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Tower of Thieves Assignment MBA Business Ethics

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Transcript of Tower of Thieves Assignment MBA Business Ethics

3-0015 - Defalcation, Misappropriation and Similar Irregularities (Fraud)
Halliburton Company & Subsidiary Companies
CORPORATE POLICY


Date: December 3, 2008
Index No.: 3-0015

PURPOSE
This Policy establishes and communicates the Company's policy regarding the prohibition, recognition, reporting and investigation of suspected fraud, defalcation, misappropriation and other similar irregularities.

DEFINITIONS
The term "Fraud" as used in this Policy includes, but is not limited to, defalcation, misappropriation and other irregularities including such things as any:
• dishonest or fraudulent act;
• defalcation;
• embezzlement;
• forgery or alteration of negotiable instruments such as Company checks and drafts;
• misappropriation of Company, Employee, customer, partner or supplier assets;
• conversion to personal use of cash, securities, supplies or any other Company asset;
• unauthorized handling or reporting of Company transactions; and
• falsification of Company records or financial statements for personal or other reasons.

The above list is not all-inclusive but is intended to be representative of situations involving fraud. Fraud may be perpetrated not only by Company Employees, but by agents and other outside parties as well. All such situations require specific action by the Company.
The purpose of this assignment is to evaluate and map each "bad act" perpetrated by characters portrayed in Tower of Thieves, by Andrew Spencer. Tower of Thieves centers on John Falcetta, a then-Vice President of AIG's life insurance division. Falcetta was arrested in December of 2007 and is currently in prison. This presentation will identify all acts which would be considered in violation of a well written Corporate Code of Ethics. Each act will be identified and subsequently paired with a section of code from a multi national corporations written Code of Ethics. Click on the arrow below to scroll Tower Of Thieves Karl Pond
MBA Business Ethics
Spring 2011 I have chosen to use Halliburton's Code of Ethics as the comparative instrument for this assignment. As each ethical "bad act" is identified, and by whom it was committed, a corresponding section from Halliburton's Corporate Code of Ethics will be used to evaluate how the "bad act" would be in violation. An index of the Code of Corporate Business Conduct:
http://www.halliburton.com/AboutUs/default.aspx?navid=976&pageid=2288 From Wikipedia, the free encyclopedia

Halliburton

Type Public (NYSE: HAL)
Industry Oil & gas equipment & services
Founded 1919, Duncan, Oklahoma, USA
Founder(s) Erle P. Halliburton
Headquarters: Houston, Texas, USA
Dubai, UAE
Area served: Worldwide
Key people David J. Lesar (Chairman), (President) & (CEO)
Products Products and services to the energy industry
Revenue increase US$18.279 billion (2008)
(U.S. 46% International 54%)
Operating income increase $4.010 billion (2008)
Net income increase $2.224 billion (2008)
Total assets increase $14.385 billion (2008)
Total equity increase $7.725 billion (2008)
Employees 52,000 (September 2009)
Website Halliburton.com

Halliburton (pronounced /hælbrtn/; NYSE: HAL) is the world's second largest oilfield services corporation with operations in more than 70 countries. It has hundreds of subsidiaries, affiliates, branches, brands and divisions worldwide and employs over 50,000 people.

The company has its headquarters in the North Belt office in Houston, Texas, and in offices in Dubai, United Arab Emirates (opened March 2007), where Chairman and CEO David J. Lesar works and resides, to focus [the] company’s Eastern Hemisphere Growth. The company will remain incorporated in the United States.
Halliburton's major business segment is the Energy Services Group (ESG). ESG provides technical products and services for petroleum and natural gas exploration and production. Halliburton's former subsidiary, KBR, is a major construction company of refineries, oil fields, pipelines, and chemical plants. Halliburton announced on April 5, 2007 that it had finally broken ties with KBR, which had been its contracting, engineering and construction unit as a part of the company for 44 years John Falcetta Sevestre
Ludwig Baruche
Joel Farre Tom Pomboyno Jackie Aguanne Hoffman Freudman Edmund Tse Anastasia Kelly Rod Martin David Fravel Bob Lewis
Timothy Gaither Connie Miller Senator Dodd Secretary #1 Secretary #2 Lower Level Management DL Piper Gary Santone Justin Broadbent AIG in General
Falcetta not reporting the lack of oversight in the issuing of payments to vendors with only an invoice required ( no other proof of work completed.). Falcetta and Pomboyno scheming to form "dummy-corporate headhunting firm". Falcetta not adressing the issue that he had single line signage authority with no control mechanism in place. Falcetta adding Enterprise Search Associates to the approved vendor list. Falcetta providing Pomboyno with actual invoices from other vendors to use as templates for his scheme. Falcetta getting checks issued for ESA with no actual placements taking place. Falcetta receiving checks on behalf of "Human Capital Management Partners". Falcetta back dating memos of opinion with regard to the Bermuda payment practice. Falcetta using, on countless occasions, his corporate account ( ie: visa) for non-authorized expenses. Falcetta directing the HR Department to utilize "Bench" funds for the payment of invoices from ESA. Falcetta conspiring to and facilitating the startup of two additional "Headhunting Firms" and adding them to the approved vendor list. Falcetta intentionally omitting any reference to Bermuda activities when interviewed by the SEC agent. Falcetta keeping the hard drive from his laptop when asked to turn it over to AIG. Vassiliou
Choffell
Garcia Nottingham Didier Hoff Karen Hansen
Marc Bernstein
Staton Young Martin Sullivan All knowingly recieved payments from the Bermuda account and did not claim these payments for tax purposes. Defrauded AIG through the operation of an illegitimate headhunting scam with Falcetta. Had direct knowledge of and involvement in the Bermuda scheme. and failed to disclose this. Produced a report describing how alternatives to the Bermuda payment structure could be orchestrated to minimize the chances of an audit, rather than reporting the fraud that had been occurring. Had direct involvement in the Bermuda scheme and never reported it. Instructed Falcetta to write checks through a known illegal practice. (Bermuda scheme) Produced a financial report for shareholders in August of 2007 that was constructed not to portray accurate information, but information which portrayed AIG in a very positive financial light. Miller drafted a Bonus Payment contract for her division for the years 2008 and 2009 which was fraught with language which entitled AIG employees to non-justifiable compenstaion. Recieved payment for a home directly from AIG. Worked with Falcetta to defraud AIG through a Bogus Headhunting scheme. As an outside firm, failed to accurately portray the reasons for examining the Bermuda practice, citing it as "outdated" and in need of "modernization" despite earlier determinations of the practice being illegal. Benefitted directly from the Bermuda scheme, and failed to report the practice. Engaged an outside firm ( DL Piper) in an attempt to avoid discovery of the Bermuda Scheme. AIG regularly worked with Price Waterhouse Cooper and had they conducted the investigation, the scheme would have been revealed. Knowingly asked George Dove to produce false earning statements in order to try and correct the Greek Tax problem. Took over as Chaiman of the Bermuda operation, replacing Tse, with full knowledge of the Bermuda scheme. Recipients of payments from the covert Bermuda account. Lied about his knowledge of the AIG bonus structure Failed to disclose his receipt of monies over the years from AIG as well as his wife's involvement in operations at AIG. Authorizing non-justified overtime payments. Falsified time cards and recieved payment for time not actually spent working. Used company time and money to purchase goods and subsequently to sell those goods, keeping all proceeds. Additionally, use of company vehicles for transport of sold goods. Steve Gorman Knowingly covered up Bermuda scheme, as well as instructing others to commit acts to continue the cover up.
Created another bogus Headhunting firm with Falcetta, and defrauded AIG. Made bogus payments to "vendors" with nothing more than an invoice..no oversight. Paticipated in, and attempted to cover up the Bermuda scheme for years. Lied to Falcetta about the Bermuda scheme. Had direct knowledge of and involvement in the Bermuda scheme. ( ie: He actually wrote checks.) Participated in, and knowingly covered up the Bermuda scheme. Collectively "passed the buck" rather than report to authorities the illegal activities of the Bermuda scheme. Ludwig Baruche
Joel Favre Both recieved Bermuda payments without claiming taxable income. Used company funds to hold lavish events, in addtion to paying for employees to travel and stay in lavish accomodations. Allowed the "home leave" scam in Hong Kong to take place. The payroll scam in the Delaware office. ( HR employees taking and cashing redundant payroll checks after knowingly issuing them in "error". The case of the Fed-Ex box being shipped from place to place, empty, with no oversight, or accountability to the cost, productivity, or effort of doing so. The payout of Bonus checks in 2008 and 2009 despite recieving Federal bailout money. The practice of being not only the underwriter of morgages, but also owning the underwriting of morgage insurance policies. The practice of "credit default swapping" Wrote the "little chestnut" into the stimulus plan that entitled AIG to make bonus payments with stimulus dollars. 3-0003 - Conflicts of Interest There are certain situations which the Company will always consider to be conflicts of interest. These occur if the Director or Employee, or any other person having a close personal relationship with the Director or Employee:
c. accepts money, gifts of other than nominal value, excessive hospitality, loans, guarantees of obligations or other special treatment from any supplier, customer or competitor of the Company (loans from lending institutions at prevailing interest rates are excluded);
e. learns of a business opportunity through association with the Company and discloses it to a third party or invests in or takes the opportunity personally without first offering it to the Company.

f. uses corporate property, information, or position for personal gain; or

g. competes with the Company.
3-0006 - Commercial Bribery
Halliburton Company & Subsidiary Companies
CORPORATE POLICY


Date: May 21, 2003
Index No.: 3-0006

PURPOSE
This Policy prohibits the payment or transfer of Company funds or assets to suppliers or customers in the form of bribes, kickbacks or other payoffs and prohibits Company Directors, Employees and agents from participating in such schemes.

POLICY
1. The Company prohibits bribes, kickbacks and other payoffs and benefits to suppliers or customers.

2. The Company also prohibits Directors, Employees and agents from receiving, directly or indirectly from a third party, anything of a significant value (other than salary, wages or other ordinary compensation paid by the Company) in connection with a transaction entered into by the Company.

3. Bribes, kickbacks and payoffs include, but are not limited to:

a. gifts of other than nominal value;

b. cash payments by Directors, Employees or third persons, such as agents, suppliers, customers or consultants, who are reimbursed by the Company;

c. the uncompensated use of Company services, facilities or property except as may be authorized by the Company; and

d. loans, loan guarantees or other extensions of credit (except from lending institutions at prevailing rates). 7. Reporting System.
Directors and Employees are both encouraged and obligated to promptly report any violations of the Code of Business Conduct. The Policy Committee shall establish a reporting system that will allow violations of the Code of Business Conduct to be reported and acted upon by Directors, officers or other Employees of the Company with sufficient authority to deal objectively with the reported matters. The existence and nature of the reporting system shall be communicated to all Employees and, to the extent appropriate, to agents of the Company. The reporting system shall include an Ethics Helpline. If in doubt about the person to contact, reports should be made to the Ethics Helpline, the General Counsel or any representative of the Law Department. 3-0001 - General Policy Regarding Laws & Business Conduct
Halliburton Company & Subsidiary Companies
CORPORATE POLICY 3-0009 - Information of a Confidential or Proprietary Nature
Halliburton Company & Subsidiary Companies
CORPORATE POLICY
Date: December 3, 2008
Index No.: 3-0009

PURPOSE
In carrying out the Company's business, Directors, Employees and agents often learn confidential or proprietary information about the Company, its customers, suppliers or joint venture partners. This Policy prohibits the unauthorized disclosure or use of confidential or proprietary information about the Company, its customers, suppliers or joint venture partners.

