Code of Business Conduct - Halliburton - Halliburton

1 code of Business ConductDear Colleagues, For nearly a century, Halliburton employees have worked tirelessly to deliver outstanding products, services and solutions to our customers. This hard work has yielded consistent, long-term success. We continue to gain new customers and to also expand relationships with existing customers. We are developing some of the industry s most advanced technological solutions. In all corners of the world and in every corner of the Company, we have repeatedly and resoundingly prevailed over our competition. I appreciate and applaud those efforts, and I am proud of our deepest pride, however, comes from the way we achieve our goals. We succeed with uncompromising integrity.

2 When we face difficult decisions during the course of our work, we choose the ethical course of action. Honesty, fairness and respect are not sacrificed in pursuit of Halliburton Board of Directors and the senior management team are committed to our Company s core values, and we expect that same commitment from every employee. Ethical behavior; technology innovation; health, safety and environmental leadership; service quality these values have defined Halliburton since the founding of the Company. If we realize our vision of being the preferred upstream service company for the development of global oil and gas assets, we must remain faithful to these essential ensure that we all understand the requirements set forth in the code of Business Conduct and can commit to it with complete confidence, we have updated its look and language.

3 It clearly outlines the guiding principles that can help us make the right decisions when confronted with challenging circumstances. Please read it carefully and refer back to it as needed. We are all accountable for upholding and abiding by the code of Business Conduct . It applies equally to all employees, directors and officers of the Company, and to all third parties that Conduct Business on behalf of Halliburton . If you see or suspect that unethical behavior has occurred, you are obligated to come forward with your concerns. Contact your supervisor. Call the Ethics Helpline. Above all, do not abandon your responsibility because of fear. We will not tolerate retaliation against anyone who raises issues in good is the best global team in the industry.

4 Take pride in the accomplishments and the stature of our Company. In every decision you face, make integrity your highest priority, and demand the same from those around you. Thank you for doing what it takes to maintain the Halliburton legacy of success a nd i nteg r it from the Chairman of the Board and CEOD avid LesarChairman of the Board and Chief Executive Officer12 Table of ContentsRelationship with the CompanyIntroduction ..6 Purpose ..5 Reporting and Investigation ..9 Relationship with OthersConclusion ..51 Compliance and Ethics Resources at Halliburton ..53Wa ivers ..53 Anti-Bribery and Anti-Corruption ..34 Gifts, Entertainment and Hospitality ..38 Fair Competition.

5 42 International Trade ..44 Communications with the Public, Investors and the Media ..46 Civic and Charitable Activities ..48 Political Activities and Lobbying ..48 Conducting Business with the Government .. Federal Sentencing Guidelines ..49 Employment and the Workplace ..14 Health, Safety and Environment (HSE) ..18 Conflicts of Interest ..20 Use and Public Disclosure of Material Nonpublic Information ..22 Financial Integrity, Reporting and Disclosure ..23 Protection of Company Assets ..26 Privacy and Data Security ..303 The code of Business Conduct is the ultimate resource document. It communicates to the world our culture, our values and our rules. Without standards in place, ethical Conduct becomes a vague concept.

6 The code provides a baseline standard for all employees, officers, contractors and suppliers, so that everyone who is connected with Halliburton knows what is Thurman Director code of Business Conduct4 Our Commitment to Honest, Fair DealingThe Halliburton Board of Directors has adopted this code to ensure honest and ethical Conduct ; compliance with applicable laws and regulations; and fairness with customers, suppliers, competitors and employees. We value good citizenship and do not take advantage of others through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair practices. The code applies wherever we do Business , equally to all Halliburton directors and employees, including officers, as well as employees of Halliburton s subsidiaries and affiliates.

7 We also expect all suppliers, contract employees, agents, consultants and others acting on our behalf to abide by the principles in the with the LawIt is our policy that all of our directors, employees and anyone acting on our behalf comply with all applicable laws in each place where we do Business . We are a company and, in some situations, the applicable law of the may conflict with the applicable law of another country. In such cases we will follow the guidance of the Ethics & Compliance Practice Group in the Law Department to resolve the conflict. The Purpose of the code of Business ConductAt Halliburton we are committed to conducting Business with the highest levels of integrity, in full compliance with both the letter and spirit of the law.

8 As part of this commitment, we must do the right thing and make the right choices as we undertake our daily activities. This includes helping to foster an environment where we treat each other respectfully, deliver world-class service to our clients, compete honestly, and take pride in our is not always easy to identify the right course of action. In situations where additional direction is required, this code of Business Conduct (the code ) serves as a practical guide to help you make the right legal and ethical choices. Together with the policies and Business practices referenced here, the code is the foundation of Halliburton s core value of Ethical Behavior and our global ethics and compliance code highlights the important legal, ethical and regulatory requirements that govern Halliburton s global operations.

9 It also provides resources for additional information and guidance on how to report potential violations. You must read, understand and abide by the code . We expect your wholehearted support of the values and principles it the CodeThe code provides a framework to help guide your behavior. It does not address every situation you may encounter but is meant to supplement your own good judgment, common sense and knowledge of what s right. As such, any Conduct that is unethical or illegal could subject you to appropriate discipline, even if it is not specifically mentioned in the should reference the code whenever you have a question or concern about compliance-related issues or what constitutes ethical and lawful Conduct .

10 Note that each section of the code also contains references to Halliburton policies and Business practices that provide additional detail on specific you ever have any questions about the code or about how to handle a specific situation, you should speak with your supervisor, contact one of the available Ethics & Compliance resources, or read the Halliburton policy or Business practice that relates to the subject of your question. The Chief Ethics & Compliance Officer (CECO) and the entire Ethics & Compliance Practice Group in the Law Department are always available to answer your questions or discuss any potential code violations that you would like to bring to their attention.