The Global Ethics and Compliance group is led by the Chief Ethics and Compliance Officer, who reports directly to the Board’s Audit Committee. The group is structured into global and regional teams to provide advice on local issues and on global standards around the clock, wherever Halliburton conducts business.
Our Global Compliance Program is based on a robust compliance governance framework with the following essential elements:
- Well-defined and clearly communicated standards of compliance
- Open lines of communication
- Robust due diligence processes
- Continuous compliance monitoring through internal assessments and audits
- An experienced and objective internal investigations team to ensure effective and timely investigations of violations of the COBC or the law, including implementing disciplinary and remedial actions when appropriate
- Ongoing training and education
- Proactive risk management
- Dedicated Regional Compliance Counsels and Local Ethics Officers responsible for answering questions and guiding Company employees on all matters related to the Company’s COBC
COBC Training and Local Ethics Officers
Our COBC requires employees, directors and officers, as well as all third parties that conduct business with us or on our behalf, to act with fairness, integrity, respect and high standards of personal and business ethics. All Halliburton employees and contract workers or consultants with access to our systems are required to complete COBC training every two years. Training courses cover areas of the COBC and the law, including anti-corruption and topics relevant to human rights. To ensure that the Company’s commitment to ethics and integrity remained central to the execution of our business during the COVID-19 pandemic, the Global Ethics and Compliance group provided live virtual trainings in lieu of in-person trainings to ensure employee safety through social distancing. As conditions allow, we expect that our Global Ethics and Compliance group will return to in-person training sessions to supplement the online COBC training courses.
More than 50 Local Ethics Officers (LEOs) in 42 countries serve as key liaisons between local employees and the Global Ethics and Compliance group. LEOs embody and model ethical behavior, and are available to answer questions, provide advice and take reports of suspected misconduct. LEOs also assist in providing regular ethics awareness to Halliburton employees, using tools such as quarterly Ethics Moments and biweekly Ethics Topics. In 2020, LEOs conducted 1,661 presentations with more than 49,916 attendees.
Our Ethical Operations Sustainability Commitment:
Conduct business with integrity, choosing the ethical course of action when confronted with challenging circumstances, promoting a speak up culture free of retaliation, and treating our employees and stakeholders honestly and fairly.
Ethics Helpline and Whistleblower Protections
At Halliburton, our employees are the first line of defense against violations. The Company maintains a COBC Ethics Helpline, managed by an independent company, to encourage employees and external whistleblowers to report misconduct anywhere in the world. Reports can be submitted anonymously by phone, email or by mail, and translators are available. Each report is reviewed, analyzed, tracked and addressed.
Potential violations of the COBC or the law are investigated, and results are shared internally with executive management, the Internal Assurance Services (IAS) group, and, as appropriate, the Board’s Audit Committee.
In the case of substantiated reports, disciplinary actions are taken in line with the principles of proportionality and fairness. Disciplinary actions can include termination, written reprimand, coaching, restitution, suspension without pay, loss of stock/bonus and demotion.
Halliburton makes every effort to maintain the confidentiality of whistleblower reports, and prohibits retaliation against anyone who raises issues in good faith or cooperates in an investigation. Any act of retaliation will be subject to disciplinary action, up to and including termination.
Internal Assurance Services
Our Internal Assurance Services group conducts reviews on a global basis to assess the effectiveness of risk mitigation through compliance with the Company’s policies, procedures and standards and/or the identification of new or emerging risk. IAS performs risk assessments that are designed to identify and evaluate key risks within the organization. IAS evaluates risks by analyzing known, perceived and anticipated threats to achieving organizational objectives. The risk assessment process is the basis of the group’s Audit Plan. Audit outcomes are presented in a formal report, and actions are required to address reported observations. Audit findings, trends and insights are reported to the organization and to Board committees as applicable. In 2020, our IAS group performed approximately 80 audits, which was consistent with previous years.