POLICY
1. No Director, Employee or agent entrusted with or otherwise knowledgeable about information of a confidential or proprietary nature shall disclose or use that information outside the Company or for personal gain, either during or after employment or other service to the Company, without the valid and proper written Company authorization to do so given by a manager or Employee with the authority to release confidential or proprietary information. An unauthorized disclosure could be harmful to the Company or helpful to a competitor. 3-0004 - Internal Accounting Controls, Procedures & Records
Halliburton Company & Subsidiary Companies
CORPORATE POLICy

POLICY
1. Authorization. The only transactions to be entered into by the Company are those which are executed in accordance with management's specific approval (as set forth in the following paragraph) or established, formalized policies and procedures.

2. Approval. No transaction will be recorded in the accounts of the Company unless it is within the scope of written policies and procedures or is specifically and formally approved by an appropriate and designated Employee. Such approval requires the determination that the transaction (i) has been authorized in accordance with this Corporate Policy and (ii) is supported by documentary evidence to verify the validity of the transaction.

3. Accounting. All transactions entered into by the Company will be recorded in the accounts of the Company in accordance with normal, standard procedures. Each entry will be coded into an account which accurately and fairly reflects the true nature of the transaction.

4. Reporting. All transactions that have been accounted for in accordance with this Corporate Policy will be accumulated and processed in a manner which will permit timely preparation of financial statements, reports and data for purposes of internal, public and regulatory reporting. Such statements, reports and data must be understandable and prepared in a form sufficient to reflect fully, accurately and fairly the results of transactions entered into by the Company and to permit proper accountability for assets. 3-0006 - Commercial Bribery
Halliburton Company & Subsidiary Companies
CORPORATE POLICY


Date: May 21, 2003
Index No.: 3-0006

PURPOSE
This Policy prohibits the payment or transfer of Company funds or assets to suppliers or customers in the form of bribes, kickbacks or other payoffs and prohibits Company Directors, Employees and agents from participating in such schemes.

POLICY
1. The Company prohibits bribes, kickbacks and other payoffs and benefits to suppliers or customers.

2. The Company also prohibits Directors, Employees and agents from receiving, directly or indirectly from a third party, anything of a significant value (other than salary, wages or other ordinary compensation paid by the Company) in connection with a transaction entered into by the Company.

3. Bribes, kickbacks and payoffs include, but are not limited to:

a. gifts of other than nominal value;

b. cash payments by Directors, Employees or third persons, such as agents, suppliers, customers or consultants, who are reimbursed by the Company;

c. the uncompensated use of Company services, facilities or property except as may be authorized by the Company; and

d. loans, loan guarantees or other extensions of credit (except from lending institutions at prevailing rates).
3-0004 - Internal Accounting Controls, Procedures & Records
Halliburton Company & Subsidiary Companies
CORPORATE POLICY

PURPOSE
This Policy establishes guidelines and procedures related to keeping books and records that in reasonable detail accurately and fairly reflect the Company's transactions and dispositions of assets. The Company shall maintain a system of internal accounting controls to ensure reliability and adequacy of its books and records and proper recording of all transactions including dispositions of assets.

POLICY
1. Authorization. The only transactions to be entered into by the Company are those which are executed in accordance with management's specific approval (as set forth in the following paragraph) or established, formalized policies and procedures.

2. Approval. No transaction will be recorded in the accounts of the Company unless it is within the scope of written policies and procedures or is specifically and formally approved by an appropriate and designated Employee. Such approval requires the determination that the transaction (i) has been authorized in accordance with this Corporate Policy and (ii) is supported by documentary evidence to verify the validity of the transaction.

3. Accounting. All transactions entered into by the Company will be recorded in the accounts of the Company in accordance with normal, standard procedures. Each entry will be coded into an account which accurately and fairly reflects the true nature of the transaction.

4. Reporting. All transactions that have been accounted for in accordance with this Corporate Policy will be accumulated and processed in a manner which will permit timely preparation of financial statements, reports and data for purposes of internal, public and regulatory reporting. Such statements, reports and data must be understandable and prepared in a form sufficient to reflect fully, accurately and fairly the results of transactions entered into by the Company and to permit proper accountability for assets.

5. Responsibility. The implementation and maintenance of internal accounting controls, procedures and records that are adequate in all respects to satisfy the requirements of this Corporate Policy will be the primary responsibility of the Chief Financial Officer.

6. Auditing. Compliance with the provisions and requirements of this Corporate Policy will be tested and evaluated by the Company's head of Audit Services in connection with the on-going internal audit program. All control failures regarding this Corporate Policy will be reported to management so that deficiencies can be corrected and assurance of compliance with the terms of this Corporate Policy maintained. 3-0006 - Commercial Bribery
Halliburton Company & Subsidiary Companies
CORPORATE POLICY


Date: May 21, 2003
Index No.: 3-0006

PURPOSE
This Policy prohibits the payment or transfer of Company funds or assets to suppliers or customers in the form of bribes, kickbacks or other payoffs and prohibits Company Directors, Employees and agents from participating in such schemes.
4. This Policy does not prohibit expenditures of nominal amounts for meals and entertainment of suppliers and customers which are an ordinary and customary business expense, if they are otherwise lawful. These expenditures should be included on expense reports and approved under standard Company procedures. 3-0001 - General Policy Regarding Laws & Business Conduct
Halliburton Company & Subsidiary Companies
CORPORATE POLICY


Date: December 3, 2008
Index No.: 3-0001 B. Administration of Code of Business Conduct
The Code of Business Conduct of the Company shall be administered as follows:

1. Scope of Code of Business Conduct.
The Policy Committee shall, periodically, in light of the experience of the Company, review the Code of Business Conduct, and when necessary or desirable, make recommendations to the Board of Directors (i) to ensure its continued conformance to applicable Law, (ii) to ensure that it meets or exceeds industry standards, and (iii) to ensure that any weaknesses revealed through monitoring, auditing and reporting systems are eliminated or corrected.
There are certain situations which the Company will always consider to be conflicts of interest. These occur if the Director or Employee, or any other person having a close personal relationship with the Director or Employee:
c. accepts money, gifts of other than nominal value, excessive hospitality, loans, guarantees of obligations or other special treatment from any supplier, customer or competitor of the Company (loans from lending institutions at prevailing interest rates are excluded);
e. learns of a business opportunity through association with the Company and discloses it to a third party or invests in or takes the opportunity personally without first offering it to the Company.

f. uses corporate property, information, or position for personal gain; or

g. competes with the Company.
3-0003 - Conflicts of Interest

3-0008 - Use and Public Disclosure of Material Nonpublic Information
Halliburton Company & Subsidiary Companies
CORPORATE POLICY POLICY
1. This Policy applies to all Directors, Employees and agents of the Company without regard to nationality or country of residence. All Directors, Employees and agents of the Company must observe the prohibition on trading on material nonpublic information.

2. General Disclosure Policy. The Company will make prompt and complete disclosure of material nonpublic information to the public when and as required by Law and/or the rules of the SEC or the NYSE. Determinations regarding "materiality" involve subjective judgments; therefore, questions of materiality will be determined by the General Counsel and Chief Financial Officer. Any disclosures made by the Company in reports and documents filed with or submitted to the SEC and other public communications made by the Company shall be full, fair, accurate, timely and understandable. In furtherance of this Policy, the Company shall establish and maintain a Disclosure Committee and an Internal Controls Committee.
3-0005 - Sensitive Transactions
Halliburton Company & Subsidiary Companies
CORPORATE POLICY


PURPOSE
This Policy advises Directors, Employees and agents of the Company's position regarding sensitive transactions and requires that transactions are executed, and access to assets is permitted, only in accordance with management's authorization.

POLICY
1. The Company will conduct its business in compliance with applicable Law (See Corporate Policy 3-0001 with respect to conflicts between United States Law and the Law of another country) and requires all Company Directors and Employees to avoid any activities which could involve the Company in any unlawful practice. Without limiting the generality of the foregoing, the Company's Directors and Employees are strictly prohibited from paying any bribe, kickback or other similar unlawful payment to, or otherwise entering into a sensitive transaction with, any public official, political party or official, candidate for public office or other individual, in any country, to secure any contract, concession or other favorable treatment for the Company. Company Directors and Employees who make such payments are subject to appropriate action by the Company, as well as the legal consequences of applicable Law.

2. The term "sensitive transactions" is commonly used to describe a broad range of corporate dealings that are generally considered to be either illegal, unethical, immoral or to reflect adversely on the integrity of management. The transactions are usually in the nature of kickbacks, bribes or payoffs made in order to influence favorably some decision affecting a company's business or for the personal gain of an individual. Any extraordinary payment made from Company funds, including extravagant entertainment or gifts of significant value, for the express purpose of obtaining or retaining business or unduly influencing some matter in favor of the Company could be considered a "sensitive payment". These payments may be considered to be bribes and may result in violation of applicable Law.

3. Sensitive transactions may result in violation of United States federal Laws such as domestic anti-bribery Laws, mail fraud and wire fraud statutes, anti-racketeering statutes and the Foreign Corrupt Practices Act (the "FCPA"), as well as state Laws or Laws of other countries in which a subsidiary company has operations. If violations occur, the Company and its officers and Directors as well as Employees directly involved may be subject to fines, imprisonment and civil litigation. 3-0005 - Sensitive Transactions
Halliburton Company & Subsidiary Companies
CORPORATE POLICY


Date: May 21, 2003
Index No.: 3-0005

PURPOSE
This Policy advises Directors, Employees and agents of the Company's position regarding sensitive transactions and requires that transactions are executed, and access to assets is permitted, only in accordance with management's authorization.

POLICY
1. The Company will conduct its business in compliance with applicable Law (See Corporate Policy 3-0001 with respect to conflicts between United States Law and the Law of another country) and requires all Company Directors and Employees to avoid any activities which could involve the Company in any unlawful practice. Without limiting the generality of the foregoing, the Company's Directors and Employees are strictly prohibited from paying any bribe, kickback or other similar unlawful payment to, or otherwise entering into a sensitive transaction with, any public official, political party or official, candidate for public office or other individual, in any country, to secure any contract, concession or other favorable treatment for the Company. Company Directors and Employees who make such payments are subject to appropriate action by the Company, as well as the legal consequences of applicable Law.

2. The term "sensitive transactions" is commonly used to describe a broad range of corporate dealings that are generally considered to be either illegal, unethical, immoral or to reflect adversely on the integrity of management. The transactions are usually in the nature of kickbacks, bribes or payoffs made in order to influence favorably some decision affecting a company's business or for the personal gain of an individual. Any extraordinary payment made from Company funds, including extravagant entertainment or gifts of significant value, for the express purpose of obtaining or retaining business or unduly influencing some matter in favor of the Company could be considered a "sensitive payment". These payments may be considered to be bribes and may result in violation of applicable Law.

3. Sensitive transactions may result in violation of United States federal Laws such as domestic anti-bribery Laws, mail fraud and wire fraud statutes, anti-racketeering statutes and the Foreign Corrupt Practices Act (the "FCPA"), as well as state Laws or Laws of other countries in which a subsidiary company has operations. If violations occur, the Company and its officers and Directors as well as Employees directly involved may be subject to fines, imprisonment and civil litigation.
4. The Company is publicly owned and its common stock is registered and traded in accordance with United States federal securities Laws and with rules and regulations promulgated by the SEC. Therefore, the Company is subject to strict disclosure requirements and must disclose to the public all material information relating to its business affairs and financial condition and conduct which is deemed to reflect on the integrity of its management.

5. Sensitive payments may violate the FCPA which prohibits a company from corruptly offering or giving anything of value to: a foreign official, including any person acting in an official capacity for a foreign government or a public international organization; a foreign political party official or political party; or a candidate for foreign political office, in any such case, for the purpose of influencing any act or decision of these officials in their official capacity or in violation of their lawful duties or to secure any improper advantage in order to help a company obtain or retain business or direct business to any person. The FCPA also prohibits the offering or paying of anything of value to any person if it is known that all or part of the payment will be used for the above prohibited actions. For purposes of compliance with this Policy, employees of government-owned corporations are to be considered "foreign officials" and, subject to Policy paragraph 6, any payment to influence a matter in favor of the Company shall be prohibited.

