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Code of Ethics
Our Values, Conduct,
and Behavior

Why do we have a Code of Ethics?
In the fast-changing world of global business, we are constantly faced with
new challenges and new opportunities. This can be unsettling, and it’s not
always clear how we should behave in certain situations or where the
boundaries lie in terms of what is acceptable to our colleagues, customers,
and thecommunities in which we work.
The Code is designed to support the Schlumberger Values and to help each
of us live those Values as we work. It is a practical and clear guide to the
behavior that the company expects from every one of its people worldwide.
The Code deliberately sets consistent and high standards for us, no matter
what our positions are within the company or where we work in theworld.
It should guide and inform our everyday decisions as we work together for
the continued success of Schlumberger.
Our responsibilities
Every one of us in Schlumberger needs to carefully read and understand
the Code, and we are all individually responsible for following both it and
the Schlumberger policies.
We must hold ourselves—and those working alongside us—accountable
forfollowing the rules: the rules of Schlumberger, the rules of the customers
we serve, and the rules of the countries in which we work and live. Being
accountable means we each must take a proactive approach to ethical,
legal, and compliance concerns by identifying, reporting, and addressing
them as necessary.
By doing this, we can all play our part in meeting the expectations of our
colleagues,customers, and shareholders, as well as many other stakeholders.

Andrew Gould
Chairman and CEO
Schlumberger Limited

The Code of Ethics does not change the terms and conditions of our employment with
Schlumberger. It is a guide for our day-to-day conduct as Schlumberger people.†

See our Schlumberger Values at www.ethics.slb.com.



Contents
4

About the Code—Questions andcompliance

7

Living our Values

8

Our actions

9

Our relationships with each other

10

Our relationships within the community

11

Recognizing and avoiding conflicts of interest

13

Our commitment to Quality and to Health, Safety,
and protecting the Environment

15

Our accounting and financial reporting obligations

16

Maintaining confidentiality and security ofinformation

18

Software copyright and licensing

19

Competing fairly and ethically

20

Stock transactions

21

Improper payments

22

Respecting trade controls and immigration laws

23

Maintaining business records

24

We are each accountable

24

Where can you go for more information?

About the Code—Questions and compliance
What is the Code of Ethics?

TheCode of Ethics is a broad outline, designed to guide your decision making and
help you handle business situations professionally, fairly, and legally. It is supported
by a wide range of company policies, standards, and other documents that set out our
obligations and responsibilities to behave ethically in every aspect of our business lives.
To whom does the Code apply?

The Code of Ethicsand the Schlumberger policies apply to every employee and manager as well as to every director and officer. Ultimately, each one of us is personally
responsible for making sure that we comply with the laws and regulations that apply
to our business, as well as our Schlumberger requirements.
If you are in a leadership position, you must communicate and implement the Code of
Ethics and theassociated Schlumberger policies, making sure that your teams comply.
Where appropriate, contractors and agents of the company should also follow the Code
of Ethics and Schlumberger policies.

Walk the walk
Managers must set the tone for their organization.
In short, they must not only talk the talk but walk it.

4

Are there waivers and exceptions to the Code?

Any waiver of or...
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