Acting ethically involves more than simply ensuring compliance with laws and regulations. It involves recognition that our decisions affect others. By keeping this in mind, we earn the respect, trust and confidence of our customers, colleagues, shareholders, and others affected by our operations. By doing things right the first time, every time, we enhance our reputation for integrity with these stakeholders (Our Code of Conduct, p. 11).
Supply Chain Management
Schlumberger works with suppliers in a socially responsible and ethical manner. We have zero tolerance for corruption of any kind, and we expect the same from our contractors and suppliers. To meet our industry requirements, suppliers must adhere to responsible social, environmental, and economic practices. Our suppliers are selected and retained in alignment with our health, safety, and environmental stewardship standards and Code of Conduct (Our Code of Conduct, p. 12).
Employee Whistle Blower Protection
Employees who believe that a violation of Our Code of Conduct has occurred must report concerns to management using any available channel of communication. Schlumberger will not tolerate retaliation against anyone who raises a concern in good faith. Employees are required to report known and suspected violations of the Code of Conduct and applicable national laws. However, employees who intentionally report false information are subject to disciplinary action (Our Code of Conduct, pp. 1 and 12).
Conflicts of Interest
Conﬂicts between personal interests and the interests of Schlumberger or its customers may arise when personal, social, financial, political, or other interests interfere. To avoid such conﬂicts of interest, employees must not hold financial stakes in companies that do business with Schlumberger. They 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 (Our Code of Conduct, p. 16).
Our Insider Trading Standard prohibits employees from releasing confidential information about such things as unannounced marketing plans, new product releases, financial results, changes in dividends and earnings, planned mergers and acquisitions, and business strategies. Employees are required to keep such information confidential, including all nonpublic and insider information that relates to Schlumberger or its financial position. Also, employees may not buy or sell Schlumberger Limited stock or publicly traded options until the information becomes public, nor can they act to acquire or sell stocks and options of companies with which Schlumberger does business until the information is public knowledge (Our Code of Conduct, p. 17).
Gifts and Entertainment
Accepting or giving business gifts or hospitality must never inﬂuence business decisions. Items or benefits for which the recipient does not pay fair market value, including meals, entertainment, or tickets to sporting events worth more than a nominal value cannot be offered to or accepted from any individual or organization that wishes to do business with Schlumberger (Our Code of Conduct, p. 19).
No employee may offer or accept bribes in any form or under any circumstance, including bribes related to charitable contributions. We avoid facilitation payments, making them only in very limited circumstances, such as when an individual's health or safety is at risk and only when we have obtained proper approval and documentation according to Schlumberger requirements. In addition, payments to government officials are forbidden. Schlumberger is politically neutral and does not make political contributions (Our Code of Conduct, p. 23).
Fair and Ethical Competition
Schlumberger does not win business or maintain customer relationships by acting illegally or unethically. We do not enter into agreements that can restrict full and fair competition. We do not share pricing or bidding information with competitors, or with anyone outside of the Company. We do not use Company funds or assets for political purposes. We may engage in dialogue with public policy decision makers, but we do not use lobbyists or seek to bring about particular outcomes or decisions. We compete aggressively, but fairly (Our Code of Conduct, p. 26).
Schlumberger provides products and services in many countries worldwide. Virtually all of the countries in which we operate have customs laws, and many have additional trade controls that govern the import, temporary import, export or re-export of Schlumberger products, services, technology, and software. Wherever we do business, we comply with all trade control laws and regulations that apply to us, and we are especially mindful of technology transfers (Our Code of Conduct, p. 30).
Business and Financial Transparency
Schlumberger keeps honest and accurate business records. Employees must not hide, alter, falsify or disguise the true nature of any business transaction. Schlumberger complies with accounting and financial reporting standards, and requires employees to follow internal financial approval guidelines. We retain and destroy business records in accordance with local laws and with Schlumberger requirements (Our Code of Conduct, p. 36).
Schlumberger recognizes that human rights abuses can exist in the extraction, transportation, and trade of minerals in some countries. We commit to not knowingly contribute to the conﬂict through our sourcing activity. Schlumberger does not tolerate corruption of any kind, and we expect our suppliers to adhere to the same standard. We have also developed a supplementary Conﬂict Minerals Policy.