6. The Company may be required to make facilitating or expediting payments to an official or employee of a government outside the United States, the purpose of which is to expedite or to secure the performance of routine governmental action by such government official or employee. Such facilitating payments may not be illegal under the FCPA and similar Laws of other countries. Nevertheless, it may be difficult to distinguish a legal facilitating payment from an illegal bribe, kickback or payoff. Accordingly, facilitating payments must be strictly controlled and every effort must be made to eliminate or minimize such payments. Facilitating payments, if required, will be made only in accordance with the advance guidance of the Law Department. Any facilitating payments must be recorded as such in the accounting records of the Company.
Falcetta's Role: 3-0006 - Commercial Bribery
Halliburton Company & Subsidiary Companies
CORPORATE POLICY

PURPOSE
This Policy prohibits the payment or transfer of Company funds or assets to suppliers or customers in the form of bribes, kickbacks or other payoffs and prohibits Company Directors, Employees and agents from participating in such schemes.

POLICY
1. The Company prohibits bribes, kickbacks and other payoffs and benefits to suppliers or customers.

2. The Company also prohibits Directors, Employees and agents from receiving, directly or indirectly from a third party, anything of a significant value (other than salary, wages or other ordinary compensation paid by the Company) in connection with a transaction entered into by the Company.

3. Bribes, kickbacks and payoffs include, but are not limited to:

a. gifts of other than nominal value;

b. cash payments by Directors, Employees or third persons, such as agents, suppliers, customers or consultants, who are reimbursed by the Company;

c. the uncompensated use of Company services, facilities or property except as may be authorized by the Company; and

d. loans, loan guarantees or other extensions of credit (except from lending institutions at prevailing rates). 3-0005 - Sensitive Transactions POLICY
1. The Company will conduct its business in compliance with applicable Law (See Corporate Policy 3-0001 with respect to conflicts between United States Law and the Law of another country) and requires all Company Directors and Employees to avoid any activities which could involve the Company in any unlawful practice. Without limiting the generality of the foregoing, the Company's Directors and Employees are strictly prohibited from paying any bribe, kickback or other similar unlawful payment to, or otherwise entering into a sensitive transaction with, any public official, political party or official, candidate for public office or other individual, in any country, to secure any contract, concession or other favorable treatment for the Company. Company Directors and Employees who make such payments are subject to appropriate action by the Company, as well as the legal consequences of applicable Law.

2. The term "sensitive transactions" is commonly used to describe a broad range of corporate dealings that are generally considered to be either illegal, unethical, immoral or to reflect adversely on the integrity of management. The transactions are usually in the nature of kickbacks, bribes or payoffs made in order to influence favorably some decision affecting a company's business or for the personal gain of an individual. Any extraordinary payment made from Company funds, including extravagant entertainment or gifts of significant value, for the express purpose of obtaining or retaining business or unduly influencing some matter in favor of the Company could be considered a "sensitive payment". These payments may be considered to be bribes and may result in violation of applicable Law.

3. Sensitive transactions may result in violation of United States federal Laws such as domestic anti-bribery Laws, mail fraud and wire fraud statutes, anti-racketeering statutes and the Foreign Corrupt Practices Act (the "FCPA"), as well as state Laws or Laws of other countries in which a subsidiary company has operations. If violations occur, the Company and its officers and Directors as well as Employees directly involved may be subject to fines, imprisonment and civil litigation.
3-0004 - Internal Accounting Controls, Procedures & Records POLICY
1. Authorization. The only transactions to be entered into by the Company are those which are executed in accordance with management's specific approval (as set forth in the following paragraph) or established, formalized policies and procedures.

2. Approval. No transaction will be recorded in the accounts of the Company unless it is within the scope of written policies and procedures or is specifically and formally approved by an appropriate and designated Employee. Such approval requires the determination that the transaction (i) has been authorized in accordance with this Corporate Policy and (ii) is supported by documentary evidence to verify the validity of the transaction.

3. Accounting. All transactions entered into by the Company will be recorded in the accounts of the Company in accordance with normal, standard procedures. Each entry will be coded into an account which accurately and fairly reflects the true nature of the transaction.

4. Reporting. All transactions that have been accounted for in accordance with this Corporate Policy will be accumulated and processed in a manner which will permit timely preparation of financial statements, reports and data for purposes of internal, public and regulatory reporting. Such statements, reports and data must be understandable and prepared in a form sufficient to reflect fully, accurately and fairly the results of transactions entered into by the Company and to permit proper accountability for assets.

5. Responsibility. The implementation and maintenance of internal accounting controls, procedures and records that are adequate in all respects to satisfy the requirements of this Corporate Policy will be the primary responsibility of the Chief Financial Officer.

6. Auditing. Compliance with the provisions and requirements of this Corporate Policy will be tested and evaluated by the Company's head of Audit Services in connection with the on-going internal audit program. All control failures regarding this Corporate Policy will be reported to management so that deficiencies can be corrected and assurance of compliance with the terms of this Corporate Policy maintained. 3-0015 - Defalcation, Misappropriation and Similar Irregularities (Fraud) POLICY
1. The Company prohibits all Fraud.
2. Directors and Employees are obligated to protect the Company's assets and ensure their efficient use. The theft, carelessness and waste of Company assets by Employees and Directors are prohibited since such actions and conduct have a direct and negative impact on the Company's profitability. All Company assets shall only be used for the legitimate business purposes of the Company.
3. The responsibility for detecting Fraud in the Company is that of management. The Chief Financial Officer bears the primary responsibility.
4. Situations involving suspected Fraud shall be reported to the Audit Services Department, the Security Department, the Chief Financial Officer or the Law Department. All Fraud investigations will be conducted under the authorization and direction of the Law Department.
5. The Company's head of Audit Services shall be notified of suspected significant Fraud (more than $50,000 of estimated loss), and any Fraud, whether material or not, that involves management or other employees who have a significant role in the Company's internal controls. The Company's head of Audit Services shall notify the Chief Executive Officer, the Chief Financial Officer and Audit Committee of any suspected Fraud involving management or other employees who have a significant role in the Company's internal controls and shall also notify the Audit Committee if it appears that there is any substance to the alleged Fraud.
6. Fraud involving more than $50,000 of estimated loss, and any Fraud, whether material or not, that involves management or other employees who have a significant role in the Company's internal controls, will be reported to the Audit Committee of the Board of Directors and the Chief Executive Officer and the Chief Financial Officer.
7. The Company's head of Audit Services, the General Counsel, the Chief Financial Officer and the Director of Business Conduct will maintain close liaison with each other and will participate in joint investigations as deemed appropriate under the circumstances.
POLICY
1. The Company prohibits all Fraud.

2. Directors and Employees are obligated to protect the Company's assets and ensure their efficient use. The theft, carelessness and waste of Company assets by Employees and Directors are prohibited since such actions and conduct have a direct and negative impact on the Company's profitability. All Company assets shall only be used for the legitimate business purposes of the Company.

3. The responsibility for detecting Fraud in the Company is that of management. The Chief Financial Officer bears the primary responsibility.

4. Situations involving suspected Fraud shall be reported to the Audit Services Department, the Security Department, the Chief Financial Officer or the Law Department. All Fraud investigations will be conducted under the authorization and direction of the Law Department.

5. The Company's head of Audit Services shall be notified of suspected significant Fraud (more than $50,000 of estimated loss), and any Fraud, whether material or not, that involves management or other employees who have a significant role in the Company's internal controls. The Company's head of Audit Services shall notify the Chief Executive Officer, the Chief Financial Officer and Audit Committee of any suspected Fraud involving management or other employees who have a significant role in the Company's internal controls and shall also notify the Audit Committee if it appears that there is any substance to the alleged Fraud.

6. Fraud involving more than $50,000 of estimated loss, and any Fraud, whether material or not, that involves management or other employees who have a significant role in the Company's internal controls, will be reported to the Audit Committee of the Board of Directors and the Chief Executive Officer and the Chief Financial Officer.

7. The Company's head of Audit Services, the General Counsel, the Chief Financial Officer and the Director of Business Conduct will maintain close liaison with each other and will participate in joint investigations as deemed appropriate under the circumstances.
3-0015 - Defalcation, Misappropriation and Similar Irregularities (Fraud) POLICY
1. The Company prohibits all Fraud.
2. Directors and Employees are obligated to protect the Company's assets and ensure their efficient use. The theft, carelessness and waste of Company assets by Employees and Directors are prohibited since such actions and conduct have a direct and negative impact on the Company's profitability. All Company assets shall only be used for the legitimate business purposes of the Company.
3. The responsibility for detecting Fraud in the Company is that of management. The Chief Financial Officer bears the primary responsibility.
4. Situations involving suspected Fraud shall be reported to the Audit Services Department, the Security Department, the Chief Financial Officer or the Law Department. All Fraud investigations will be conducted under the authorization and direction of the Law Department.
5. The Company's head of Audit Services shall be notified of suspected significant Fraud (more than $50,000 of estimated loss), and any Fraud, whether material or not, that involves management or other employees who have a significant role in the Company's internal controls. The Company's head of Audit Services shall notify the Chief Executive Officer, the Chief Financial Officer and Audit Committee of any suspected Fraud involving management or other employees who have a significant role in the Company's internal controls and shall also notify the Audit Committee if it appears that there is any substance to the alleged Fraud.
6. Fraud involving more than $50,000 of estimated loss, and any Fraud, whether material or not, that involves management or other employees who have a significant role in the Company's internal controls, will be reported to the Audit Committee of the Board of Directors and the Chief Executive Officer and the Chief Financial Officer.
7. The Company's head of Audit Services, the General Counsel, the Chief Financial Officer and the Director of Business Conduct will maintain close liaison with each other and will participate in joint investigations as deemed appropriate under the circumstances.
3-0015 - Defalcation, Misappropriation and Similar Irregularities (Fraud) A. Standards of Conduct.
It is the Company's policy to observe and comply with all Laws applicable to it or the conduct of its business wherever located. In some situations, the applicable Law of the United States may conflict with the applicable Law of another country. In such cases, the Company will endeavor to resolve such conflict following the guidance of its Law Department. Where such a conflict cannot be resolved, the applicable Law of the United States will be observed and complied with by the Company.

The Code of Business Conduct applies to agents of the Company as well as its Directors and Employees. However, in the case of agents whose activities are wholly outside the United States, Corporate Policy No. 3-0007 establishes the policies and procedures to be observed with respect to such agents.

The Code of Business Conduct sets forth specific Corporate Policies governing the conduct of the business of the Company. These policies were developed and are intended to be applied in good faith with reasonable business judgment to enable the Company to achieve its operating and financial goals within the framework of the Law.

It is the personal responsibility of each Director, Employee and agent of the Company to adhere to the standards and restrictions, whether imposed by Law or the Code of Business Conduct, applicable to his or her assigned duties and responsibilities and to conduct himself or herself accordingly. Such standards and restrictions require each Director, Employee and agent to avoid any activities which would involve the Company in any practice which is not in compliance with the Code of Business Conduct. Any Director, Employee or agent who does not adhere to such standards and restrictions is acting outside the scope of his or her employment, responsibilities or agency.

