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COBC - Code of Business Conduct - Halliburton

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Anti-Bribery and Anti-Corruption<br />

Prohibition <strong>of</strong> Bribery<br />

Bribes are illegal in virtually every country. Because<br />

<strong>Halliburton</strong> conducts business around the world, we<br />

are subject to numerous laws that prohibit receiving,<br />

<strong>of</strong>fering, providing or authorizing the payment <strong>of</strong><br />

bribes <strong>of</strong> any kind to anyone. These include the U.S.<br />

Foreign Corrupt Practices Act (FCPA) and the U.K.<br />

Bribery Act 2010 (U.K. Bribery Act), which apply to<br />

our operations around the world.<br />

At <strong>Halliburton</strong>, we do not bribe or use any other<br />

means to improperly influence the decisions <strong>of</strong><br />

others, including customers, potential customers or<br />

government <strong>of</strong>ficials. No <strong>Halliburton</strong> employee may<br />

authorize, provide or <strong>of</strong>fer anything <strong>of</strong> value (or do<br />

so through a third party) to a government <strong>of</strong>ficial,<br />

company or individual for the purpose <strong>of</strong> obtaining<br />

or retaining business, gaining influence, or seeking<br />

any other advantage for the Company. It is also illegal<br />

for <strong>Halliburton</strong> employees to accept bribes or<br />

request anything <strong>of</strong> value from suppliers or other<br />

third parties.<br />

No employee will ever be disciplined for refusing<br />

to pay a bribe, regardless <strong>of</strong> its impact on sales,<br />

pr<strong>of</strong>itability, project completion or other aspects<br />

<strong>of</strong> our business. The ultimate cost and long-term<br />

detrimental effects <strong>of</strong> bribery and corruption far<br />

outweigh any short-term benefits.<br />

Failure to comply with any anti-bribery laws will<br />

result in disciplinary action, up to and including<br />

termination <strong>of</strong> employment. Additionally, violations<br />

<strong>of</strong> anti-bribery laws, including both the FCPA and<br />

the U.K. Bribery Act, may result in criminal and<br />

civil penalties for both the Company and individual<br />

employees. These penalties can include significant<br />

fines and jail terms for those involved.<br />

Take Note!<br />

A “foreign government employee” means<br />

an individual who is a non-U.S. government<br />

employee, including any <strong>of</strong>ficer or employee<br />

<strong>of</strong> a foreign government unit or national oil<br />

company.<br />

Regulators consider government employees,<br />

candidates for political <strong>of</strong>fice, party <strong>of</strong>ficials,<br />

members <strong>of</strong> the royal family, and even all<br />

employees <strong>of</strong> government-owned businesses<br />

(such as national oil companies) to be<br />

“government <strong>of</strong>ficials.” Also included are<br />

<strong>of</strong>ficials and employees <strong>of</strong> public international<br />

organizations such as the World Bank.<br />

In addition, gifts or bribes to a family member<br />

<strong>of</strong> a government <strong>of</strong>ficial can be considered to be<br />

bribes to foreign <strong>of</strong>ficials.<br />

Be aware that the bribery <strong>of</strong> foreign government<br />

employees and the bribery <strong>of</strong> commercial<br />

personnel are both prohibited by this <strong>Code</strong>.<br />

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