All employees with relevant job functions and those working in high-risk countries complete additional anti-bribery and anti-corruption training. The training covers the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act, as well as other country-specific anti-corruption laws regarding hospitality, charitable contributions, donations, gifts and international business relationships. The Global Ethics and Compliance group conducts in-person training sessions to supplement the web-based anti-corruption training courses.
All employees with relevant job functions, along with employees working in countries that have been designated as high-risk, must complete anti-bribery and anti-corruption training. The High-Risk Country Evaluation Committee comprises senior leadership from Supply Chain, Finance, Operations, IAS and Legal. This mandatory training provides employees with general information about anti-bribery and anti-corruption laws, and offers practical guidance on topics such as determining who is a government official, business hospitality, charitable contributions, gifts, due diligence requirements for business relationships, maintaining accurate books and records, and internal controls in the procurement process.
The Global Ethics and Compliance group conducts in-person and video training sessions and interactive workshops to supplement online anti-corruption training courses. Additionally, regional compliance counsels are embedded in all geographies where the Company does business, focusing much of their efforts on anti-corruption training and awareness, and engaging those we do business with on anti-corruption initiatives.
In 2020, Halliburton revised procurement controls in high-risk countries to further protect against fraud and corruption, and reconfirmed the Company’s ongoing commitment to prohibit facilitation payments via a corporate policy. To guarantee that employees were updated regarding changes to the Company’s anti-bribery and anti-corruption policies and procedures, the Global Ethics and Compliance group provided live virtual trainings, in lieu of in-person trainings, to ensure employee safety through social distancing.
The COBC includes our commitment to competing fairly and winning business ethically and legally, including refraining from making unfair or disparaging comments about our competitors and their offerings. Our business practices are regulated by various global competition laws and antitrust regulations.
The COBC requires all Halliburton employees to comply with the content and spirit of these laws and regulations, and forbids engaging in anti-competitive behavior. These requirements include respecting and protecting the intellectual property and confidential information of our competitors. The Company’s ethical practices regarding anti-competitive behavior are reinforced through our mandatory COBC training.