Beyond legal compliance, all Company Directors, Employees and agents are expected to observe high standards of business and personal ethics in the discharge of their assigned duties and responsibilities. This requires the practice of fair dealing, honesty and integrity by Directors and Employees in every aspect of dealing with other Company Employees, the public, the business community, shareholders, customers, suppliers, competitors and governmental and regulatory authorities. Directors and Employees when acting on behalf of the Company shall not take unfair advantage through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or other unfair-dealing practices. 3-0001 - General Policy Regarding Laws & Business Conduct 3-0001 - General Policy Regarding Laws & Business Conduct 1. honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships

2. full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company files with, or submits to, the SEC and in other public communications made by the Company

3. compliance with applicable governmental laws, rules and regulations

4. the prompt internal reporting of violations of the Code to an appropriate person or persons identified in the Code; and

5. accountability for adherence to the Code. 3-0001 - General Policy Regarding Laws & Business Conduct 3-0008 - Use and Public Disclosure of Material Nonpublic Information POLICY
1. This Policy applies to all Directors, Employees and agents of the Company without regard to nationality or country of residence. All Directors, Employees and agents of the Company must observe the prohibition on trading on material nonpublic information.

2. General Disclosure Policy. The Company will make prompt and complete disclosure of material nonpublic information to the public when and as required by Law and/or the rules of the SEC or the NYSE. Determinations regarding "materiality" involve subjective judgments; therefore, questions of materiality will be determined by the General Counsel and Chief Financial Officer. Any disclosures made by the Company in reports and documents filed with or submitted to the SEC and other public communications made by the Company shall be full, fair, accurate, timely and understandable. In furtherance of this Policy, the Company shall establish and maintain a Disclosure Committee and an Internal Controls Committee. Policy:

A. Standards of Conduct.
It is the Company's policy to observe and comply with all Laws applicable to it or the conduct of its business wherever located. In some situations, the applicable Law of the United States may conflict with the applicable Law of another country. In such cases, the Company will endeavor to resolve such conflict following the guidance of its Law Department. Where such a conflict cannot be resolved, the applicable Law of the United States will be observed and complied with by the Company.

The Code of Business Conduct applies to agents of the Company as well as its Directors and Employees. However, in the case of agents whose activities are wholly outside the United States, Corporate Policy No. 3-0007 establishes the policies and procedures to be observed with respect to such agents.

The Code of Business Conduct sets forth specific Corporate Policies governing the conduct of the business of the Company. These policies were developed and are intended to be applied in good faith with reasonable business judgment to enable the Company to achieve its operating and financial goals within the framework of the Law.

It is the personal responsibility of each Director, Employee and agent of the Company to adhere to the standards and restrictions, whether imposed by Law or the Code of Business Conduct, applicable to his or her assigned duties and responsibilities and to conduct himself or herself accordingly. Such standards and restrictions require each Director, Employee and agent to avoid any activities which would involve the Company in any practice which is not in compliance with the Code of Business Conduct. Any Director, Employee or agent who does not adhere to such standards and restrictions is acting outside the scope of his or her employment, responsibilities or agency.

Beyond legal compliance, all Company Directors, Employees and agents are expected to observe high standards of business and personal ethics in the discharge of their assigned duties and responsibilities. This requires the practice of fair dealing, honesty and integrity by Directors and Employees in every aspect of dealing with other Company Employees, the public, the business community, shareholders, customers, suppliers, competitors and governmental and regulatory authorities. Directors and Employees when acting on behalf of the Company shall not take unfair advantage through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or other unfair-dealing practices.
Policy:

A. Standards of Conduct.
It is the Company's policy to observe and comply with all Laws applicable to it or the conduct of its business wherever located. In some situations, the applicable Law of the United States may conflict with the applicable Law of another country. In such cases, the Company will endeavor to resolve such conflict following the guidance of its Law Department. Where such a conflict cannot be resolved, the applicable Law of the United States will be observed and complied with by the Company.

The Code of Business Conduct applies to agents of the Company as well as its Directors and Employees. However, in the case of agents whose activities are wholly outside the United States, Corporate Policy No. 3-0007 establishes the policies and procedures to be observed with respect to such agents.

The Code of Business Conduct sets forth specific Corporate Policies governing the conduct of the business of the Company. These policies were developed and are intended to be applied in good faith with reasonable business judgment to enable the Company to achieve its operating and financial goals within the framework of the Law.

It is the personal responsibility of each Director, Employee and agent of the Company to adhere to the standards and restrictions, whether imposed by Law or the Code of Business Conduct, applicable to his or her assigned duties and responsibilities and to conduct himself or herself accordingly. Such standards and restrictions require each Director, Employee and agent to avoid any activities which would involve the Company in any practice which is not in compliance with the Code of Business Conduct. Any Director, Employee or agent who does not adhere to such standards and restrictions is acting outside the scope of his or her employment, responsibilities or agency.

Beyond legal compliance, all Company Directors, Employees and agents are expected to observe high standards of business and personal ethics in the discharge of their assigned duties and responsibilities. This requires the practice of fair dealing, honesty and integrity by Directors and Employees in every aspect of dealing with other Company Employees, the public, the business community, shareholders, customers, suppliers, competitors and governmental and regulatory authorities. Directors and Employees when acting on behalf of the Company shall not take unfair advantage through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or other unfair-dealing practices.
3-0001 - General Policy Regarding Laws & Business Conduct 3-0003 - Conflicts of Interest POLICY 5. The Company shall have on file a statement of compliance from each key Employee who can direct or influence the use or disposition of any significant amount of funds or other assets of the Company. The disclosure of a financial or other beneficial interest does not mean that the Company will deem it significant or substantial enough to be prohibited. Each case will be decided on an individual basis.
6. While International Business Relationships are ordinarily customary means of conducting operations in a particular country, such arrangements, if not adequately subjected to a corporation's system of internal controls, may be used to disburse a corporation's assets for purposes not authorized by management. Moreover, the Company may be held accountable for actions taken by agents and others on its behalf. 3-0007- International Business Relationships POLICY 5. International Business Relationships do not include the following: 5. International Business Relationships do not include the following: 3-0007- International Business Relationships 6. While International Business Relationships are ordinarily customary means of conducting operations in a particular country, such arrangements, if not adequately subjected to a corporation's system of internal controls, may be used to disburse a corporation's assets for purposes not authorized by management. Moreover, the Company may be held accountable for actions taken by agents and others on its behalf.

7. In carrying out the policies set forth in Policy paragraphs 1 and 2, the Company shall give consideration to such matters as the reputation of the proposed parties to an International Business Relationship, their familial or other connections with the local government, the necessity of the services to be rendered by such persons, the reasonableness of their fees or other compensation in light of those services and the fees paid to other persons in the area for similar services, any local legal requirements to utilize an agent for such services, the employment of such persons by other corporations operating in the area, the employment of such persons by affiliates of the Company, the location at which, and the currency in which, fees or other compensation is to be paid to such persons, any local legal requirements, including taxes and foreign currency exchange controls, regarding the payment of fees or other compensation to such persons, and the business and cultural environment in which such persons will render such services. 3-0004 - Internal Accounting Controls, Procedures & Records
Halliburton Company & Subsidiary Companies
CORPORATE POLICY
PURPOSE
This Policy establishes guidelines and procedures related to keeping books and records that in reasonable detail accurately and fairly reflect the Company's transactions and dispositions of assets. The Company shall maintain a system of internal accounting controls to ensure reliability and adequacy of its books and records and proper recording of all transactions including dispositions of assets.
POLICY
1. Authorization. The only transactions to be entered into by the Company are those which are executed in accordance with management's specific approval (as set forth in the following paragraph) or established, formalized policies and procedures.

2. Approval. No transaction will be recorded in the accounts of the Company unless it is within the scope of written policies and procedures or is specifically and formally approved by an appropriate and designated Employee. Such approval requires the determination that the transaction (i) has been authorized in accordance with this Corporate Policy and (ii) is supported by documentary evidence to verify the validity of the transaction.

3. Accounting. All transactions entered into by the Company will be recorded in the accounts of the Company in accordance with normal, standard procedures. Each entry will be coded into an account which accurately and fairly reflects the true nature of the transaction.

4. Reporting. All transactions that have been accounted for in accordance with this Corporate Policy will be accumulated and processed in a manner which will permit timely preparation of financial statements, reports and data for purposes of internal, public and regulatory reporting. Such statements, reports and data must be understandable and prepared in a form sufficient to reflect fully, accurately and fairly the results of transactions entered into by the Company and to permit proper accountability for assets.

5. Responsibility. The implementation and maintenance of internal accounting controls, procedures and records that are adequate in all respects to satisfy the requirements of this Corporate Policy will be the primary responsibility of the Chief Financial Officer.

6. Auditing. Compliance with the provisions and requirements of this Corporate Policy will be tested and evaluated by the Company's head of Audit Services in connection with the on-going internal audit program. All control failures regarding this Corporate Policy will be reported to management so that deficiencies can be corrected and assurance of compliance with the terms of this Corporate Policy maintained.

PROCEDURE
1. The Company will continuously evaluate its internal accounting controls, procedures and records to ensure compliance with the requirements of this Corporate Policy. Such evaluation will be documented in a form suitable for inspection by outside parties, such as regulatory authorities, if the need arises.

2. The Company will take action to remedy any deficiency in internal accounting controls, procedures and records to ensure continuing compliance with the requirements of this Corporate Policy. 3-0001 - General Policy Regarding Laws & Business Conduct
Halliburton Company & Subsidiary Companies
CORPORATE POLICY
PURPOSE
The Code of Business Conduct of Halliburton Company contains the specific Corporate Policies adopted by the Board of Directors that relate to the legal and ethical standards of conduct of Directors, Employees and agents of the Company. The Corporate Policies listed in the index set forth in Corporate Policy 3-0000 constitute the Code of Business Conduct and govern the conduct of business by the Company.

The purpose of this General Policy Regarding Laws and Business Conduct is to provide a general statement regarding the Company's expectations as to the legal and ethical nature of conduct of the Company's Directors, Employees and agents while acting on the Company's behalf and to provide for the administration of the Company's Code of Business Conduct.

This Corporate Policy 3-0001 is intended to enhance the qualifications of the Code of Business Conduct as a program that, under the United States Sentencing Guidelines, is reasonably designed, implemented and enforced so as to be generally effective in preventing and detecting criminal conduct, and that promotes an organizational culture that encourages ethical conduct and a commitment to compliance with the law.

Moreover, this Code of Business Conduct applies to the Company's principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions. The Company believes that this Code of Business Conduct exceeds the requirements of the definition of a "Code of Ethics" as set forth in the regulations of the United States Securities and Exchange Commission ("SEC") issued pursuant to Section 406 of the Sarbanes-Oxley Act of 2002. However, for purposes of clarity and to ensure compliance with Section 406, this Code of Business Conduct as it applies to these listed officers is designed to deter wrongdoing and promote:

1. honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships

2. full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company files with, or submits to, the SEC and in other public communications made by the Company

3. compliance with applicable governmental laws, rules and regulations

4. the prompt internal reporting of violations of the Code to an appropriate person or persons identified in the Code; and

5. accountability for adherence to the Code. 3-0004 - Internal Accounting Controls, Procedures & Records
Halliburton Company & Subsidiary Companies
CORPORATE POLICY
PURPOSE
This Policy establishes guidelines and procedures related to keeping books and records that in reasonable detail accurately and fairly reflect the Company's transactions and dispositions of assets. The Company shall maintain a system of internal accounting controls to ensure reliability and adequacy of its books and records and proper recording of all transactions including dispositions of assets.

POLICY
1. Authorization. The only transactions to be entered into by the Company are those which are executed in accordance with management's specific approval (as set forth in the following paragraph) or established, formalized policies and procedures.

2. Approval. No transaction will be recorded in the accounts of the Company unless it is within the scope of written policies and procedures or is specifically and formally approved by an appropriate and designated Employee. Such approval requires the determination that the transaction (i) has been authorized in accordance with this Corporate Policy and (ii) is supported by documentary evidence to verify the validity of the transaction.

