The SLB

Code of Conduct
The Code of Conduct applies to everyone at SLB and,
together with other SLB requirements, should help answer
most business ethics questions. If you are still not sure what
to do, ask for help.

All employees should speak openly and ask questions about

the Code of Conduct or any other SLB requirements without
fear of retaliation.
Contents
4 Our Purpose 6 My Actions 18 Our Company
and Values Reflect on is the Sum
the Company of Our Actions
10 Commitment to Health, Safety and 20 Fair and Open Business Practices 31 Information Technology Enables
Protection of the Environment is the Represent Who We Are Superior Results
Platform for Our Success
22 Competing Fairly and Ethically 33 Maintaining Confidentiality
13 Commitment to Quality Delivers Builds Trust and Information Security Protects
Excellence Our Future
24 Our Relationships with Others
14 Avoiding Conflict of Interest Shows Demonstrates Respect 34 Protecting Our Intellectual Property
Commitment Promotes Technological Innovation
25 Our Community Relationships Build
15 Transparent Stock Transactions on Our Mindset 34 Respecting Copyrights, Software
Support Integrity Licenses and Trademarks Benefits
26 Respecting Immigration Laws Enables us all
16 Good Judgement about Business Our Global Footprint
Entertainment Builds Positive 37 Managing Business Records
Relationships 27 Trade Control Compliance Ensures Transparency
Safeguards Our Business
38 Rigorous Accounting and
28 Data Privacy and Protection Preserves Financial Reporting Standards
Information Security Instill Confidence

30 Representing SLB is a Privilege

3
Our Purpose and Values

Our Purpose Our Values

Together, we create amazing technology that As SLB employees, we pride ourselves on
unlocks access to energy for the benefit of all. upholding our three values, which will guide the
decisions we make as we pursue our ambitions:
A Balanced Planet demands. We’re working on that answer.
Every day, a step closer. Our collective
At SLB we create amazing technology future depends on decarbonizing the fossil
that unlocks access to energy for the fuel industry while innovating across the
benefit of all. As innovators, that’s been
our mission for 100 years. We are facing
entire energy landscape. It’s what drives We value We value We value
us. Ensuring progress for people and the
the world’s greatest balancing act – how planet, on the journey to net zero and People Technology Performance
to simultaneously reduce emissions beyond.
while meeting the world’s growing energy Because our exceptional Because our passion for Because together we
and diverse people exploring enables us to deliver extraordinary
are the pulse and spirit solve the worlds energy results to build a
of who we are. challenges. sustainable future.

Our Behaviors Our Behaviors Our Behaviors

We are safe We are pioneers We act with integrity

We are inclusive We innovate together We deliver today

and tomorrow
We respect work We experiment,
& personal life learn and grow We focus on what
matters most

