COBC - Code of Business Conduct - Halliburton

Stephanie, a Halliburton employee, was in a quarterly performance review with an operator
discussing recent shale gas development work. During the quarterly review, safety and
operational performance results were presented. New technology applications, advances,
suggestions and value drivers were also to be presented. Gene, the Vice President of
Drilling for the International Oil Company, stated openly, “We use these quarterly reviews
to learn what else is going on in the field and surrounding areas, so please provide me with
the results from your well construction performance using your new technology; everyone
knows you’re using it with operator XYZ.” Stephanie has these results and examples that do
illustrate Halliburton’s performance on a thumb drive. Is it appropriate for her to share this
information with the customer?
During sales and customer meetings, it is often important that we convey examples and statistics
that accurately depict Halliburton’s successful performance to demonstrate why we are the best
company for a particular project. However, we have an obligation to protect the confidential and
proprietary information that we gather about other customers and partners. It is inappropriate to
share such information with others, as our customers and partners expect that we will handle their
confidential information with the utmost discretion and privacy. Before sharing the information
on her thumb drive, Stephanie should ensure that all confidential data is removed so that no
information that we are bound to protect is shared with other customers.
Take Note!
We are all responsible for safeguarding the confidential information of our customers and vendors.
This includes proprietary information belonging to our customers and vendors, and any personal
information about individuals and proprietary company information belonging to partners or
other third parties.
• You should only access confidential
information if you have a legitimate
business reason for doing so.
• You may provide confidential information
to another Halliburton employee only if
that employee has a need to know it in
order to fulfill job responsibilities.
• If you are unsure about whether to
disclose confidential information, ask your
supervisor, Human Resources or the
Ethics & Compliance Practice Group in the
Law Department for guidance.
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