3. Accounting. All transactions entered into by the Company will be recorded in the accounts of the Company in accordance with normal, standard procedures. Each entry will be coded into an account which accurately and fairly reflects the true nature of the transaction.

4. Reporting. All transactions that have been accounted for in accordance with this Corporate Policy will be accumulated and processed in a manner which will permit timely preparation of financial statements, reports and data for purposes of internal, public and regulatory reporting. Such statements, reports and data must be understandable and prepared in a form sufficient to reflect fully, accurately and fairly the results of transactions entered into by the Company and to permit proper accountability for assets. 3-0006 - Commercial Bribery
Halliburton Company & Subsidiary Companies
CORPORATE POLICY
PURPOSE
This Policy prohibits the payment or transfer of Company funds or assets to suppliers or customers in the form of bribes, kickbacks or other payoffs and prohibits Company Directors, Employees and agents from participating in such schemes.

POLICY
1. The Company prohibits bribes, kickbacks and other payoffs and benefits to suppliers or customers.

2. The Company also prohibits Directors, Employees and agents from receiving, directly or indirectly from a third party, anything of a significant value (other than salary, wages or other ordinary compensation paid by the Company) in connection with a transaction entered into by the Company. 3-0004 - Internal Accounting Controls, Procedures & Records
Halliburton Company & Subsidiary Companies
CORPORATE POLICY
PURPOSE
This Policy establishes guidelines and procedures related to keeping books and records that in reasonable detail accurately and fairly reflect the Company's transactions and dispositions of assets. The Company shall maintain a system of internal accounting controls to ensure reliability and adequacy of its books and records and proper recording of all transactions including dispositions of assets.

POLICY
1. Authorization. The only transactions to be entered into by the Company are those which are executed in accordance with management's specific approval (as set forth in the following paragraph) or established, formalized policies and procedures.

2. Approval. No transaction will be recorded in the accounts of the Company unless it is within the scope of written policies and procedures or is specifically and formally approved by an appropriate and designated Employee. Such approval requires the determination that the transaction (i) has been authorized in accordance with this Corporate Policy and (ii) is supported by documentary evidence to verify the validity of the transaction.

3. Accounting. All transactions entered into by the Company will be recorded in the accounts of the Company in accordance with normal, standard procedures. Each entry will be coded into an account which accurately and fairly reflects the true nature of the transaction.

4. Reporting. All transactions that have been accounted for in accordance with this Corporate Policy will be accumulated and processed in a manner which will permit timely preparation of financial statements, reports and data for purposes of internal, public and regulatory reporting. Such statements, reports and data must be understandable and prepared in a form sufficient to reflect fully, accurately and fairly the results of transactions entered into by the Company and to permit proper accountability for assets.

5. Responsibility. The implementation and maintenance of internal accounting controls, procedures and records that are adequate in all respects to satisfy the requirements of this Corporate Policy will be the primary responsibility of the Chief Financial Officer.

6. Auditing. Compliance with the provisions and requirements of this Corporate Policy will be tested and evaluated by the Company's head of Audit Services in connection with the on-going internal audit program. All control failures regarding this Corporate Policy will be reported to management so that deficiencies can be corrected and assurance of compliance with the terms of this Corporate Policy maintained. 3-0006 - Commercial Bribery
Halliburton Company & Subsidiary Companies
CORPORATE POLICY


Date: May 21, 2003
Index No.: 3-0006

PURPOSE
This Policy prohibits the payment or transfer of Company funds or assets to suppliers or customers in the form of bribes, kickbacks or other payoffs and prohibits Company Directors, Employees and agents from participating in such schemes.

POLICY
1. The Company prohibits bribes, kickbacks and other payoffs and benefits to suppliers or customers.

2. The Company also prohibits Directors, Employees and agents from receiving, directly or indirectly from a third party, anything of a significant value (other than salary, wages or other ordinary compensation paid by the Company) in connection with a transaction entered into by the Company.
3-0005 - Sensitive Transactions
Halliburton Company & Subsidiary Companies
CORPORATE POLICY
PURPOSE
This Policy advises Directors, Employees and agents of the Company's position regarding sensitive transactions and requires that transactions are executed, and access to assets is permitted, only in accordance with management's authorization.

POLICY
1. The Company will conduct its business in compliance with applicable Law (See Corporate Policy 3-0001 with respect to conflicts between United States Law and the Law of another country) and requires all Company Directors and Employees to avoid any activities which could involve the Company in any unlawful practice. Without limiting the generality of the foregoing, the Company's Directors and Employees are strictly prohibited from paying any bribe, kickback or other similar unlawful payment to, or otherwise entering into a sensitive transaction with, any public official, political party or official, candidate for public office or other individual, in any country, to secure any contract, concession or other favorable treatment for the Company. Company Directors and Employees who make such payments are subject to appropriate action by the Company, as well as the legal consequences of applicable Law.

2. The term "sensitive transactions" is commonly used to describe a broad range of corporate dealings that are generally considered to be either illegal, unethical, immoral or to reflect adversely on the integrity of management. The transactions are usually in the nature of kickbacks, bribes or payoffs made in order to influence favorably some decision affecting a company's business or for the personal gain of an individual. Any extraordinary payment made from Company funds, including extravagant entertainment or gifts of significant value, for the express purpose of obtaining or retaining business or unduly influencing some matter in favor of the Company could be considered a "sensitive payment". These payments may be considered to be bribes and may result in violation of applicable Law.

3. Sensitive transactions may result in violation of United States federal Laws such as domestic anti-bribery Laws, mail fraud and wire fraud statutes, anti-racketeering statutes and the Foreign Corrupt Practices Act (the "FCPA"), as well as state Laws or Laws of other countries in which a subsidiary company has operations. If violations occur, the Company and its officers and Directors as well as Employees directly involved may be subject to fines, imprisonment and civil litigation. 3-0012 - Political Contributions
Halliburton Company & Subsidiary Companies
CORPORATE POLICY
PURPOSE
The Company encourages participation in the political process by its Employees. The United States federal government, some states and some other countries have, however, enacted Laws regulating campaign contributions in order to limit the political influence of certain types of contributors, such as corporations. This Policy sets forth certain rules regarding Company and Employee contributions to political candidates and participation in political campaigns.

POLICY
1. The Company will comply with applicable Laws regulating political influence and campaign contributions.

2. The Company believes strongly in the democratic political process and that its Directors, Employees and agents should take an active interest in fostering principles of good government in the nations, states and communities in which they live. Directors and Employees may spend their own time and funds supporting political candidates and issues but they will not be reimbursed by the Company in any way for such time or their funds used for political contributions. Directors and Employees are urged to be sure that their personal political contributions and activities are in compliance with applicable Law. For example, persons who are not United States citizens are not permitted to make political contributions to candidates in federal, state or local elections in the United States. Other countries also have Laws regulating political contributions.

3. No Director, Employee or agent shall apply any pressure, direct or implied, on any other Employee that infringes upon an individual's right to decide whether, to whom and in what amount a personal political contribution is to be made.

4. Directors, Employees and agents who represent the Company in political and governmental matters must comply with all Laws that regulate corporate participation in public affairs. Under various statutes, certain conduct, which is permitted and encouraged for individuals, is prohibited on the part of corporations. It is the Company's policy to comply fully with these prohibitions.

5. The Company is legally prohibited from contributing directly or indirectly in support of political candidates for elective federal office in the United States and is similarly prohibited from making such contributions in certain states and other countries. Indirect expenditures on behalf of a candidate, such as travel on Company aircraft, may be considered as contributions in this regard.

6. No political contribution of Company funds, property or services can be made by the Company, or in the name of the Company, except in accordance with a plan approved by the Chief Executive Officer or his or her designee. Such approval is subject to assurance by the Law Department that such contribution is legal and proper under applicable Laws and regulations. 3-0012 - Political Contributions
Halliburton Company & Subsidiary Companies
CORPORATE POLICY
PURPOSE
The Company encourages participation in the political process by its Employees. The United States federal government, some states and some other countries have, however, enacted Laws regulating campaign contributions in order to limit the political influence of certain types of contributors, such as corporations. This Policy sets forth certain rules regarding Company and Employee contributions to political candidates and participation in political campaigns.

POLICY
1. The Company will comply with applicable Laws regulating political influence and campaign contributions.

2. The Company believes strongly in the democratic political process and that its Directors, Employees and agents should take an active interest in fostering principles of good government in the nations, states and communities in which they live. Directors and Employees may spend their own time and funds supporting political candidates and issues but they will not be reimbursed by the Company in any way for such time or their funds used for political contributions. Directors and Employees are urged to be sure that their personal political contributions and activities are in compliance with applicable Law. For example, persons who are not United States citizens are not permitted to make political contributions to candidates in federal, state or local elections in the United States. Other countries also have Laws regulating political contributions.

3. No Director, Employee or agent shall apply any pressure, direct or implied, on any other Employee that infringes upon an individual's right to decide whether, to whom and in what amount a personal political contribution is to be made.

4. Directors, Employees and agents who represent the Company in political and governmental matters must comply with all Laws that regulate corporate participation in public affairs. Under various statutes, certain conduct, which is permitted and encouraged for individuals, is prohibited on the part of corporations. It is the Company's policy to comply fully with these prohibitions.

5. The Company is legally prohibited from contributing directly or indirectly in support of political candidates for elective federal office in the United States and is similarly prohibited from making such contributions in certain states and other countries. Indirect expenditures on behalf of a candidate, such as travel on Company aircraft, may be considered as contributions in this regard.

6. No political contribution of Company funds, property or services can be made by the Company, or in the name of the Company, except in accordance with a plan approved by the Chief Executive Officer or his or her designee. Such approval is subject to assurance by the Law Department that such contribution is legal and proper under applicable Laws and regulations.
3-0001 - General Policy Regarding Laws & Business Conduct
Halliburton Company & Subsidiary Companies
CORPORATE POLICY

PURPOSE
The Code of Business Conduct of Halliburton Company contains the specific Corporate Policies adopted by the Board of Directors that relate to the legal and ethical standards of conduct of Directors, Employees and agents of the Company. The Corporate Policies listed in the index set forth in Corporate Policy 3-0000 constitute the Code of Business Conduct and govern the conduct of business by the Company.

The purpose of this General Policy Regarding Laws and Business Conduct is to provide a general statement regarding the Company's expectations as to the legal and ethical nature of conduct of the Company's Directors, Employees and agents while acting on the Company's behalf and to provide for the administration of the Company's Code of Business Conduct.

This Corporate Policy 3-0001 is intended to enhance the qualifications of the Code of Business Conduct as a program that, under the United States Sentencing Guidelines, is reasonably designed, implemented and enforced so as to be generally effective in preventing and detecting criminal conduct, and that promotes an organizational culture that encourages ethical conduct and a commitment to compliance with the law.

Moreover, this Code of Business Conduct applies to the Company's principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions. The Company believes that this Code of Business Conduct exceeds the requirements of the definition of a "Code of Ethics" as set forth in the regulations of the United States Securities and Exchange Commission ("SEC") issued pursuant to Section 406 of the Sarbanes-Oxley Act of 2002. However, for purposes of clarity and to ensure compliance with Section 406, this Code of Business Conduct as it applies to these listed officers is designed to deter wrongdoing and promote:

1. honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships

2. full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company files with, or submits to, the SEC and in other public communications made by the Company

3. compliance with applicable governmental laws, rules and regulations

4. the prompt internal reporting of violations of the Code to an appropriate person or persons identified in the Code; and

5. accountability for adherence to the Code.
3-0001 - General Policy Regarding Laws & Business Conduct
Halliburton Company & Subsidiary Companies
CORPORATE POLICY

PURPOSE
The Code of Business Conduct of Halliburton Company contains the specific Corporate Policies adopted by the Board of Directors that relate to the legal and ethical standards of conduct of Directors, Employees and agents of the Company. The Corporate Policies listed in the index set forth in Corporate Policy 3-0000 constitute the Code of Business Conduct and govern the conduct of business by the Company.