4 5
 My Actions
Reflect on
the Company

6 7
My Actions Reflect on the Company
In Brief If you are in a leadership position, you must Reporting a Concern or Violation transparent way. Similarly, SLB employees,
demonstrate integrity by living the Code of officers and directors may not purchase
• I take it upon myself to know and obey Conduct, and by communicating it to your If you know of or suspect a violation of the stock in companies that are customers of
the laws where the company operates. team members to ensure that they do, too. Code of Conduct or applicable laws, you SLB, other than as part of a mutual fund.
must report it internally.
• I do not engage in actions unless I am Dealing with Suppliers
Commitment to Accountability
sure they are ethical and legal. Your first point of contact should be your
If we intentionally or unintentionally direct or functional manager. If this is not SLB maintains zero tolerance for corruption
• I ask questions and raise concerns when practical, you may contact a managerin of any kind, and we expect the same from
violate the rules, we could be subject to
issues arise and I report internally any Personnel, Legal, Finance or another our contractors, suppliers, and agents. They
disciplinary action. We could also face
actual or potential violation, without fear relevant function, or contact the SLB are required to comply with the laws of the
personal financial or criminal liability if we
of retaliation. Director of Governance and Integrity. In countries in which they operate, and to act
violate applicable laws. SLB has adopted
• I am committed to our customers, treating progressive accountability guidelines as a addition, you can raise your concern by in a socially responsible and ethical manner,
them in a consistent and transparent fair and consistent system for assessing the using the QUEST Event Report feature orthe consistent with the Code of Conduct. All
way, and avoiding purchase of customer actions of individuals who violate the rules. EthicsLine, which provides two methods of suppliers, contractors, and agents must be
stock, except through mutual funds. reporting, via telephone (888-884-8849) approved and managed in accordance with
Any waiver or exception to the rules of or online (www.slbethics.ethicspoint.com). internal requirements.
the Code of Conduct must be approved For calls outside North America, it may be
Demonstrating Integrity according to SLB requirements. If no necessary to first dial a country access Finally, we have always supported
standard applies, the SLB Director of number that can also be found at the above responsible sourcing of materials from
Acting ethically involves more than simply Governance and Integrity must approve suppliers that share our values, and we
link. Any employee who fails to report or
ensuring compliance with laws and the waiver or exception. The board of commit to avoid using conflict minerals in
provide further information abouta violation
regulations. It involves recognition that directors of SLB must approve any waiver our sourcing activities.
will be subject to disciplinary action.
our decisions affect others. By keeping or exception for executive officers or
this in mind, we earn the respect, trust and No Retaliation Dealing with International Differences
directors.
confidence of our customers, colleagues, SLB employees deliver high- quality
shareholders and others affected by our SLB prohibits retaliation for good faith
reporting of a potential or actual violation technology and services worldwide, and
operations. we are subject to the laws and customs of
of the Code of Conduct, our internal
By doing things right the first time, every requirements or applicable laws. However, different countries. Sometimes these laws
time, we enhance our reputation for any employee who intentionally reports vary from place to place and could even
integrity with these stakeholders. false information will be subject to conflict.
disciplinary action. We are responsible for knowing and
Individually, we are all responsible for
adhering to the Code of Conduct and to the Commitment to Customers following the laws and regulations that
internal requirements governing our work. apply where we work. When local laws
SLB is committed to delivering excellence or common practices are not as strict,
to our customers in everything we do. We the Code of Conduct and other SLB
treat all our customers in a consistent and requirements still apply.

8 9
Commitment to Health, Safety Q A
and Protection of the Environment What are my options if I feel my You may stop any job immediately
is the Platform for Our Success working conditions are unsafe? if you feel conditions are unsafe.
You should also immediately report
any unsafe conduct to a supervisor.
In Brief drugs or controlled substances or while in
possession of these substances illegally or
• I do not perform a job without proper without authorization.
training and personal protective
equipment or while impaired by alcohol, We must be proactive about our safety
drugs or controlled substances. and that of our team members. Wear all
personal protective equipment required
• I stop any job at any time if I believe by the job at hand. Do not perform a job
conditions are unsafe. without proper training. Stop any job at
• I always wear seat belts and I do not use any time if conditions are unsafe and
mobile phones or electronic devices immediately report any unsafe conduct to a
while driving. supervisor.

• I minimize our environmental impact Driving is the riskiest activity at SLB. All
by preventing pollution and minimizing employees whose jobs involve driving must
waste. comply with journey management and
specific safe-driving requirements. SLB
mandates that all vehicle occupants wear
An Unwavering Commitment to HSE seatbelts. Driving under the influence of
drugs or alcohol is not permitted. Use of
Our company is determined to safeguard mobile phones or electronic devices while
people’s health and security, operate the driving is not permitted—even if the device
business safely and protect the environment. is hands-free. The driver must bring the
vehicle to a complete stop before using any
Working Safely
such device.
A safe and productive work environment
is one that is free from the harmful effects Protecting the Environment
of alcohol, controlled substances and SLB is committed to minimizing its
legal or illegal drugs. We are prohibited impact on the environment. We do this by
from entering SLB facilities, conducting preventing pollution, reducing emissions,
company business and driving or operating consuming fewer natural resources and
equipment while impaired by alcohol, minimizing waste.

10 11
 Commitment to Quality
Delivers Excellence

In Brief The long-term business success of SLB

depends on continuous improvement in
• I aim to do the right thing the first time, the quality of our products and the delivery
every time. of services to our customers. Quality
• I strive to exceed customer expectations. means that every employee commits to
doing the job right the first time, every
• I respond to customer requests in a timely time. We demonstrate our commitment
and appropriate manner. to quality by meeting or exceeding
customer expectations and by avoiding
• I pursue every opportunity for continuous
nonconformities in our daily activities.
improvement.
To help make continuous quality
improvements, we should participate in
any audits and periodic assessments the
company requires. We can also help to
improve quality by addressing customer
feedback in a timely and appropriate
manner.

