COBC - Code of Business Conduct - Halliburton

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Reporting and Investigation Our Commitment to Non-Retaliation We will not tolerate any type of retaliation against an employee for making a report or participating in an investigation in good faith. Such actions may also be protected in accordance with the Sarbanes-Oxley Act of 2002 and the Dodd-Frank Wall Street Reform Act and Consumer Protection Act. Acting in “good faith” means that you reasonably believe a violation has occurred (or will occur), that you disclose all of the information you have, and that you believe you are giving a complete and accurate report. Anyone who retaliates against a good-faith reporter will be subject to disciplinary action, up to and including termination of employment. You should never file reports that are knowingly false or made in bad faith. A bad-faith report can result in disciplinary action, up to and including termination. Investigations and Confidentiality We will respond to all reports as promptly as possible. We will treat reported information in a confidential manner to the fullest extent practical while still enabling a thorough investigation. The appropriate individuals within the Company will be assigned to promptly investigate all reports. In certain circumstances outside investigators and legal counsel may also be involved. As an employee you are expected to cooperate fully with all internal and external investigations or audits. This includes responding to investigations truthfully and disclosing all relevant information that you have. Consequences of Violating the Code At Halliburton, Ethical Behavior is a core value and we take Code violations very seriously. Failure to follow the Code could result in disciplinary action, up to and including termination of employment and legal action in some cases. Take Note! Retaliation is defined as any adverse action taken against an employee because he or she exercised his or her protected rights. A few examples are: • Creating an uncomfortable or hostile work environment • Decreasing or marginalizing responsibilities or reporting relationships • Transferring an employee • Denying or excluding the employee from training and development opportunities 10
What can I expect after I make a report in good faith? After making a report to any Halliburton Ethics & Compliance resource, you can expect the following: • Your report will be taken seriously. • Your report will be investigated promptly and thoroughly. • Your report and your identity will be treated confidentially to the extent practical or to the extent permissible by law. • Your report will be escalated appropriately, including to the Halliburton Board of Directors. • If you have disclosed your identity, you will receive follow-up communications regarding the receipt and final closure of your report. • You will not be subject to any retaliation as a result of your good-faith report. I believe that I may have witnessed a violation of the Code, but I am not sure. What should I do? If you reasonably suspect a violation of the Code, you must report it. The earlier the issue is reported, the sooner it can be resolved. Even if you don’t have all the facts, you should discuss what you know of the suspected violation with your supervisor, report the issue to the Ethics & Compliance Practice Group in the Law Department, or call the Ethics Helpline. By doing so, you will have fulfilled your obligation under the Code and will help ensure that we can carefully review the issue to determine if a violation has occurred. Company policy prohibits retaliation against anyone who reports a concern in good faith. Acting in “good faith” means that you reasonably believe a violation has occurred (or will occur), that you disclose all of the information you have, and that you believe you are giving a complete and accurate report. 11
Page 1: Code of Business Conduct
Page 5 and 6: Table of Contents Purpose..........
Page 7 and 8: The Purpose of the Code of Business
Page 9 and 10: Take Note! Before determining a cou
Page 11: Reporting and Investigation Asking
Page 15 and 16: Relationship with the Company The H
Page 17 and 18: We Encourage an Inclusive Workplace
Page 19 and 20: A co-worker I have known for many y
Page 21 and 22: I was injured while working in the
Page 23 and 24: Family and Personal Relationships H
Page 25 and 26: Financial Integrity, Reporting and
Page 27 and 28: Records Management In the course of
Page 29 and 30: Pradipa is preparing a proposal for
Page 31 and 32: Hashim plans to be away on vacation
Page 33 and 34: Stephanie, a Halliburton employee,
Page 35 and 36: Relationship with Others At Hallibu
Page 37 and 38: Take Note! Bribes can take many for
Page 39 and 40: Money Laundering Money laundering i
Page 41 and 42: Receiving Gifts, Entertainment or H
Page 43 and 44: Maggie, a Halliburton employee in a
Page 45 and 46: Gathering Competitive Information U
Page 47 and 48: Customs and Import Compliance We wi
Page 49 and 50: Personal Use of Social Media Always
Page 51 and 52: Conducting Business with the U.S. G
Page 53: Conclusion We are all responsible f
Page 56: H010043 05/13 Produced by Halliburt

COBC - Code of Business Conduct - Halliburton

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