Business Gifts and Courtesies Guideline

Guideline SL-FINANCE-G001

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

2. Objective
The objective of this guideline is to provide guidance to Schlumberger employees
so that they understand what is considered to be appropriate and inappropriate
behavior with respect to the giving and acceptance of business gifts and
courtesies under the Schlumberger Code of Ethics and Business Ethics Policy.
In addition, this guideline serves as a reminder that Schlumberger employees
should not cause an employee of any company that Schlumberger does or seeks
to do business with to violate any applicable laws or related internal policies of his
or her company.

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

4. Implementation and Monitoring

4.1. Definitions
”Business gifts and courtesies” are items or benefits for which the recipient
does not pay fair market value. These can include tangible goods, services,
recreation, hospitality, passes, discounts and favors.
“nominal value” is less than US $200 or equivalent local currency. Depending
on cultural or client customs and practices, local business practices, or
currency exchange rates, an Area or GeoMarket Controller may establish a
lower limit for such a value.
“Schlumberger employee(s)” means all employees, contractors, and agents of
the Schlumberger Group of Companies, and all entities that are majority
owned or controlled by Schlumberger.

4.2. Responsibility
It is the responsibility of every Schlumberger employee to make sure that his
or her conduct regarding the giving or acceptance of business gifts and
courtesies is and appears to be proper and ethical at all times, and strictly in
compliance with applicable laws and Schlumberger policies and guidelines.
Business Gifts and Courtesies Guideline
Guideline SL-FINANCE-G001

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

4.3 General Requirements: Business Gifts and Courtesies

4.3.1 Schlumberger employees and members of their families are not
permitted to offer business gifts or courtesies of more than nominal
value to any individuals, relatives of such individuals, or any entity with
whom Schlumberger does or seeks to do business with.
4.3.2 Schlumberger employees and members of their families are not
permitted to accept business gifts or courtesies of more than nominal
value from any individuals, relatives of such individuals, or any entity
that does or seeks to do business with Schlumberger.
4.3.3 Schlumberger employees may provide or accept meals, entertainment
and travel of a value in excess of the nominal value provided:
(i) It is associated with a legitimate business purpose and
consistent with marketplace practices;
(ii) A representative of the company offering the invitation is
present;
(iii) It is not lavish or extravagant;
(iv) Such offers are not frequent; and
(v) It could not be perceived as a direct attempt by the offering
party to secure a favorable decision on a particular issue or
matter.
4.3.4 Schlumberger employees may not, in relation to individuals, relatives
of such individuals, or any entity that does or seeks to do business
with Schlumberger:
(i) Give or accept a gift even of nominal value if it can be
perceived to influence the recipient’s judgment in business
decisions or dealings;
(ii) Give or accept cash or loans of any amount; or
(iii) Seek or ask for business gifts or courtesies.
4.3.5 This Guideline is also meant to cover the exchange of business gifts,
courtesies, meals or entertainment with any government employees or
employees of national or state owned companies that Schlumberger
does or seeks to do business with.
4.3.6 This Guideline does not prohibit ‘facilitating payments’ (where
necessary to assist in completing routine governmental actions),
which are covered in more detail in Financial Procedure- 24.
4.3.7 All receipts, records, and expenses associated with business gifts,
courtesies, meals and entertainment must be properly detailed,
Business Gifts and Courtesies Guideline
Guideline SL-FINANCE-G001

recorded and retained in the appropriate company financial

accounting records.

4.4. Exceptions
4.4.1 The expectation is that there will be strict adherence to this Guideline.
However, in the limited case where circumstances might warrant an
exception to the Business Gifts and Courtesies Guideline, they must
be specifically documented and approved as follows:
(i) By the appropriate GeoMarket Controller for business gifts and
courtesies with values between US $200 (or the established
lower limit) and US $400.
(ii) By the appropriate Area Controller for business gifts and
courtesies with values over US $400.
(iii) By the SL Controller for any monetary or other exceptions to
the Guideline.
4.4.2 Any local, or otherwise applicable law that might be more strict than
this Guideline must be complied with.

5. Useful Resources:
Schlumberger Code of Ethics
Business Ethics Policy
Anti-Corruption Policy
Financial Procedure (FP) - 24 Compliance with Business Ethics, Anti-
Corruption, and Financial Reporting Policies

6. Revision History
Effective Date Description Prepared by (name) Reviewed by
(name)
Nov. 15, 2004 Business Gifts and Courtesies S. Girard
Guideline S. Ayat
B. Curtis

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