The purpose of this General Policy Regarding Laws and Business Conduct is to provide a general statement regarding the Company's expectations as to the legal and ethical nature of conduct of the Company's Directors, Employees and agents while acting on the Company's behalf and to provide for the administration of the Company's Code of Business Conduct.

This Corporate Policy 3-0001 is intended to enhance the qualifications of the Code of Business Conduct as a program that, under the United States Sentencing Guidelines, is reasonably designed, implemented and enforced so as to be generally effective in preventing and detecting criminal conduct, and that promotes an organizational culture that encourages ethical conduct and a commitment to compliance with the law.

Moreover, this Code of Business Conduct applies to the Company's principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions. The Company believes that this Code of Business Conduct exceeds the requirements of the definition of a "Code of Ethics" as set forth in the regulations of the United States Securities and Exchange Commission ("SEC") issued pursuant to Section 406 of the Sarbanes-Oxley Act of 2002. However, for purposes of clarity and to ensure compliance with Section 406, this Code of Business Conduct as it applies to these listed officers is designed to deter wrongdoing and promote:

1. honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships

2. full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company files with, or submits to, the SEC and in other public communications made by the Company

3. compliance with applicable governmental laws, rules and regulations

4. the prompt internal reporting of violations of the Code to an appropriate person or persons identified in the Code; and

5. accountability for adherence to the Code.
3-0001 - General Policy Regarding Laws & Business Conduct
Halliburton Company & Subsidiary Companies
CORPORATE POLICY


Date: December 3, 2008
Index No.: 3-0001

PURPOSE
The Code of Business Conduct of Halliburton Company contains the specific Corporate Policies adopted by the Board of Directors that relate to the legal and ethical standards of conduct of Directors, Employees and agents of the Company. The Corporate Policies listed in the index set forth in Corporate Policy 3-0000 constitute the Code of Business Conduct and govern the conduct of business by the Company.

The purpose of this General Policy Regarding Laws and Business Conduct is to provide a general statement regarding the Company's expectations as to the legal and ethical nature of conduct of the Company's Directors, Employees and agents while acting on the Company's behalf and to provide for the administration of the Company's Code of Business Conduct.

This Corporate Policy 3-0001 is intended to enhance the qualifications of the Code of Business Conduct as a program that, under the United States Sentencing Guidelines, is reasonably designed, implemented and enforced so as to be generally effective in preventing and detecting criminal conduct, and that promotes an organizational culture that encourages ethical conduct and a commitment to compliance with the law.

Moreover, this Code of Business Conduct applies to the Company's principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions. The Company believes that this Code of Business Conduct exceeds the requirements of the definition of a "Code of Ethics" as set forth in the regulations of the United States Securities and Exchange Commission ("SEC") issued pursuant to Section 406 of the Sarbanes-Oxley Act of 2002. However, for purposes of clarity and to ensure compliance with Section 406, this Code of Business Conduct as it applies to these listed officers is designed to deter wrongdoing and promote:

1. honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships

2. full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company files with, or submits to, the SEC and in other public communications made by the Company

3. compliance with applicable governmental laws, rules and regulations

4. the prompt internal reporting of violations of the Code to an appropriate person or persons identified in the Code; and

5. accountability for adherence to the Code.
3-0006 - Commercial Bribery
Halliburton Company & Subsidiary Companies
CORPORATE POLICY
PURPOSE
This Policy prohibits the payment or transfer of Company funds or assets to suppliers or customers in the form of bribes, kickbacks or other payoffs and prohibits Company Directors, Employees and agents from participating in such schemes.

POLICY
1. The Company prohibits bribes, kickbacks and other payoffs and benefits to suppliers or customers.

2. The Company also prohibits Directors, Employees and agents from receiving, directly or indirectly from a third party, anything of a significant value (other than salary, wages or other ordinary compensation paid by the Company) in connection with a transaction entered into by the Company.

3. Bribes, kickbacks and payoffs include, but are not limited to:

a. gifts of other than nominal value;

b. cash payments by Directors, Employees or third persons, such as agents, suppliers, customers or consultants, who are reimbursed by the Company;

c. the uncompensated use of Company services, facilities or property except as may be authorized by the Company; and

d. loans, loan guarantees or other extensions of credit (except from lending institutions at prevailing rates). 3-0004 - Internal Accounting Controls, Procedures & Records
Halliburton Company & Subsidiary Companies
CORPORATE POLICY
PURPOSE
This Policy establishes guidelines and procedures related to keeping books and records that in reasonable detail accurately and fairly reflect the Company's transactions and dispositions of assets. The Company shall maintain a system of internal accounting controls to ensure reliability and adequacy of its books and records and proper recording of all transactions including dispositions of assets.

POLICY
1. Authorization. The only transactions to be entered into by the Company are those which are executed in accordance with management's specific approval (as set forth in the following paragraph) or established, formalized policies and procedures.

2. Approval. No transaction will be recorded in the accounts of the Company unless it is within the scope of written policies and procedures or is specifically and formally approved by an appropriate and designated Employee. Such approval requires the determination that the transaction (i) has been authorized in accordance with this Corporate Policy and (ii) is supported by documentary evidence to verify the validity of the transaction. 3-0004 - Internal Accounting Controls, Procedures & Records
Halliburton Company & Subsidiary Companies
CORPORATE POLICY
PURPOSE
This Policy establishes guidelines and procedures related to keeping books and records that in reasonable detail accurately and fairly reflect the Company's transactions and dispositions of assets. The Company shall maintain a system of internal accounting controls to ensure reliability and adequacy of its books and records and proper recording of all transactions including dispositions of assets.

POLICY
1. Authorization. The only transactions to be entered into by the Company are those which are executed in accordance with management's specific approval (as set forth in the following paragraph) or established, formalized policies and procedures.

2. Approval. No transaction will be recorded in the accounts of the Company unless it is within the scope of written policies and procedures or is specifically and formally approved by an appropriate and designated Employee. Such approval requires the determination that the transaction (i) has been authorized in accordance with this Corporate Policy and (ii) is supported by documentary evidence to verify the validity of the transaction.

3. Accounting. All transactions entered into by the Company will be recorded in the accounts of the Company in accordance with normal, standard procedures. Each entry will be coded into an account which accurately and fairly reflects the true nature of the transaction. 3-0015 - Defalcation, Misappropriation and Similar Irregularities (Fraud)
Halliburton Company & Subsidiary Companies
CORPORATE POLICY

PURPOSE
This Policy establishes and communicates the Company's policy regarding the prohibition, recognition, reporting and investigation of suspected fraud, defalcation, misappropriation and other similar irregularities.

DEFINITIONS
The term "Fraud" as used in this Policy includes, but is not limited to, defalcation, misappropriation and other irregularities including such things as any:
• dishonest or fraudulent act;
• defalcation;
• embezzlement;
• forgery or alteration of negotiable instruments such as Company checks and drafts;
• misappropriation of Company, Employee, customer, partner or supplier assets;
• conversion to personal use of cash, securities, supplies or any other Company asset;
• unauthorized handling or reporting of Company transactions; and
• falsification of Company records or financial statements for personal or other reasons. 3-0015 - Defalcation, Misappropriation and Similar Irregularities (Fraud)
Halliburton Company & Subsidiary Companies
CORPORATE POLICY

PURPOSE
This Policy establishes and communicates the Company's policy regarding the prohibition, recognition, reporting and investigation of suspected fraud, defalcation, misappropriation and other similar irregularities.

DEFINITIONS
The term "Fraud" as used in this Policy includes, but is not limited to, defalcation, misappropriation and other irregularities including such things as any:
• dishonest or fraudulent act;
• defalcation;
• embezzlement;
• forgery or alteration of negotiable instruments such as Company checks and drafts;
• misappropriation of Company, Employee, customer, partner or supplier assets;
• conversion to personal use of cash, securities, supplies or any other Company asset;
• unauthorized handling or reporting of Company transactions; and
• falsification of Company records or financial statements for personal or other reasons. 3-0004 - Internal Accounting Controls, Procedures & Records
Halliburton Company & Subsidiary Companies
CORPORATE POLICY

PURPOSE
This Policy establishes guidelines and procedures related to keeping books and records that in reasonable detail accurately and fairly reflect the Company's transactions and dispositions of assets. The Company shall maintain a system of internal accounting controls to ensure reliability and adequacy of its books and records and proper recording of all transactions including dispositions of assets.
POLICY
1. Authorization. The only transactions to be entered into by the Company are those which are executed in accordance with management's specific approval (as set forth in the following paragraph) or established, formalized policies and procedures.
2. Approval. No transaction will be recorded in the accounts of the Company unless it is within the scope of written policies and procedures or is specifically and formally approved by an appropriate and designated Employee. Such approval requires the determination that the transaction (i) has been authorized in accordance with this Corporate Policy and (ii) is supported by documentary evidence to verify the validity of the transaction.
3. Accounting. All transactions entered into by the Company will be recorded in the accounts of the Company in accordance with normal, standard procedures. Each entry will be coded into an account which accurately and fairly reflects the true nature of the transaction.
4. Reporting. All transactions that have been accounted for in accordance with this Corporate Policy will be accumulated and processed in a manner which will permit timely preparation of financial statements, reports and data for purposes of internal, public and regulatory reporting. Such statements, reports and data must be understandable and prepared in a form sufficient to reflect fully, accurately and fairly the results of transactions entered into by the Company and to permit proper accountability for assets.
5. Responsibility. The implementation and maintenance of internal accounting controls, procedures and records that are adequate in all respects to satisfy the requirements of this Corporate Policy will be the primary responsibility of the Chief Financial Officer.
6. Auditing. Compliance with the provisions and requirements of this Corporate Policy will be tested and evaluated by the Company's head of Audit Services in connection with the on-going internal audit program. All control failures regarding this Corporate Policy will be reported to management so that deficiencies can be corrected and assurance of compliance with the terms of this Corporate Policy maintained.
PROCEDURE
1. The Company will continuously evaluate its internal accounting controls, procedures and records to ensure compliance with the requirements of this Corporate Policy. Such evaluation will be documented in a form suitable for inspection by outside parties, such as regulatory authorities, if the need arises.
2. The Company will take action to remedy any deficiency in internal accounting controls, procedures and records to ensure continuing compliance with the requirements of this Corporate Policy.
3. The audit services staff, in coordination with the Company's head of Audit Services, will ascertain that its audit scope, procedures and programs are adequate (i) for the purpose of testing and evaluating internal accounting controls, procedures and records and (ii) for complete reporting of deficiencies in internal accounting controls, procedures and records.
4. On or before March 31 of each year, the Chief Financial Officer and the Company's head of Audit Services will prepare a written summary applicable to the preceding fiscal year which sets forth financial management's evaluation of the Company's internal accounting controls, procedures and records. Such a summary will consider financial management's overall evaluation and results of audits performed during the year, internal and external. For deficiencies noted in the evaluation, remedial action in progress or contemplated will be set forth in the summary. The summary will be addressed to the Audit Committee of the Board of Directors.
5. The Company's head of Audit Services will, on an annual basis, report to the Audit Committee of the Board of Directors on the adequacy of internal accounting controls, procedures and records.

