects focus on Indigenous culture and traditions, such as sponsoring Indigenous artists' travel to Moscow and abroad and helping to support native languages. For example, ENL contributed to the Okha Art museum and purchased traditional Indigenous objects and display cases (Sakhalin-1, 2019a). In Kaktovik, the company held discussions with the tribal government (the Native Village of Kaktovik) and the community on projects related to cultural resources, including the digital mapping of an eroding cemetery. 51 In a widely publicized project, Exxon transferred historical Kaktovik artifacts from the Canadian Museum of History to the Museum of the North at the University of Alaska, Fairbanks. 52 The company then organized transportation for community members' to travel to Fairbanks to see these artifacts. 53 Environmental protection is another component of ExxonMobil's diagram. 54 The environmental commitments expressed in various corporate policies are based on international agreements and guidelines as well as local stakeholders' demands. A persistent concern among Indigenous peoples on Sakhalin has been the impact of extraction on salmon migration and spawning grounds. 55 ENL employs Indigenous people in temporary positions at the exploration stage of project development to monitor wildlife populations; in Kaktovik wildlife monitors are employed annually during the whaling season. In response to legal requirements from the U.S. Fish and Wildlife Service and stakeholder requests, ExxonMobil also sponsors significant monitoring of species such as caribou and polar bear, vegetation, and fish populations as well as water levels on Alaska's North Slope. The Point Thomson project conducts biannual meetings to communicate with the local community, where project representatives explain how the operations will develop and answer questions about possible impacts on wildlife. At some of these meetings, the community has also raised broader issues related to benefit sharing.

Discussion: Explaining Similarities and Differences in Patterns of Indigenous Engagement
These case studies demonstrate that ExxonMobil has a repertoire of strategiesa diagram -developed in its node of governance designed to engage Indigenous communities near sites of oil extraction. Athough the headquarters of ExxonMobil is located in Irving, Texas, the concept of a node of governance design centered around a TNC trascends a single geographic location and encompasses corporate units located in Houston, Washington DC, Anchorage and Fairbanks. The repertoire of strategies deveoped in this node include grant programs to community organizations, community liaisons, educational and cultural support, and the employment of Indigenous wildlife monitors. The TNC's programs are similar across distant geographies, both in benefit-sharing and environmental monitoring (see Figure 4). However, despite these commonalities, there are important differences in how ExxonMobil works with Indigenous communities in Russia and the US due to the contexts of the sites of implementation. One difference is simply that Sakhalin-1 is Other variations in the implementation of the company's standardized approach are shaped by national and regional laws, by specific stakeholders, and at times by the policies of other members of the consortia or other TNCs operating in the region. The diagram also changes over time in response to Indigenous resistance. Below we explore sources of similarity, changes over time, and adaptations to local conditions, briefly considering the ownership of land or mineral rights, national laws related to Indigenous peoples, Indigenous self-governance institutions, Indigenous agency and activism, cooperation with environmental NGOs, and finally pressure toward isomorphism with the policies of other TNCs.

Standardizing Extractive Projects: Lowering Transaction Costs and Risks
As a node of global governance design, a TNC adopts commitments from other global nodes and develops a standardized set of policies and programs to engage Indigenous communities. This standardized approach is designed in part to reduce the costs of project development and to minimize risks of community opposition. As a for-profit enterprise, ExxonMobil's commitment to global standards in its corporate policies and programs is an aspect of risk management. For ExxonMobil, a key source of similarity across geographic sites of implementation is the use of a team of specialists to initiate new projects, regardless of their location. The ExxonMobil Development Company employs community relations experts who specialize in the construction stage of project development and who move from country to country over the course of their careers. These experts are charged with upholding corporate standards and ensuring that the company complies with the rules and regulations at the site of implementation 56 and develops best practices to apply to each successive project. 57 A primary objective of this work is to minimize the risk of negative publicity by engaging in benefit-sharing, community outreach, and philanthropy. As one ExxonMobil representative stated, "One of the first things I was taught was that I wasn't joining an oil and gas development company as much as I was joining a risk management company." 58 Still, some global standards are more likely to be upheld than others. For example, ExxonMobil rarely mentions the principle of Free, Prior and Informed Consent (FPIC) it its Citzenship and Sustainabilty reports, even though this principle is endorsed in both UNDRIP and the ILO nodes of global governance. Regarding both Sakhalin-1 and Point Thomson, ExxonMobil has only relied on consultations with communities and community liaisons.
