COBC - Code of Business Conduct - Halliburton

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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” 40
Maggie, a Halliburton employee in a Middle Eastern country, is responding to a tender for a significant and high-profile project for the government of that country. One of the tender’s requirements is that Halliburton must make a sizable contribution to the country’s Education Ministry, which will use the funds to improve education facilities and opportunities for young girls. What should Maggie do? Is it permissible to make such a contribution in order to help secure a large project? Halliburton believes in supporting educational institutions and charities outside of the U.S. and has implemented policies that formalize the process for making education-related contributions. The facts surrounding this scenario present a number of red flags; however, so Maggie must proceed with caution. Primarily because the contribution request involves a government ministry, it must be carefully scrutinized to prevent a possible violation of the U.S. Foreign Corrupt Practices Act or similar anti-corruption law. Before making or authorizing any charitable contribution, particularly one that is required in a project tender, Maggie should consult the Anti-Corruption & International Compliance (ACIC) Practice Group within the Law Department. 41
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 and 38: Take Note! Bribes can take many for
Page 39 and 40: Money Laundering Money laundering i
Page 41: Receiving Gifts, Entertainment or H
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

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