OTHER REFERENCES
1. Corporate Policy 3-02370 (Approvals for Investments, Acquisitions and Dispositions, and Significant Contracts) or its successor Policy should be consulted. POLICY
1. This Policy applies to all Directors, Employees and agents of the Company without regard to nationality or country of residence. All Directors, Employees and agents of the Company must observe the prohibition on trading on material nonpublic information.

2. General Disclosure Policy. The Company will make prompt and complete disclosure of material nonpublic information to the public when and as required by Law and/or the rules of the SEC or the NYSE. Determinations regarding "materiality" involve subjective judgments; therefore, questions of materiality will be determined by the General Counsel and Chief Financial Officer. Any disclosures made by the Company in reports and documents filed with or submitted to the SEC and other public communications made by the Company shall be full, fair, accurate, timely and understandable. In furtherance of this Policy, the Company shall establish and maintain a Disclosure Committee and an Internal Controls Committee.

3. Trading While in Possession of Material Nonpublic Information.

Nondisclosure. Material nonpublic information must not be disclosed to anyone other than persons within the Company whose positions require them to know the information until it has been publicly released by the Company.

Trading in Company Securities. No Director, Employee or agent shall place a purchase or sale order, or recommend that another person place a purchase or sale order, in the Company's securities (or related derivative securities, such as put or call options) when he or she has knowledge of material information concerning the Company that has not been disclosed to the public. Any Director, Employee or agent who possesses material nonpublic information shall wait until the end of business on the second business day after the information has been publicly released before trading or recommending that others trade.

Speculation. The Company discourages Directors, Employees and agents from speculating in Company securities. The Company does encourage its Directors and Employees to invest in Company securities, but investing means buying to share in the growth of the Company; it does not mean short term speculation based on fluctuations in the market.

Trading in Other Securities. No Director, Employee or agent shall place a purchase or sale order, or recommend that another person place a purchase or sale order, in the securities of another company (or related derivative securities, such as put or call options) if the Director, Employee or agent learns in the course of his or her position or employment confidential information about the other company that is likely to affect the value of those securities. For example, it would be a violation of this Policy and Law if an Employee learned through Company sources that the Company intended to purchase assets from another company, and then bought or sold stock in that other company because of the likely increase or decrease in the value of its securities. 3-0015 - Defalcation, Misappropriation and Similar Irregularities (Fraud)
Halliburton Company & Subsidiary Companies
CORPORATE POLICY


Date: December 3, 2008
Index No.: 3-0015

PURPOSE
This Policy establishes and communicates the Company's policy regarding the prohibition, recognition, reporting and investigation of suspected fraud, defalcation, misappropriation and other similar irregularities.

DEFINITIONS
The term "Fraud" as used in this Policy includes, but is not limited to, defalcation, misappropriation and other irregularities including such things as any:
• dishonest or fraudulent act;
• defalcation;
• embezzlement;
• forgery or alteration of negotiable instruments such as Company checks and drafts;
• misappropriation of Company, Employee, customer, partner or supplier assets;
• conversion to personal use of cash, securities, supplies or any other Company asset;
• unauthorized handling or reporting of Company transactions; and
• falsification of Company records or financial statements for personal or other reasons.

The above list is not all-inclusive but is intended to be representative of situations involving fraud. Fraud may be perpetrated not only by Company Employees, but by agents and other outside parties as well. All such situations require specific action by the Company. 3-0003 - Conflicts of Interest
Halliburton Company & Subsidiary Companies
CORPORATE POLICY

PURPOSE
This Policy establishes guidelines and procedures regarding timely and proper disclosure of possible conflicts of interests which an Employee or Director may have in connection with job duties and responsibilities in order that management may review and approve each situation as necessary to protect the best interests of the Company and its responsibilities as a public company.

POLICY
1. The Company prohibits conflicts of interest unless specifically approved by the Chief Executive Officer or his or her designee as provided below since Directors and Employees have a duty to the Company to advance the Company's legitimate interests when the opportunity to do so arises.

2. The Company has always been concerned with outside business interests of its Directors and Employees that might possibly conflict with the interests of the Company. An adequate definition of what constitutes a conflict of interest is most difficult. However, the Company expects and requires Directors and Employees to be honest and ethical in the handling of actual or apparent conflicts of interest between personal and business relationships. The minimum standard is that required by law.

There are certain situations which the Company will always consider to be conflicts of interest. These occur if the Director or Employee, or any other person having a close personal relationship with the Director or Employee:

a. obtains a significant financial or other beneficial interest in one of the Company's suppliers, customers or competitors without first notifying the Company and obtaining written approval from the Chief Executive Officer or his or her designee;

b. engages in a significant personal business transaction involving the Company for profit or gain, unless such transaction has first been approved in writing by the Chief Executive Officer or his or her designee;

c. accepts money, gifts of other than nominal value, excessive hospitality, loans, guarantees of obligations or other special treatment from any supplier, customer or competitor of the Company (loans from lending institutions at prevailing interest rates are excluded);

d. participates in any sale, loan or gift of Company property without obtaining written approval from the Chief Executive Officer or his or her designee;

e. learns of a business opportunity through association with the Company and discloses it to a third party or invests in or takes the opportunity personally without first offering it to the Company.

f. uses corporate property, information, or position for personal gain; or

g. competes with the Company.
3-0005 - Sensitive Transactions
Halliburton Company & Subsidiary Companies
CORPORATE POLICY

PURPOSE
This Policy advises Directors, Employees and agents of the Company's position regarding sensitive transactions and requires that transactions are executed, and access to assets is permitted, only in accordance with management's authorization.

POLICY
1. The Company will conduct its business in compliance with applicable Law (See Corporate Policy 3-0001 with respect to conflicts between United States Law and the Law of another country) and requires all Company Directors and Employees to avoid any activities which could involve the Company in any unlawful practice. Without limiting the generality of the foregoing, the Company's Directors and Employees are strictly prohibited from paying any bribe, kickback or other similar unlawful payment to, or otherwise entering into a sensitive transaction with, any public official, political party or official, candidate for public office or other individual, in any country, to secure any contract, concession or other favorable treatment for the Company. Company Directors and Employees who make such payments are subject to appropriate action by the Company, as well as the legal consequences of applicable Law.

2. The term "sensitive transactions" is commonly used to describe a broad range of corporate dealings that are generally considered to be either illegal, unethical, immoral or to reflect adversely on the integrity of management. The transactions are usually in the nature of kickbacks, bribes or payoffs made in order to influence favorably some decision affecting a company's business or for the personal gain of an individual. Any extraordinary payment made from Company funds, including extravagant entertainment or gifts of significant value, for the express purpose of obtaining or retaining business or unduly influencing some matter in favor of the Company could be considered a "sensitive payment". These payments may be considered to be bribes and may result in violation of applicable Law.

3. Sensitive transactions may result in violation of United States federal Laws such as domestic anti-bribery Laws, mail fraud and wire fraud statutes, anti-racketeering statutes and the Foreign Corrupt Practices Act (the "FCPA"), as well as state Laws or Laws of other countries in which a subsidiary company has operations. If violations occur, the Company and its officers and Directors as well as Employees directly involved may be subject to fines, imprisonment and civil litigation.

4. The Company is publicly owned and its common stock is registered and traded in accordance with United States federal securities Laws and with rules and regulations promulgated by the SEC. Therefore, the Company is subject to strict disclosure requirements and must disclose to the public all material information relating to its business affairs and financial condition and conduct which is deemed to reflect on the integrity of its management.

5. Sensitive payments may violate the FCPA which prohibits a company from corruptly offering or giving anything of value to: a foreign official, including any person acting in an official capacity for a foreign government or a public international organization; a foreign political party official or political party; or a candidate for foreign political office, in any such case, for the purpose of influencing any act or decision of these officials in their official capacity or in violation of their lawful duties or to secure any improper advantage in order to help a company obtain or retain business or direct business to any person. The FCPA also prohibits the offering or paying of anything of value to any person if it is known that all or part of the payment will be used for the above prohibited actions. For purposes of compliance with this Policy, employees of government-owned corporations are to be considered "foreign officials" and, subject to Policy paragraph 6, any payment to influence a matter in favor of the Company shall be prohibited.

6. The Company may be required to make facilitating or expediting payments to an official or employee of a government outside the United States, the purpose of which is to expedite or to secure the performance of routine governmental action by such government official or employee. Such facilitating payments may not be illegal under the FCPA and similar Laws of other countries. Nevertheless, it may be difficult to distinguish a legal facilitating payment from an illegal bribe, kickback or payoff. Accordingly, facilitating payments must be strictly controlled and every effort must be made to eliminate or minimize such payments. Facilitating payments, if required, will be made only in accordance with the advance guidance of the Law Department. Any facilitating payments must be recorded as such in the accounting records of the Company.
3-0004 - Internal Accounting Controls, Procedures & Records
Halliburton Company & Subsidiary Companies
CORPORATE POLICY

PURPOSE
This Policy establishes guidelines and procedures related to keeping books and records that in reasonable detail accurately and fairly reflect the Company's transactions and dispositions of assets. The Company shall maintain a system of internal accounting controls to ensure reliability and adequacy of its books and records and proper recording of all transactions including dispositions of assets.

POLICY
1. Authorization. The only transactions to be entered into by the Company are those which are executed in accordance with management's specific approval (as set forth in the following paragraph) or established, formalized policies and procedures.

2. Approval. No transaction will be recorded in the accounts of the Company unless it is within the scope of written policies and procedures or is specifically and formally approved by an appropriate and designated Employee. Such approval requires the determination that the transaction (i) has been authorized in accordance with this Corporate Policy and (ii) is supported by documentary evidence to verify the validity of the transaction.

3. Accounting. All transactions entered into by the Company will be recorded in the accounts of the Company in accordance with normal, standard procedures. Each entry will be coded into an account which accurately and fairly reflects the true nature of the transaction.

4. Reporting. All transactions that have been accounted for in accordance with this Corporate Policy will be accumulated and processed in a manner which will permit timely preparation of financial statements, reports and data for purposes of internal, public and regulatory reporting. Such statements, reports and data must be understandable and prepared in a form sufficient to reflect fully, accurately and fairly the results of transactions entered into by the Company and to permit proper accountability for assets.

5. Responsibility. The implementation and maintenance of internal accounting controls, procedures and records that are adequate in all respects to satisfy the requirements of this Corporate Policy will be the primary responsibility of the Chief Financial Officer.

6. Auditing. Compliance with the provisions and requirements of this Corporate Policy will be tested and evaluated by the Company's head of Audit Services in connection with the on-going internal audit program. All control failures regarding this Corporate Policy will be reported to management so that deficiencies can be corrected and assurance of compliance with the terms of this Corporate Policy maintained. 3-0015 - Defalcation, Misappropriation and Similar Irregularities (Fraud)
Halliburton Company & Subsidiary Companies
CORPORATE POLICY


Date: December 3, 2008
Index No.: 3-0015

PURPOSE
This Policy establishes and communicates the Company's policy regarding the prohibition, recognition, reporting and investigation of suspected fraud, defalcation, misappropriation and other similar irregularities.

DEFINITIONS
The term "Fraud" as used in this Policy includes, but is not limited to, defalcation, misappropriation and other irregularities including such things as any:
• dishonest or fraudulent act;
• defalcation;
• embezzlement;
• forgery or alteration of negotiable instruments such as Company checks and drafts;
• misappropriation of Company, Employee, customer, partner or supplier assets;
• conversion to personal use of cash, securities, supplies or any other Company asset;
• unauthorized handling or reporting of Company transactions; and
• falsification of Company records or financial statements for personal or other reasons.
3-0015 - Defalcation, Misappropriation and Similar Irregularities (Fraud)
Halliburton Company & Subsidiary Companies
CORPORATE POLICY


Date: December 3, 2008
Index No.: 3-0015

PURPOSE
This Policy establishes and communicates the Company's policy regarding the prohibition, recognition, reporting and investigation of suspected fraud, defalcation, misappropriation and other similar irregularities.

