Acting ethically means not only complying with laws and regulations but also recognizing that our decisions affect others. Through compliance and ethical behavior, we maintain the respect, trust, and confidence of our customers, colleagues, shareholders, and others affected by our operations (Code of Conduct, p. 7).
Schlumberger also requires suppliers and other third parties doing business or entering into contracts with Schlumberger to abide strictly by our ethical standards.
Supply Chain Management
Schlumberger has zero tolerance for corruption of any kind, and we expect the same from our contractors and suppliers. We work with our suppliers in a socially responsible and ethical manner and continuously seek to improve the way we conduct business. All suppliers, contractors, and agents are approved and managed according to our Code of Conduct and other company requirements (Code of Conduct, p. 7).
To meet our requirements for working conditions, our suppliers must adhere to responsible social, environmental, and economic practices. These requirements relate to freely chosen employment, child labor, discrimination, harsh and inhumane treatment, minimum wages, working hours, and freedom of association.
Employee Whistle Blower Protection
Schlumberger prohibits retaliation for good faith reporting of both potential and actual violations of the Code of Conduct, other company requirements, and applicable laws. Employees who intentionally report false information are subject to disciplinary action (Code of Conduct, p. 7).
Employees who know of or suspect a violation of the Code of Conduct or applicable laws are required to report it internally (Code of Conduct, p. 7).
Conflicts of Interest
Employees must put Schlumberger business interests first, disclose all conflicts of interest, and avoid situations that create the appearance of a conflict of interest. If such a conflict exists, the affected employee must obtain written approval from an appropriate Schlumberger controller before continuing to work (Code of Conduct, p. 9).
We keep confidential all nonpublic and insider information that relates to Schlumberger or our financial position. This includes knowledge of unannounced marketing plans, new product releases, financial results, changes in dividends and earnings, planned mergers and acquisitions, and business strategies. If we have such information, we must keep it confidential and we may not buy or sell Schlumberger Limited stock or publicly traded options of Schlumberger stock until the information becomes public. Stock and options of other companies with which Schlumberger does business also cannot be acted upon until the information is public knowledge (Code of Conduct, p. 10).
Gifts and Entertainment
Gifts and hospitality of more than nominal value (defined as $200 or any lower limit specified locally) cannot be offered to or accepted from any individual or organization that does or seeks to do business with Schlumberger (Code of Conduct, p. 11).
Schlumberger has zero tolerance for corruption. Bribes are never offered or accepted in any form or under any circumstance. We do not use company funds or assets for political purposes. We may engage in direct dialogue with public policy decision makers, but we do not use lobbyists or seek to bring about particular outcomes or decisions. We avoid facilitation payments, making them only in very limited circumstances, such as when health or safety is at risk, and only when we have obtained proper approval and documentation according to Schlumberger requirements (Code of Conduct, p. 13).
Fair and Ethical Competition
Schlumberger competes aggressively but fairly. We do not enter into agreements that can restrict full and fair competition. We do not share pricing and bidding information with competitors or anyone outside of Schlumberger (Code of Conduct, p. 14).
We comply fully with all applicable trade control laws and regulations. We are especially mindful of technology transfers. We review all shipments for compliance before they are shipped or released. We expect all employees to consult a trade control compliance manager about any questionable import or export (Code of Conduct, p. 16).
Business and Financial Transparency
We maintain honest and accurate business records. We never hide, alter, falsify, or disguise the true nature of any business transaction. We comply with accounting and financial reporting standards and require employees to follow internal financial approval guidelines. We retain and destroy business records in accordance with local laws and Schlumberger requirements (Code of Conduct, p. 20).
Schlumberger recognizes that there are serious human rights abuses associated with the extraction, transportation, and trade in minerals in the covered countries. We have always supported responsible sourcing of materials from suppliers that share our values, and we commit to avoiding contributing to the conflict through our sourcing activity. We have developed a Conflict Minerals Policy to supplement our Code of Conduct.