6.2 Land, Minerals, and Self-Governance Differences in the ownership of land and mineral rights and in governance institutions can shape the implementation of the diagram. In Sakhalin, as elsewhere in Russia, all land and mineral resources are owned by the state; therefore, Indigenous peoples' involvement in natural resource management is limited. 59 60 Indigenous enterprises in Sakhalin tend to be small, family-based entities. In contrast, Alaska Native Corporations are powerful for-profit entities that may own significant land and mineral resource rights. Under ANCSA, Alaska Native people were allowed to join Alaska Native Corporations -one at the village level and one at the regional level. Residents born before 1971 received 100 shares that can be inherited or gifted, 61 while Alaska Native Corporations could choose to distribute shares to those born after 1972. 62 For the Point Thomson project, ExxonMobil has a contract for services with the Indigenous-led ASRC in Prudhoe Bay. Almost all Indigenous residents of Kaktovik are ASRC shareholders and therefore receive indirect benefits from ExxonMobil. In 2019, in ASRC the dividend per share was $70, a significant sum, especially for families with children, but in 2021 annual distribution declined to $40 per share. 63 Kaktovik residents also receive shares from the Kaktovik Inupiat Corporation, which has some limited contracts with ExxonMobil. Relative financial support to Indigenous communities on Sakhalin tends to be much lower than on the North Slope. The number and type of Indigenous organizations and institutions that play a role in governing local communities and natural resources or advocating on behalf of Indigenous peoples differ in the two cases. The North Slope of Alaska is characterized by multilayered governance with a high level of self-government and Indigenous leadership. In the Alaskan case, the North Slope Borough is a municipality with an elected leadership that is primarily Indigenous. It has the authority to tax energy company infrastructure in Prudhoe Bay. In addition, multiple federal agencies, such as the Bureau of Land Management and Fish and Wildlife Service, are involved in the governance of natural resources on federal lands and waters. Compared to the North Slope of Alaska, Sakhalin hosts few Indigenous-led institutions involved in the governance of natural resources. In Sakhalin, the regional government is led by ethnic Russians but includes Indigenous peoples who are employed in some municipalities, in addition to Indigenous representatives in the State Duma. Sakhalin's Regional Council of the Authorized Representatives of the Indigenous Minorities of the North, an organization established after the Green Wave campaign consisting of elected Indigenous representatives from different groups, represents Indigenous communities in negotiations and company consultations, but the organization is not involved in resource management. Over time the institutionalization of Indigenous organizations has deepened, in part due to grants from ENL and Sakhalin Energy. In Sakhalin, the availability of funding for Indigenous programs over the past decade has fostered Indigenous enterprises as well as their involvement in resource management. 64 Compared to other parts of Russia, Sakhalin Indigenous peoples' organizations are now well-institutionalized and highly engaged in negotiations with both oil companies and governments, especially around benefit-sharing. 65 6.3 Indigenous Agency: Activism and Allies While ExxonMobil's implementation of corporate policies broadly follows a similar template with some adaptation to local institutions, there has been change over time in the company's approach to benefit-sharing -notably, a shift in programs in Sakhalin in the early 2000s. 66 The development of ExxonMobil's benefit-sharing programs came in response to Indigenous activism and the model of Sakhalin Energy. An Indigenous-environmental grassroots campaign stretched from the sites of implementation to the global level, targeting the European Bank of Reconstruction and Development (EBRD), the investment bank which financed the Sakhalin-2 project, in order to put pressure on Sakhalin Energy, operator of the Sakhalin 2 project. The campaign was successful in that it contributed to a Sakhalin Indigenous Minorities Development Plan. The Plan, evaluted and renewed every five years, is designed to foster greater respect of Indigenous peoples' rights and allow them to participate in some aspects of benefit-sharing. These policy changes, as well as continued local Indigenous mobilization, later shaped ExxonMobil's engagement with Indigenous communities on Sakhalin and, according to interviewees, reverberated in Kaktovik, Alaska, encouraging fuller implementation of ExxonMobil's own governance commitments.