12 13
Avoiding Conflict of Interest Transparent Stock Transactions
Shows Commitment Support Integrity
In Brief For example: In Brief In the course of our work, we may have
access to non-public or insider information
• I do not hold financial stakes in • If a family member works in an • I ensure that all non-public information that relates to SLB or its financial
companies that do business with SLB. organization that competes with SLB to which I have access through my work position. Examples include knowledge
remains confidential. of unannounced marketing plans, new
• I put SLB business interests first, and • If we have an active interest in an
do not accept any improper personal organization that does business with SLB, • I do not buy or sell stocks or securities of product releases, financial results, changes
benefit as a result of my position. including customers or suppliers SLB or other companies based on non- in dividends or earnings, planned mergers
public or insider knowledge. or acquisitions, and business strategies.
• I do not use company resources, funds • If an employee serves as a director,
or equipment for personal gain. officer, agent or consultant of a company • I do not provide insider information If we have such information, we must keep
that competes with SLB to others, either inside or outside the it confidential and we may not buy or sell
•  I disclose all potential conflicts of interest SLB Limited stock or publicly traded
company, for them to buy or sell stock
to my manager. • If the company grants a personal loan options of SLB stock until the information
or securities.
to an employee becomes public.
• I avoid even the appearance of using
A conflict of interest is a conflict between Employees must put SLB business interests insider information improperly. It can also be illegal to provide non- public
our personal interests and the interests of first, disclose all conflicts and avoid information to someone else for them to buy
SLB or a customer. A conflict may arise if situations that create the appearance or sell stock or other securities, even if we
we have personal, social, financial, political of a conflict of interest. Advance written ourselves do not gain financially.
or other interests that could interfere with approval is required before an employee
our responsibilities as SLB employees. can continue working while a conflict of This prohibition also applies to buying
interest exists. and selling the stock or options of other
companies with which SLB does business.

Q A
My wife works for a SLB supplier. No. A relationship conflict of
Can I recommend her company’s interest such as this must be
bid over two others we are disclosed to your supervisor and
considering? you must recuse yourself from the
decision-making process.

14 15
Good Judgement about Business
Entertainment Builds Positive
Relationships
In Brief Accepting or giving business gifts or
hospitality must never suggest an ability
• I do not offer or accept any business gift to influence business decisions. Gifts are
or hospitality of more than nominal value items or benefits for which the recipient
(200 USD or any lower limit specified does not pay fair market value. Hospitality
locally). includes meals, entertainment and sporting
• I use good judgment when giving or events.
receiving business gifts or hospitality
and never use them with the intention We must not offer or accept any gift or
of influencing business decisions. hospitality of more than nominal value
(defined as 200 USD or any lower limit
• I recognize and respect our customers’ specified locally) to or from any individual
policies regarding gifts and hospitality. or organization that does or seeks to do
business with SLB.
• I always ask my manager if I am unsure
whether a particular gift or type of
entertainment is appropriate.

Q A
Apart from its monetary value, Yes. While the amount should be
is there anything else I should below nominal value (200 USD)
consider before giving or or properly approved if above that
receiving a business gift? amount, other factors are equally
important.

You should be sure that any

proposed business gift is not
made too frequently, intended to
influence a decision or made while
a decision is pending.
16 17
 Our Company
is the Sum
of Our Actions

18 19
Fair and Open Business Practices
Represent Who We Are
In Brief Government Officials

• W
 e have zero tolerance for corruption Payments to government officials are
and no employee may offer or accept forbidden. The term “government official”
bribes in any form (including Facilitation includes officers or employees of any
Payments). branch of government, the immediate
family members of such an official, political
• W
 e do not use company funds or assets candidates, and officers or employees
for political purposes. of any corporation owned or controlled
• W
 e may engage in direct dialogue with by the government, including national oil
public policy decision makers, but we do companies.
not use lobbyists or seek to bring about a Direct payments are prohibited, as are
particular outcome or decision. offers of payment, payments made
through third parties (such as agents) and
reimbursements of payments that we or
someone else may have made personally.
Bribery and Corruption
SLB Does not Engage in Political Activity
We do not obtain a business advantage
through bribery, improper payments or any SLB is politically neutral and does not
other illegal means. SLB has zero tolerance make political contributions. We may not
for corruption. The direct or indirect offer, use company funds or assets for political
payment, solicitation or acceptance of purposes.
bribes in any form is strictly prohibited.
With respect to public policy matters
We must never give or receive any kind of affecting the company and its shareholders,
bribe or hidden payment to: SLB may engage in a direct dialogue with
decision makers but does not use paid
• influence someone’s judgment about our lobbyists or seek to bring about a particular
products and services outcome or decision.
• g
 ain improper advantage when selling
our goods and services