DEFINITIONS
The term "Fraud" as used in this Policy includes, but is not limited to, defalcation, misappropriation and other irregularities including such things as any:
• dishonest or fraudulent act;
• defalcation;
• embezzlement;
• forgery or alteration of negotiable instruments such as Company checks and drafts;
• misappropriation of Company, Employee, customer, partner or supplier assets;
• conversion to personal use of cash, securities, supplies or any other Company asset;
• unauthorized handling or reporting of Company transactions; and
• falsification of Company records or financial statements for personal or other reasons.
3-0015 - Defalcation, Misappropriation and Similar Irregularities (Fraud)
Halliburton Company & Subsidiary Companies
CORPORATE POLICY


Date: December 3, 2008
Index No.: 3-0015

PURPOSE
This Policy establishes and communicates the Company's policy regarding the prohibition, recognition, reporting and investigation of suspected fraud, defalcation, misappropriation and other similar irregularities.

DEFINITIONS
The term "Fraud" as used in this Policy includes, but is not limited to, defalcation, misappropriation and other irregularities including such things as any:
• dishonest or fraudulent act;
• defalcation;
• embezzlement;
• forgery or alteration of negotiable instruments such as Company checks and drafts;
• misappropriation of Company, Employee, customer, partner or supplier assets;
• conversion to personal use of cash, securities, supplies or any other Company asset;
• unauthorized handling or reporting of Company transactions; and
• falsification of Company records or financial statements for personal or other reasons.
3-0015 - Defalcation, Misappropriation and Similar Irregularities (Fraud)
Halliburton Company & Subsidiary Companies
CORPORATE POLICY


Date: December 3, 2008
Index No.: 3-0015

PURPOSE
This Policy establishes and communicates the Company's policy regarding the prohibition, recognition, reporting and investigation of suspected fraud, defalcation, misappropriation and other similar irregularities.

DEFINITIONS
The term "Fraud" as used in this Policy includes, but is not limited to, defalcation, misappropriation and other irregularities including such things as any:
• dishonest or fraudulent act;
• defalcation;
• embezzlement;
• forgery or alteration of negotiable instruments such as Company checks and drafts;
• misappropriation of Company, Employee, customer, partner or supplier assets;
• conversion to personal use of cash, securities, supplies or any other Company asset;
• unauthorized handling or reporting of Company transactions; and
• falsification of Company records or financial statements for personal or other reasons.

3-0001 - General Policy Regarding Laws & Business Conduct
Halliburton Company & Subsidiary Companies
CORPORATE POLICY


Date: December 3, 2008
Index No.: 3-0001

PURPOSE
The Code of Business Conduct of Halliburton Company contains the specific Corporate Policies adopted by the Board of Directors that relate to the legal and ethical standards of conduct of Directors, Employees and agents of the Company. The Corporate Policies listed in the index set forth in Corporate Policy 3-0000 constitute the Code of Business Conduct and govern the conduct of business by the Company.

The purpose of this General Policy Regarding Laws and Business Conduct is to provide a general statement regarding the Company's expectations as to the legal and ethical nature of conduct of the Company's Directors, Employees and agents while acting on the Company's behalf and to provide for the administration of the Company's Code of Business Conduct.

This Corporate Policy 3-0001 is intended to enhance the qualifications of the Code of Business Conduct as a program that, under the United States Sentencing Guidelines, is reasonably designed, implemented and enforced so as to be generally effective in preventing and detecting criminal conduct, and that promotes an organizational culture that encourages ethical conduct and a commitment to compliance with the law.

Moreover, this Code of Business Conduct applies to the Company's principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions. The Company believes that this Code of Business Conduct exceeds the requirements of the definition of a "Code of Ethics" as set forth in the regulations of the United States Securities and Exchange Commission ("SEC") issued pursuant to Section 406 of the Sarbanes-Oxley Act of 2002. However, for purposes of clarity and to ensure compliance with Section 406, this Code of Business Conduct as it applies to these listed officers is designed to deter wrongdoing and promote:

1. honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships

2. full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company files with, or submits to, the SEC and in other public communications made by the Company

3. compliance with applicable governmental laws, rules and regulations

4. the prompt internal reporting of violations of the Code to an appropriate person or persons identified in the Code; and

5. accountability for adherence to the Code.
3-0015 - Defalcation, Misappropriation and Similar Irregularities (Fraud)
Halliburton Company & Subsidiary Companies
CORPORATE POLICY


PURPOSE
This Policy establishes and communicates the Company's policy regarding the prohibition, recognition, reporting and investigation of suspected fraud, defalcation, misappropriation and other similar irregularities.

DEFINITIONS
The term "Fraud" as used in this Policy includes, but is not limited to, defalcation, misappropriation and other irregularities including such things as any:
• dishonest or fraudulent act;
• defalcation;
• embezzlement;
• forgery or alteration of negotiable instruments such as Company checks and drafts;
• misappropriation of Company, Employee, customer, partner or supplier assets;
• conversion to personal use of cash, securities, supplies or any other Company asset;
• unauthorized handling or reporting of Company transactions; and
• falsification of Company records or financial statements for personal or other reasons. 3-0015 - Defalcation, Misappropriation and Similar Irregularities (Fraud)
Halliburton Company & Subsidiary Companies
CORPORATE POLICY


Date: December 3, 2008
Index No.: 3-0015

PURPOSE
This Policy establishes and communicates the Company's policy regarding the prohibition, recognition, reporting and investigation of suspected fraud, defalcation, misappropriation and other similar irregularities.

DEFINITIONS
The term "Fraud" as used in this Policy includes, but is not limited to, defalcation, misappropriation and other irregularities including such things as any:
• dishonest or fraudulent act;
• defalcation;
• embezzlement;
• forgery or alteration of negotiable instruments such as Company checks and drafts;
• misappropriation of Company, Employee, customer, partner or supplier assets;
• conversion to personal use of cash, securities, supplies or any other Company asset;
• unauthorized handling or reporting of Company transactions; and
• falsification of Company records or financial statements for personal or other reasons. Costello
Warren
Gonzalez The Panama "Grey Market" practice. 3-0007- International Business Relationships
Halliburton Company & Subsidiary Companies
CORPORATE POLICY
PURPOSE
This Policy provides guidelines for business relationships entered into outside the United States ("International Business Relationships") as further defined below.

POLICY
1. The selection of parties with whom the Company may join in an International Business Relationship shall be subject to careful consideration by appropriate management of the Company after an investigation, reasonable under the circumstances, with respect to such parties and the proposed arrangements with such parties.
2. The terms and provisions of all proposed agreements with respect to International Business Relationships, including all proposed material amendments thereto, shall be subject to careful review and approval by the General Counsel and the Chief Financial Officer, or their designees, prior to execution and delivery of such agreements or material amendments. Such agreements will provide that the other party or parties will agree to comply with the Code of Business Conduct for International Business Relationships ("Code") as set forth in Annex A to this Policy. It is the responsibility of management, working with the Law Department, to (i) discuss the Code with such other parties to facilitate an understanding by the other parties of the requirements of such Code; and (ii) explain the Company's rationale for requiring the incorporation of the Code into agreements for International Business Relationships and the importance of compliance with the United States Laws described in paragraphs 4, 5, and 6 of such Code.
3. The Company may find it necessary or desirable to enter into International Business Relationships to assist the Company to obtain business or promote the distribution, marketing or sales of its products and services in which the other party or parties to the International Business Relationship either: (i) is paid compensation (monetary or non-monetary, fixed fees, lump sum fees, percentage of sales fees, award or bonus fees or any other form of direct or indirect compensation) based upon sales of products or services of the Company; (ii) is granted the right to distribute Company products or services; or (iii) participates, shares or receives directly or indirectly portions of the revenue or income of the Company.
4. International Business Relationships include the following:
a. the employment of an agent, sales representative, sponsor or any other third party (individual, partnership, corporation or unincorporated entity) to assist the Company to obtain business or promote the distribution, marketing or sales of its products and services, including licensing agreements pursuant to which a third party or parties distributes, markets, sells or is granted a license to distribute, market or sell the services, products or technology of the Company in the name of or on the behalf of the Company. These types of International Business Relationships are referred to as "Commercial Agents";
b. entering into a joint venture, consortium, partnership, shareholder agreement or any other similar agreement or arrangement pursuant to which a third party obtains: (i) an equity interest in an entity owned by the Company or (ii) a share of the profits from the business of a joint venture, consortium, partnership or entity owned by the Company; or
c. entering into a contract or subcontract (including a purchase order) pursuant to which a third party or third parties will perform a majority of the work or services to be provided under the Company's contract.
5. International Business Relationships do not include the following:
a. agents, representatives or consultants retained to support the day-to-day operations of the Company, including, but not limited to, activities relating to tax advisors, statutory auditors, outside legal advisors, personnel visas, immigration, import or export licenses, customs agents or brokers, freight forwarders, facilities or real estate and other matters routinely necessary for effective operations of the business ("Non-Commercial Agents"); or
b. subcontracts or purchase orders for goods or services in the regular course of business as may be necessary for the performance of work.
6. While International Business Relationships are ordinarily customary means of conducting operations in a particular country, such arrangements, if not adequately subjected to a corporation's system of internal controls, may be used to disburse a corporation's assets for purposes not authorized by management. Moreover, the Company may be held accountable for actions taken by agents and others on its behalf.
7. In carrying out the policies set forth in Policy paragraphs 1 and 2, the Company shall give consideration to such matters as the reputation of the proposed parties to an International Business Relationship, their familial or other connections with the local government, the necessity of the services to be rendered by such persons, the reasonableness of their fees or other compensation in light of those services and the fees paid to other persons in the area for similar services, any local legal requirements to utilize an agent for such services, the employment of such persons by other corporations operating in the area, the employment of such persons by affiliates of the Company, the location at which, and the currency in which, fees or other compensation is to be paid to such persons, any local legal requirements, including taxes and foreign currency exchange controls, regarding the payment of fees or other compensation to such persons, and the business and cultural environment in which such persons will render such services. 3-0015 - Defalcation, Misappropriation and Similar Irregularities (Fraud) POLICY
1. The Company prohibits all Fraud.
2. Directors and Employees are obligated to protect the Company's assets and ensure their efficient use. The theft, carelessness and waste of Company assets by Employees and Directors are prohibited since such actions and conduct have a direct and negative impact on the Company's profitability. All Company assets shall only be used for the legitimate business purposes of the Company.
3. The responsibility for detecting Fraud in the Company is that of management. The Chief Financial Officer bears the primary responsibility.
4. Situations involving suspected Fraud shall be reported to the Audit Services Department, the Security Department, the Chief Financial Officer or the Law Department. All Fraud investigations will be conducted under the authorization and direction of the Law Department.
5. The Company's head of Audit Services shall be notified of suspected significant Fraud (more than $50,000 of estimated loss), and any Fraud, whether material or not, that involves management or other employees who have a significant role in the Company's internal controls. The Company's head of Audit Services shall notify the Chief Executive Officer, the Chief Financial Officer and Audit Committee of any suspected Fraud involving management or other employees who have a significant role in the Company's internal controls and shall also notify the Audit Committee if it appears that there is any substance to the alleged Fraud.
6. Fraud involving more than $50,000 of estimated loss, and any Fraud, whether material or not, that involves management or other employees who have a significant role in the Company's internal controls, will be reported to the Audit Committee of the Board of Directors and the Chief Executive Officer and the Chief Financial Officer.
7. The Company's head of Audit Services, the General Counsel, the Chief Financial Officer and the Director of Business Conduct will maintain close liaison with each other and will participate in joint investigations as deemed appropriate under the circumstances.
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