In Sakhalin, in response to Indigenous and environmental activism, ExxonMobil's approach to benefit-sharing shifted from one largely focused on compensation for damages to a more robust grant-based strategy with the involvement of Indigenous people in distributing resources to their communities and in monitoring impacts of the project's operations on the salmon population. In the period from 1999 to 2001, Russia's State Department of Environment and Natural Resources demanded compensation from ENL and the Sakhalin-1 project for damage to reindeer pastures, among other environmental impacts. 67 Instead of formal compensation, the company voluntarily provided funds to reindeer herders in the Nogliki District to purchase supplies and improve local infrastructure. 68 In the following year, to protect the company from the regional government's persistent requests for compensation on behalf of Indigenous peoples, ENL devised an alternative approach. 69 In 2002, ENL and the Association of Indigenous Peoples of Sakhalin Oblast jointly created an advisory committee for a grant program to provide funds to support cultural and social projects for Sakhalin's Indigenous population. 70 At the same time, disruptions linked to extraction led to Indigenous mobilization. The Sakhalin-1 and Sakhalin-2 projects constructed pipelines that crossed more than 1,000 salmon spawning streams, causing concern among Indigenous people about salmon fishing, a traditional economic activity. 71 Activists charged that ENL's contractors violated multiple environmental rules. 72 The Green Wave campaign against oil development on Sakhalin emerged in 2005-2006 simultaneously at the site of implementation, where it was led by Indigenous activists, and through a transnational environmental NGO-led network pressuring the EBRD to review the projects, thereby creating a new forum of negotiation. In January 2005, several hundred Indigenous people from five Sakhalin districts, along with Sakhalin Environment Watch and several other environmental NGOs, demanded an ethnological impact assessment and compensation from the oil and gas consortia.
The campaign for greater consultation and transparency, as well as environmental protection, indirectly served to force a renegotiation of elements of ExxonMobil's diagram. Due to the nature of its financing, Sakhalin Energy, head of the Sakhalin-2 project, was more vulnerable to the Green Wave campaign than ENL. In January 2007, the EBRD canceled a USD $300 million loan for Phase 2 of the Sakhalin-2 project due to violations of both Russian national legislation and global standards. 73 ENL did not rely on international financial institutions as it was financed direclty by ExxonMobil. However, the Green Wave campaign influenced the benefit-sharing practices of both the Sakhalin-1 and Sakhalin-2 consortia. Under pressure from the regional government and the Association of Indigenous Peoples of Sakhalin Oblast, ENL adopted most of Sakhalin Energy's new benefit-sharing strategies following negotiations with the Regional Council of Authorized Representatives of the Indigenous Peoples of Sakhalin Oblast. 74 In response to stakeholders' demands, in 2012 ENL again changed its grant program to more closely match the tripartite arrangement between Indigenous peoples' representatives, the Sakhalin regional government, and the company, created by Sakhalin Energy for the Sakhalin-2 project. 75 This three-way agreement allowed more input for each party when distributing funds to Indigenous populations.
In this case, we see that over time ENL's minimalist approach to voluntary compensation for damages developed into a more multifaceted model of benefit-sharing. Indigenous activism, widespread praise for Sakhalin Energy's approach, and government pressure created incentives for ENL to develop a similar style of collaboration, such as formal procedures for grant applications and a greater role for Indigenous representatives in grant decision-making. Thus, implementation of global standards and corporate policies has evolved not only due to stakeholder resistance at the site of implementation, but in response to other actors in the GGN. This changing model has then gone on to influence benefit-sharing practices at other sites, including Kaktovik, near Point Thomson, in Alaska.