• influence a government official’s use of

discretionary authority

20 21
Competing Fairly and Ethically
Builds Trust
In Brief An Honest and Open Approach

• We compete aggressively but fairly. SLB competes aggressively but fairly.
We do not win business or maintain
• W
 e do not win business or maintain customer relationships by acting illegally
customer relationships by acting illegally or unethically. Each of us must deal fairly
or unethically. and openly with customers, suppliers and
competitors.
• W
 e do not enter into agreements that can
restrict full and fair competition. Promoting Full and Fair Competition

• W
 e do not share pricing or bidding As SLB employees, we must not take
information with competitors or anyone unfair advantage of a business situation
outside of SLB. through abuse of confidential information,
misrepresenting material facts or
deliberately doing anything that may be
viewed as unfair. Any kind of agreement
or understanding with our competitors
to restrict full and fair competition is
prohibited. This means we cannot enter
into agreements that fix or control prices;
allocate products, markets or territories; or
limit the manufacture, sale or production of
any product or the provision of any service.

Whenever we are involved in trade

association activities or in other situations Q A
where there is communication among A friend works at a competitor. Yes. However, at trade association
competitors, customers or suppliers, we We will both be attending an meetings and similar functions
must be especially alert to ethical and legal upcoming trade association one should be careful to avoid any
requirements.
meeting, so I’m going to request appearance of impropriety when
that we are seated at the same interacting with competitors. So,
lunch table for both days. at your lunch you should avoid
discussing SLB or the competitor’s
Is this OK?
business matters because this may
create the appearance of improper
collaboration.
22 23
Our Relationships with Others Our Community Relationships
Demonstrates Respect Build on Our Mindset
In Brief Embracing Diversity and Equality Contributing to Development and
Communities Worldwide
• W
 e encourage fair employment and offer One of our company’s strengths is the
equal opportunity. diversity of our workforce. Employees of SLB employees represent more than
many nationalities and backgrounds work 140 nationalities and live and work in
• W
 e do not tolerate harassment or other together to achieve common objectives. approximately 85 countries worldwide. We
offensive behavior. As a global company, we encourage fair foster economic development by recruiting,
• W
 e recruit, hire and train where we work, employment practices and offer equal hiring, and training where we work;
and we comply with local content rules. opportunities to all our employees. promoting from within; and by complying
with international labor standards and local
• We promote health and education in local SLB obeys the employment laws of the content rules.
communities. countries in which it operates and does
not engage in discrimination based on In addition, we contribute to the social
race, color, gender, age, sexual orientation, development and well-being of these
ethnicity, disability, religion, union communities by actively advancing
membership, or marital status in hiring and education and health awareness as well as
employment practices such as promotions, supporting initiatives that improve youth
rewards, and access to training. education and living conditions. We prohibit
any use or contracting, directly or indirectly,
Working Together with Mutual Respect of slavery, human trafficking, child labor, or
SLB employees are expected to treat one any form of forced labor.
another professionally and with mutual SLB is committed to respecting the
respect. SLB employees must also display principles in The International Bill of Human
respect when interacting with customers, Rights and conducting business in a manner
contractors and others affected by our that preserves and respects human dignity.
operations. SLB does not tolerate any form To ensure the respect of human rights and
of harassment or other offensive action. the progression of sustainable development,
SLB has aligned its sustainability program
with the Sustainable Development Goals of
the United Nations.

