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8/2/2019 Code Conduct Ethics 1/40 Code of  Conduct

Code Conduct Ethics

Apr 05, 2018



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Codeof  Conduct

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Table of Contents

Noble Corporation • June 2011

2 CEO Message & Introduction

4 Overarching ValuesHonesty and Integrity


Environmental Stewardship

Fair Employment

6 General Business PrinciplesBusiness Ethics and Compliance

Business Strategy

Quality and Operational Excellence

Risk Management

Customer Relations

Supplier Relations

8 HSE & QualityHSE

Emergency Action


Environmental Sustainability

12 Workplace ConductMutual Respect


Workplace Violence

Internet and Social Media

Alcohol and Drugs

Data Privacy

Learning and DevelopmentEqual Opportunity

18 CommunicationsBusiness Communications

Political Activity/Lobbying

Political Donations

20 Confict o InterestConflicts of Interest

Gifts and Hospitality

Insider Dealing

24 LegalAnti-Bribery and Anti-CorruptionGovernment Officials


Fair Competition

International Operations

Trade Controls

Global Security

Money Laundering

30 Protecting our AssetsProperty and Equipment

Intellectual PropertyInformation Technology

Records Management

34 FinancialFinancial Accounting and Reporting


36 Employee Resources

Important ContactsReporting Issues and Concerns

The NobleLine

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 A resource is onlyeective if it works when you need it the most.

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CEO Message

Earning and maintaining the trust of our coworkers, customers,

shareholders, government regulators, communities and others is

one of the hardest jobs we have. The value of a strong reputation

cannot be overestimated. Regaining trust and rebuilding a

tarnished reputation is even harder, if not impossible to do.

The purpose of Noble’s Code of Business Conduct and Ethics

is to provide guidance in doing your job and conducting business

day-to-day. Maintaining our high ethical standards is essential

in order to preserve Noble’s nine decade-long heritage, strong

reputation and the trust of our business partners. The Code claries

Noble’s expectations for individual and team behavior and work-

related interactions and activities. It is a reference for the Noble

policies, processes, tools and resources available to support you in

acting with honesty and integrity and following all laws, rules and

regulations that apply to you and Noble.

This Code cannot answer every question, solve every problem

or clarify every issue. If you have questions or concerns or need

detailed guidance, please refer to the Administrative Policy

Manual, talk to your supervisor or manager, or contact one of the

listed “Employee Resources.”

Noble wants you to succeed and will continue to give you the

tools and information you need to live up to our Code of Business

Conduct and Ethics.

The Noble Code of Business

Conduct & Ethics

David W. Williams

Chairman, President and Chief Executive Ocer

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Noble Corporation • June 2011

As a Noble employee, your decisions and actions aect

coworkers, customers, suppliers, shareholders, community members

and others. The Noble Code of Business Conduct and Ethics (“the

Code”) is a resource to help you understand and apply Noble’s

values, general business principles and policies related to your day-

to-day work activities, and to provide general guidelines that are

further strengthened and complemented by the our Administrative

Policy Manual. The Code provides an overview of Health, Safety

and Environment (“HSE”), quality, the workplace, communications,

conicts, following the law, Company assets, nancial compliance,

and employee resources.

The Code applies to all Noble employees, ocers, and members

of the board of directors, and impacts those we do business with,

including customers, contractors, suppliers and agents. Every person

covered by Noble’s Code must be familiar with it and follow the

leer and spirit of the Code, Noble standards and policies, even if we

are not required to do so by laws and regulations. Those who violate

any standard in this Code may be subject to disciplinary action.

Any waiver of this Code may only be made by the Board of

Directors of the Company or a commiee of the Board. If a law

conicts with a policy in this Code, you must comply with the law;

however, if a local custom or policy conicts with this Code, you

must comply with the Code.

Noble encourages you to report any suspected Code or policy

violation. Our policy protects you from retaliation if you make areport in good faith.

If you have questions about any aspect of the Code and how

it applies to you and others, talk to your supervisor, manager,

Human Resources representative, Corporate Compliance or call the

NobleLine. All employees worldwide can call NobleLine at any time

to anonymously report any concerns that are not being addressed

through normal channels. Call NobleLine to discuss issues related to:

• Violations of laws or policies

• Workplace harassment/discrimination• Fraud, theft, conict of interest or inappropriate gifts,

entertainment and gratuities

• The environment and worker health and safety

• Actions that threaten Noble’s integrity, security or reputation

Even with guidance from the Code of Business Conduct and

Ethics, the right path may not always be easy to identify. In these

situations, ask yourself if an action or decision is legal and ethical,

follows Noble policies and honors Noble values. If you can answer

yes to these questions, you are on the right path.

