COBC - Code of Business Conduct - Halliburton

Giving Gifts, Entertainment or Hospitality to Foreign Officials
Because of strict anti-bribery laws in the U.S. and
abroad, there are special considerations when
exchanging gifts, entertainment or hospitality with
foreign government officials. Where giving nominal
gifts is consistent with customary business practices,
and they are not offered to influence or reward a
particular business decision or action, you may give
gifts to foreign officials that are under USD250 in
value. You may also offer gifts with Halliburton logos
on them.
Gifts exceeding USD250 in value require approval
from the Ethics & Compliance Practice Group
in the Law Department. Similarly, all hospitality
or entertainment, regardless of value, requires
approval from the Anti-Corruption & International
Compliance (ACIC) Practice Group before being
offered to foreign officials.
Several Petroland Oil Company (a national oil company) employees approached a local
Halliburton Business Development team to jointly form golf teams to participate in a local golf
tournament. They suggested that Halliburton sponsor two teams, each consisting of two players
from Petroland Oil Company and two players from Halliburton. Can the Halliburton employees
play in the tournament?
Maybe. However, before agreeing to play in the golf tournament, the employees must contact the
Anti-Corruption & International Compliance (ACIC) Practice Group to seek approval. This is a
sensitive situation because, as national oil company employees, the Petroland employees may be
considered government officials under some anti-bribery laws. Paying for them to participate in a
golf tournament could be considered bribery under certain circumstances; therefore, the situation
needs to be carefully evaluated before proceeding. Halliburton’s policy is that any gifts for foreign
government officials valued at more than USD250 and all entertainment of foreign government
officials require Law Department approval.
References
Company Policy 3-15540, “Gifts and Entertainment
Provided by Suppliers and Supplier Sponsorship of
Company Events”
Company Business Practice 4-10986, “Company
Contributions to Meet Social Commitments”
Company Business Practice 4-11056, “Gifts, Travel,
Lodging, and Entertainment for Foreign Government
Employees (including Employees of National Oil
Companies) and their Families”
Company Business Practice 4-11059, “Travel and
Entertainment Expense Reporting”
Company Business Practice 4-11156, “Procurement
Processes Manual”
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