24 25
Respecting Immigration Laws Trade Control Compliance
Enables Our Global Footprint Safeguards Our Business
In Brief Our business involves the international In Brief SLB provides products and services in
movement of employees. We must ensure many countries worldwide. Virtually all
• We comply with all immigration and that the travel, transfer, employment and • W
 e comply fully with all applicable trade the countries in which we operate have
employment laws. residence of all personnel comply with control laws and regulations. customs laws and many have additional
• We expect all employees to take applicable immigration and employment • W
 e are especially mindful of technology trade controls that govern the import,
responsibility for their immigration status. laws. transfers. temporary import, export or re- export of
SLB products, services, technology and
• We expect all employee dependents This requirement extends to dependents of • W
 e review all shipments for compliance software.
and contractor personnel to abide by our employees and to contractor personnel. before they are shipped or released.
immigration laws. SLB has visa and immigration compliance We must comply strictly with all trade
programs to assist in this effort, but we are • W
 e expect all employees to consult a control laws and regulations that apply to
• We maintain immigration compliance each responsible for our immigration and trade control compliance manager on us, wherever we do business.
programs to ensure that correct employment status in the countries where any questionable import or export.
procedures are followed. we work and live.

Q A
I will be performing a safety Maybe. Hand-carrying products,
inspection on a deepwater rig in software or technical data from one
West Africa. The team on the rig country to another is considered an
needs equipment for the job. export or re-export and is subject
Can I carry it to the rig for them? to applicable trade regulations,
including the proper filing of
customs paperwork.
If the proper procedure is not
followed, hand-carrying items to
another country may subject an
employee to disciplinary action.

26 27
Data Privacy and Protection
Preserves Information Security
In Brief Personal information must be collected
only for lawful business purposes. SLB is
• We respect the privacy of our employees committed to protecting and respecting
and ensure proper collection and use of the privacy of any employee or third-party
personal data and hold those who handle personal information that it processes.
such information accountable for its
proper use. Specific internal data privacy requirements
guide the collection, use, transfer (including
• We protect the security of personal data transfer across international boundaries),
and maintain records in accordance with release, disclosure and security of such
regulations. data.
• We expect employees to refrain from These requirements also describe our
discussing other employees or company expectations for third parties who process
business in public forums. such data on our behalf.
• We require employees to refer all external The transfer of employee data to third
inquiries for information to the Legal or parties located in countries that do not have
Communications function. adequate levels of personal data protection
(e.g. outside the European Economic Area)
is regulated more strictly.

Q A
What are some examples of Employee personal data includes
employee personal data? an employee’s name, birth date,
address, telephone number, social
security number, and financial or
bank account information.
Such employee data may be
processed only for legitimate
and appropriate purposes in
connection with SLB business
activities.

28 29
Representing SLB is a Privilege Information Technology
Enables Superior Results
In our daily lives, we interact in a variety of What we publish externally reflects on the
public forums, such as conferences and entire company. Any profile and related SLB provides its employees with a range
professional society events or through content that we post on personal or social of information technology tools, such as
the Internet and social media. In these networking web sites must be consistent computers, software and networks for
situations, we may unintentionally be seen with how we are expected to present business purposes. Reasonable personal
as representing SLB in an official capacity. ourselves to customers and colleagues as use of these tools is allowed. All electronic
We represent SLB whenever we identify SLB employees. Refrain from discussing records produced using SLB tools or
ourselves as SLB employees or affiliates. SLB business or confidential company transmitted using SLB networks are SLB
information on these web sites or anywhere property, including email, instant messages
else outside the company. and computer files.

SLB has the right to review the information

stored or transmitted using these tools.
Employees should have no expectation of
privacy over any such information, subject
to applicable data privacy laws.

Q A
As a field engineer working on a Maybe. Social media should
customer rig, would it be okay to not be used to publish, post or
post on a social media site photos discuss SLB or customer- related
of me and my crew at work? information without prior approval.
Photos of SLB or customer
equipment, premises or products
could contain such proprietary
information.
Also, the presence of other
individuals in the photos could raise
questions about data privacy.

