COBC - Code of Business Conduct - Halliburton

Conducting Business with the U.S. Government
Halliburton does not generally work as a contractor
providing goods and/or services to the U.S.
government, agencies thereof or for parties using
federal funds. U.S. federal law has strict rules and
regulations that apply to companies attempting to
qualify for, bid for, or perform U.S. Governmentfunded
work. These regulations and requirements
differ from our normal business operations and
impose certain obligations on the Company.
Violations of these rules and regulations can impose
heavy penalties and sanctions on the Company.
Accordingly, no bid should be made by any
Halliburton entity for any U.S. Government-funded
work unless and until the bid request has
been reviewed by the Law Department and
approved by the Senior Vice President and
Chief Commercial Lawyer.
Halliburton complies with applicable U.S. federal
statutes and regulations governing the employment
of former U.S. military, Department of Defense, or
other federal employees. Supervisors contemplating
hiring a former U.S. governmental employee or
engaging the employee as a consultant should consult
with the Law Department for guidance before hiring
the individual.
U.S. Federal Sentencing Guidelines
Halliburton’s Code of Business Conduct represents
an effective compliance program as required under
the Federal Sentencing Guidelines, which are a
product of the United States Sentencing Commission,
created by the Sentencing Reform Act of 1984. The
Code is designed to detect an offense before discovery
outside of the Company, or before the discovery
is reasonably likely, and to provide reasonable
assurances that no individual with operational
responsibility for the Company’s compliance
program will participate in, condone or willfully
ignore criminal conduct in the Company.
The Company has taken reasonable steps to remedy
the harm that may result from any criminal conduct,
including as appropriate, paying restitution,
self-reporting the conduct to government authorities
and cooperating with those authorities in any
ensuing investigation.
If it is determined that criminal conduct has
occurred, Halliburton will assess its compliance
program and make appropriate modifications to
prevent such conduct from recurring, including
consultation with outside professional advisors as
to what modifications should be made and how to
comply with such modifications.
Our Chief Ethics & Compliance Officer (CECO) has
a direct reporting relationship to the Halliburton
Board of Directors as well as the Executive Vice
President and General Counsel. At the direction
of the Board, the CECO has express authority
to communicate personally with the Audit,
Compensation, and Nominating and Corporate
Governance committees promptly on any matter
involving criminal conduct, or potential criminal
conduct, and no less than annually on the
implementation and effectiveness of Halliburton’s
compliance program.
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