A decade later, similar aspects of this renegotiated diagram have been enacted in the TNC on the North Slope of Alaska, including the creation of the Kaktovik Community Foundation. An interviewee at ExxonMobil's headquarters claimed that lessons learned in Sakhalin were taken into account by the company in developing community relations in Point Thomson. 76 In its corporate documents, Exxon emphasizes the TNC's sensitivity to Indigenous interests: "In the vicinity of our Point Thomson Project in northern Alaska, we work with the local communities and government authorities to understand their concerns and avoid conflicts with their traditional lifestyle. Through a comprehensive assessment and regular engagement, we have identified several areas of concern to the local people, and we have adopted corresponding measures to address these concerns." 77 At the time of our field work, ExxonMobil had not encountered significant community resistance, and interviewees expressed few grievances directly tied to the Point Thomson facility. Company representatives asserted that ExxonMobil cooperates with the NSB as well as the municipality and Indigenous peoples in Kaktovik on issues ranging from wildlife monitoring to cultural preservation. 78 The role of environmental NGOs and their cooperation with Indigenous communities on Sakhalin Island and Alaska's North Slope also differ across the two cases, however. In Sakhalin, environmental NGOs supported Indigenous rights during the Green Wave campaign, alongside a global campaign to preserve Western Pacific grey whales. This Indigenous-environmental alliance in Sakhalin has weakened over time.
With the exception of the 1989 Exxon Valdez oil spill in Alaska's Prince William Sound, 79 ExxonMobil's operations in Alaska have not elicited the level of Indigenous and environmental protests that occurred during the Green Wave movement on Sakhalin. While Kaktovik residents express greater on-going concern about harm to marine mammals and other wildlife, Alaska Natives from the North Slope generally do not cooperate with environmental NGOs, in part due to past NGO campaigns against seal and whale hunting, and tend to have an adversarial relationship with federal wildlife agencies, with some interviewees expressing the sentiment that these are colonizing institutions that negatively intervene in Indigenous stewardship and management of natural resources.

Conclusion
In this study, we examine how a TNC in the extractives sector that operates in multiple geographical settings develops a standard diagram of policies which is then adapted to local contexts. Similarity in TNC policies and programs is a product of global standards, CSR policies, and the TNC's desire to lower transaction costs and minimize risk. Specifically we investigate how ExxonMobil develops its corporate policies, partly in response to global standards, to construct a diagram -or standardized approach -to engaging Indigenous peoples at sites of implementation, in part to avoid reputational damage associated with Indigenous protests. The TNC attempts to replicate its approach to engagement with Indigenous peoples in strikingly different contexts at sites of implementation by using specialized teams who work globally to launch new extractive projects. At the center of this diagram are benefit-sharing programs.
However, this diagram must adapt to pre-existing institutional arrangements at the site of implementation and is subject to renegotiation, leading to variation. Even as TNCs develop relatively universal approaches toward Indigenous communities that can be applied in different socio-economic contexts, local conditions influence practices of benefit-sharing and community engagement at different sites of implementation, including pre-existing Indigenous self-government institutions, varied resource ownership models, and different roles for government agencies. Indigenous movements and associations and the policies of other corporate actors may play important roles in shaping how corporate policies and global standards are implemented at sites of extraction.
Notably, actors such as Indigenous associations and social movements play a crucial role in negotiating, resisting, or adapting to corporate policies. By engaging in resistance, such as protests, Indigenous peoples promote new practices of benefit-sharing. 80 In the case of ENL in Sakhalin, we show how an Indigenous and environmental campaign can prompt the revision of the TNC's diagram, forcing new strategies and programs to implement corporate commitments in communities proximate to extraction -changes to the diagram that were then disseminated to other sites. In Alaska, greater opportunities for Indigenous leadership at the borough, city, and village level may ensure more opportunites for Indigenous voices in governance, beyond Indigenous associations, although this remains an open question.
Thus, even as these case studies illustrate how ExxonMobil has developed a diagram of benefit-sharing with Indigenous communities, we also see that a TNC's efforts to develop universal strategies to manage risk and avoid reputational damage must be continuously adapted in response both to institutional specificities in local sites of extraction and to Indigenous resistance to social and environmental damage resulting from extraction. The company's approach to engaging Indigenous communities is likely to continue to develop and change following efforts to further entrench Indigenous rights and self-governance, both internationally and in specific countries. In this continually evolving context, the respective roles of TNCs and Indigenous communities in negotiating benefit-sharing and environmental protection continues to offer a dynamic and significant issue for further research.