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