Why do we have a Code of Ethics?
In the fast-changing world of global business, we are constantly faced with new challenges and new opportunities. This can be unsettling, and it’s not always clear how we should behave in certain situations or where the boundaries lie in terms of what is acceptable to our colleagues, customers, and thecommunities in which we work. The Code is designed to support the Schlumberger Values and to help each of us live those Values as we work. It is a practical and clear guide to the behavior that the company expects from every one of its people worldwide. The Code deliberately sets consistent and high standards for us, no matter what our positions are within the company or where we work in the world. Itshould guide and inform our everyday decisions as we work together for the continued success of Schlumberger. Our responsibilities Every one of us in Schlumberger needs to carefully read and understand the Code, and we are all individually responsible for following both it and the Schlumberger policies. We must hold ourselves—and those working alongside us—accountable for following the rules: therules of Schlumberger, the rules of the customers we serve, and the rules of the countries in which we work and live. Being accountable means we each must take a proactive approach to ethical, legal, and compliance concerns by identifying, reporting, and addressing them as necessary. By doing this, we can all play our part in meeting the expectations of our colleagues, customers, and shareholders,as well as many other stakeholders.
Andrew Gould Chairman and CEO Schlumberger Limited
The Code of Ethics does not change the terms and conditions of our employment with Schlumberger. It is a guide for our day-to-day conduct as Schlumberger people.†
See our Schlumberger Values at www.ethics.slb.com.
4 7 8 9 10 11 13 About the Code—Questions and compliance Living ourValues Our actions Our relationships with each other Our relationships within the community Recognizing and avoiding conflicts of interest Our commitment to Quality and to Health, Safety, and protecting the Environment Our accounting and financial reporting obligations Maintaining confidentiality and security of information Software copyright and licensing Competing fairly and ethically Stocktransactions Improper payments Respecting trade controls and immigration laws Maintaining business records We are each accountable Where can you go for more information?
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About the Code—Questions and compliance
What is the Code of Ethics?
The Code of Ethics is a broad outline, designed to guide your decision making and help you handle business situationsprofessionally, fairly, and legally. It is supported by a wide range of company policies, standards, and other documents that set out our obligations and responsibilities to behave ethically in every aspect of our business lives.
To whom does the Code apply?
The Code of Ethics and the Schlumberger policies apply to every employee and manager as well as to every director and officer. Ultimately, each oneof us is personally responsible for making sure that we comply with the laws and regulations that apply to our business, as well as our Schlumberger requirements. If you are in a leadership position, you must communicate and implement the Code of Ethics and the associated Schlumberger policies, making sure that your teams comply. Where appropriate, contractors and agents of the company shouldalso follow the Code of Ethics and Schlumberger policies.
Walk the walk
Managers must set the tone for their organization. In short, they must not only talk the talk but walk it.
Are there waivers and exceptions to the Code?
Any waiver of or exception to the Code for executive officers or directors must be approved by the Board of Directors of Schlumberger Limited or one of its...