COBC - Code of Business Conduct - Halliburton

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International Business Relationships Halliburton frequently enters into business relationships with individuals and companies outside the U.S. The risk to the Company from each type of International Business Relationship is different and therefore the appropriate amount of due diligence and the necessary prior management approvals required before the Company enters into an agreement are different for each type of relationship. The Company has different policies that specify the requirements for each. The Anti-Corruption & International Compliance (ACIC) Practice Group in the Law Department makes the final determination on the true nature of the proposed relationship and which policies apply. Anti-bribery laws prohibit companies from making corrupt payments. When a payment is made by a third party on behalf of a company, it is treated as if the company made the payment itself. Companies can be held responsible not only when they knew that such activity was occurring, but also under circumstances when they should have known that such payments would be made. What is an International Business Relationship? The term International Business Relationship includes any entities or individuals that represent our interest or interact with government officials on our behalf, including joint ventures, alliances, agreements with international commercial agents, sales agents, international noncommercial agents (such as customs brokers, freight forwarders or immigration and visa agents), software resellers, consigned stock agents and distributors. No payment of anything of value may be made by any employee, director, agent, consultant or any third party acting for, or on behalf of, the Company to a government official (including any employee of a national oil company) for the purpose of obtaining or retaining business or for gaining any business advantage. If a local government official recommends or suggests entering into a business relationship with an agent, vendor, subcontractor or joint venture partner, the Company will ensure that due diligence is performed before that individual or entity can be retained. We do not seek such recommendations from any local government officials. Employees who work with International Business Relationships are responsible for ensuring that our business partners act legally and ethically on behalf of the Company at all times. If you suspect that a third party agent is violating anti-bribery law, contact the ACIC Practice Group immediately. 36
Money Laundering Money laundering is the process by which illegally obtained funds are transferred through the financial system in an attempt to conceal their criminal origin. We are committed to complying with all applicable anti-money laundering laws, rules and regulations. We must only conduct business with reputable third parties who engage in legitimate business activities. You must avoid any transactions that are structured in a way that could be viewed as concealing illegal conduct or illegally obtained funds and should contact the Ethics & Compliance Practice Group in the Law Department if you have any concerns. References Company Policy 3-15400, “Facilitating Payments” Company Policy 3-15700, “International Non-Commercial Agents that Represent the Company Before a Non-U.S. Government Agency or National Oil Company (Including any Referred to as Consultants)” Company Policy 3-15800, “Joint Ventures, Sponsors, Software Resellers, Alliances, Joint Cooperation Agreements, and Similar Forms of International Business Relationships” Company Policy 3-31112, “International Commercial Agents” Company Policy 3-31113, “International Distributors” Company Business Practice 4-11056, “Gifts, Travel, Lodging, and Entertainment for Foreign Government Employees (including Employees of National Oil Companies) and their Families” 37
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 and 12: Reporting and Investigation Asking
Page 13 and 14: What can I expect after I make a re
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: Take Note! Bribes can take many for
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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