30
 Maintaining Confidentiality
and Information Security Protects

In brief reservoir data, information stored in the

corporate directory, employee personal
• W
 e treat all electronic records that are data and financial operating results.
created or transmitted using company
tools as company property. Protecting Restricted Information

• W
 e allow limited personal use of SLB Accidental disclosure of confidential
IT tools, and employees should have information can be as harmful as
no expectation of privacy over any intentional disclosure. If we have access to
information stored or transmitted using information that is commercially sensitive
such tools. or confidential, we may not disclose that
information to any unauthorized person,
• W
 e take every available measure to inside or outside SLB, without obtaining the
preserve the confidentiality of SLB and necessary prior approvals.
customer data.
We need to be particularly careful of
• W
 e expect each employee to prevent what we and our family members say or
disclosure of confidential information and do in our day-to-day interactions with
to protect access to company property. customers and other business associates
and in social settings. Be careful when
handling computers, software and data to
Information is the Foundation prevent inadvertent disclosure of sensitive
of Our Business information. Protect company computers
We must protect important information, and other data devices from theft and
whether it belongs to SLB or to others, such damage.
as our customers, who have entrusted Everyone must obtain the appropriate
it to us. We may learn confidential or management authorization to access
commercially sensitive information directly company property, including buildings,
from a customer or while we are performing equipment and data.
our jobs. Confidential information comes in
many forms, including in conversation, on
paper or electronically.

Examples of confidential information

include tool designs, application source
codes, marketing plans, customers’
32 33
Protecting Our Intellectual Property
Promotes Technological Innovation
In brief SLB’s investment in technology requires
strong protection of the resulting intellectual
• W
 e protect our technology and property assets. Intellectual property is
intellectual property assets. created when a SLB employee makes a
• W
 e require employees to acknowledge new discovery or conceives of an idea,
that intellectual property created while device, technique or process that is related
working for the company belongs to our business.
exclusively to the company. The invention becomes the exclusive
• W
 e comply with restrictions on the property of SLB. Upon joining the company,
installation and use of third-party all employees agree to this concept as a
software. condition of employment.

• W
 e do not allow employees to make or The company also protects its intellectual
use copies of software, publications, property and confidential information by
copyrighted materials or trademarks using non-disclosure agreements and
without proper authorization. confidential disclosure agreements—
before giving third parties access to such
information.

Respecting Copyrights, Software

Licenses and Trademarks Benefits
us all
SLB respects copyright and trademark laws All the software, copyrighted material
and observes the terms and conditions or trademarks we use must be properly
of software license agreements. Never licensed or owned by SLB. We must comply
make unauthorized copies of software, with company restrictions on the installation
publications or other copyrighted material. and use of third-party software on company
Likewise, never use trademarks without computers.
proper authorization.

34 35
 Managing Business Records
Ensures Transparency
In Brief This applies equally to instant and email
messages, internal memos and formal
• We maintain honest and accurate reports.
business records.
Archiving and Destroying
• We never hide, alter, falsify or disguise the Business Records
true nature of any business transaction.
Every business unit is responsible for
• We comply with accounting and ensuring that its records are retained or
financial reporting standards and require destroyed according to local laws and
employees to comply with internal SLB requirements governing document
financial approval limits. retention and destruction.
• We retain or destroy business records At times, the company may direct us to
in accordance with local laws and SLB retain documents, in electronic or other
requirements. formats, in connection with certain specific
subjects, such as litigation, government
inquiries or government or customer audits.
Full and Accurate Accounting Failure to retain documents could result in
of Our Activities criminal, civil or administrative penalties or
We must keep honest and accurate disciplinary action.
business records. The company’s ability
to make responsible business decisions;
to meet legal, financial, regulatory and
management obligations; and to maximize
the benefit of previous experience,
depends on compliance with this
requirement.

Never hide, alter, falsify or disguise the true

nature of any business transaction. Business
records and communications often
become public, so avoid exaggeration,
derogatory remarks, speculation or
inappropriate characterization of people
and companies.

36 37
Rigorous Accounting
and Financial Reporting
Standards Instill Confidence
Complying with Accounting and Financial
Reporting Standards

All company transactions must be described

accurately in accounting or supporting
documents. Employees with financial
reporting obligations must provide accurate
and complete information to ensure that
any reporting or disclosure of financial
information is full, fair, accurate, timely and
understandable. Approval by the appropriate
level of financial personnel is also required.

These requirements facilitate the preparation

of financial statements, provide transparency
to our shareholders, and ensure compliance
with the U.S. Generally Accepted Accounting
Principles (GAAP).

Making Financial Transactions on Behalf

of the Company

We must have the appropriate management

authorization for any transaction that we
conduct on behalf of SLB.

For more detail, refer to www.integrity.slb.com

38 39