COBC - Code of Business Conduct - Halliburton

International Trade
As a company operating globally, we frequently move products, supplies, equipment and software
between countries. We must comply with the laws of those countries with respect to the import and
export of those items.
Export and Compliance
We will comply with the laws of each country from which we export our goods, software and technical data;
no business will be transacted nor item exported that is not in compliance with the following:
• The United States Export Administration Act
(EAA)
• The Arms Export Control Act (AECA)
• Regulations to implement international
economic sanctions programs involving
particular countries, including
regulations promulgated by the Office
of Foreign Assets Control of the United
States Department of the Treasury
• The Export Administration Regulations (EAR)
• The International Traffic in Arms Regulations
(ITAR)
• The export laws and regulations of any other
country that apply to a particular shipment
• The terms and conditions of any export license
issued to the Company or any of its subsidiaries
There are no exceptions to this policy and it applies to all employees, officers, directors and any third parties
acting on our behalf.
We have a system of internal controls, many of which are automated in SAP. All employees must comply with
these internal control systems.
Take Note!
While we typically think of exports as being physical items shipped from one country to
another, the terms actually cover a much broader spectrum, including goods, services,
technology, software or data; and items, or even information, that is shipped, flown, uploaded or
downloaded, emailed or faxed.
Export rules become more complicated when it comes to intangible exports. While goods must
be physically shipped to another country to be considered exports, technology and software
can be “exported” by giving a foreign national access to them in this country, or by posting the
information on a website that may be viewed in other countries.
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