Business_Gifts_&_Courtesies_Guideline

Business Gifts and Courtesies Guideline Guideline SL-FINANCE-G001

1. Statement of Guideline

Schlumberger recognizes that the exchange or provision of business gifts and courtesies is common practice in the business environment and is usually done to create goodwill and strengthen business relationships. While allowable within limits, giving and accepting such items in a business relationship may create a sense of obligation or a request for special treatment that may lead to improper, unethical, or illegal behavior.

2. Objective The objective of this guideline is to provide guidance to Schlumberger employees so that they understand what is considered to be appropriate and inappropriate behavior with respect to the giving and acceptance of business gifts and courtesies under the Schlumberger Code of Ethics and Business Ethics Policy.

In addition, this guideline serves as a reminder that Schlumberger employees should not cause an employee of any company that Schlumberger does or seeks to do business with to violate any applicable laws or related internal policies of his or her company.

3. Scope This guideline applies to all employees, contractors and agents of the Schlumberger Group of Companies, and all entities that are majority owned or controlled by Schlumberger.

4. Implementation and Monitoring 4.1. Definitions

”Business gifts and courtesies” are items or benefits for which the recipient does not pay fair market value. These can include tangible goods, services, recreation, hospitality, passes, discounts and favors.

“nominal value” is less than US $200 or equivalent local currency. Depending on cultural or client customs and practices, local business practices, or currency exchange rates, an Area or GeoMarket Controller may establish a lower limit for such a value.

“Schlumberger employee(s)” means all employees, contractors, and agents of the Schlumberger Group of Companies, and all entities that are majority owned or controlled by Schlumberger.

4.2. Responsibility

It is the responsibility of every Schlumberger employee to make sure that his or her conduct regarding the giving or acceptance of business gifts and courtesies is and appears to be proper and ethical at all times, and strictly in compliance with applicable laws and Schlumberger policies and guidelines.


In situations where the nature of a gift or reason for giving or accepting a gift is uncertain or questionable, employees should consult with their manager, or the Legal or Finance Departments.

4.3 General Requirements: Business Gifts and Courtesies

4.3.1 Schlumberger employees and members of their families are not permitted to offer business gifts or courtesies of more than nominal value to any individuals, relatives of such individuals, or any entity with whom Schlumberger does or seeks to do business with.

4.3.2 Schlumberger employees and members of their families are not permitted to accept business gifts or courtesies of more than nominal value from any individuals, relatives of such individuals, or any entity that does or seeks to do business with Schlumberger.

4.3.3 Schlumberger employees may provide or accept meals, entertainment and travel of a value in excess of the nominal value provided:

(i) It is associated with a legitimate business purpose and consistent with marketplace practices;

(ii) A representative of the company offering the invitation is present;

(iii) It is not lavish or extravagant;

(iv) Such offers are not frequent; and

(v) It could not be perceived as a direct attempt by the offering party to secure a favorable decision on a particular issue or matter.

4.3.4 Schlumberger employees may not, in relation to individuals, relatives of such individuals, or any entity that does or seeks to do business with Schlumberger:

(i) Give or accept a gift even of nominal value if it can be perceived to influence the recipient’s judgment in business decisions or dealings;

(ii) Give or accept cash or loans of any amount; or

(iii) Seek or ask for business gifts or courtesies.

4.3.5 This Guideline is also meant to cover the exchange of business gifts, courtesies, meals or entertainment with any government employees or employees of national or state owned companies that Schlumberger does or seeks to do business with.

4.3.6 This Guideline does not prohibit ‘facilitating payments’ (where necessary to assist in completing routine governmental actions), which are covered in more detail in Financial Procedure- 24.

4.3.7 All receipts, records, and expenses associated with business gifts, courtesies, meals and entertainment must be properly detailed,


recorded and retained in the appropriate company financial accounting records.

4.4. Exceptions

4.4.1 The expectation is that there will be strict adherence to this Guideline. However, in the limited case where circumstances might warrant an exception to the Business Gifts and Courtesies Guideline, they must be specifically documented and approved as follows:

(i) By the appropriate GeoMarket Controller for business gifts and courtesies with values between US $200 (or the established lower limit) and US $400.

(ii) By the appropriate Area Controller for business gifts and courtesies with values over US $400.

(iii) By the SL Controller for any monetary or other exceptions to the Guideline.

4.4.2 Any local, or otherwise applicable law that might be more strict than this Guideline must be complied with.

5. Useful Resources: Schlumberger Code of Ethics

Business Ethics Policy

Anti-Corruption Policy

Financial Procedure (FP) - 24 Compliance with Business Ethics, Anti-Corruption, and Financial Reporting Policies

6. Revision History Effective Date

Nov. 15, 2004

Description

Business Gifts and Courtesies Guideline

Prepared by (name)

S. Girard

B. Curtis

Reviewed by (name)

S. Ayat

Latest revision approved by (name): J-M Perraud Signed:

Documents

Business_Gifts_&_Courtesies_Guideline