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Over our longhistory, Noble

has consistently

communicated whatwe value, what westand for and whatmakes us unique.These overarchingvalues are the foundation of “the Noble Way”

and can be found inboth our wrien andunwrien policies.

Overarching Values

Honesty and IntegrityHonesty and integrity are the most important qualities of who we are and in all of our

  business dealings. We will demonstrate these values in every aspect of our relations with

employees, customers, suppliers, subcontractors, government and regulatory authorities,shareholders and other investors, the business community and the public. We will be

forthright, honor agreements, meet obligations in a timely manner, maintain the spirit and intent of

our commitments, value good relationships and adhere to applicable national and international laws

and regulations.

SafetyThe safety of our people is Noble’s greatest responsibility and we believe every job can

and must be done safely. We respect the safety and welfare of lives and property beyond

our own people, including customers, suppliers, subcontractors and regulatory personnel.

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We maintain extensive policies, processes and procedures to create

a safe work environment and provide training and equipment to

help our employees stay safe on the job. Process safety is a large part

of our eort to achieve a safe work environment and is based upon

a structured incident and near miss reporting system, and carefully

dened and communicated rating matrices, all feeding into a program

of continuous improvement. We want every employee to return home

to their families and loved ones safely at the end of the day.

As a Noble employee, you not only have the authority but the

obligation to alert or, if necessary, suspend any process or operation if

you believe it represents a hazard to the life and health of any person,

the environment or surrounding communities.

Environmental StewardshipWe are stewards of our global natural resources. It takes the

commitment of Noble employees, individual citizens, the publicsector and the industry to preserve and improve the environment. Our

collective eorts assure that current and future generations enjoy the

 benets of a cleaner environment.

Noble’s approach is to be proactive, act voluntarily and go

above and beyond regulatory compliance in our eorts to protect

the environment.

Managers have the fundamental duty to inform employees about

environmental issues aecting them and their operations and the

specic policies and procedures we have to minimize our impact onthe environment. As stewards of the environment, all employees are

to promptly report any deviation from our goals to ensure Noble is

in compliance with environmental rules, regulations and Company


Fair EmploymentWe strive to be the employer of choice and respect the dignity and

worth of all employees. We expect each individual to demonstrate a

strong work ethic and contribute to Noble’s success.

Noble is an equal opportunity employer. It is our policy not to discriminate againstemployees and people who apply to work for Noble.

Noble has operations in many countries and endeavors to employ a skilled workforce that

reects the diverse populations of the communities where we operate. We will train employees

to steadily develop and improve their competence and skills so they are fully prepared to

meet the highest industry standards, customer expectations and demands of modern oshore

drilling. We will foster a culture where our employees reach their highest potential and create

an environment that provides a safe place to work, structured career development, encourages

open communication, promotes teamwork, and rewards performance.

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T hese general business principles guide how 

Noble conducts our

business. Keeping these principles in mind willhelp you approach your job in a way that benetsthe Company and ourstakeholders.

General Business


Business Ethics and ComplianceWe will deal honestly and adhere to high ethical standards in all business activities. This

is how we earn and keep the trust of each other, our customers, shareholders and everyone we

impact with our decisions and actions.

Noble invests in mandatory ethics and compliance training, outreach and monitoring to

ensure our employees meet our high standards and comply with applicable laws and regulations

wherever we operate. As an employee, you must annually review and arm that you understand

and are commied to this Code and the Administrative Policy Manual.

Business StrategyNoble’s long-standing business strategy is the enhancement of our eet of mobile oshore

drilling units through economic acquisitions and construction, market-projected rig upgrades

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and deployment of drilling assets in proven and emerging geological

regions. We adhere to a conservative nancial policy and disciplined

operational mind-set to understand and manage nancial and

operational risk and deliver shareholder value. We integrate HSE

performance improvements into our business strategy to add further

value for customers, shareholders and employees and contribute to the

sustainability of our business.

Quality and Operational ExcellenceWe strive for a system of continuous improvement to beer

our operating eciency, asset reliability, safety performance and

environmental protection. Our quality management systems serve

to document the processes by which we will conduct our daily

operations and to provide a means of assuring consistent performance

through the management of change. We will invest in quality assets

and continuously improve our eciency, asset reliability, safety and

environmental performance. We are commied to excellence in HSE,

operations, communications, teamwork, engineering, personnel and

maintenance. We stand ready to learn, grow and improve to beer

serve our customers and dierentiate Noble from our competitors.

Risk ManagementNoble manages risk proactively to improve safety, environmental,

operational and nancial performance. To minimize risk, we train

our employees, provide a safe environment, operate clean and well-

maintained rigs and keep equipment in good working order. We audit

rigs regularly to ensure that employees follow policies and procedures

and use equipment properly.

Customer RelationshipsStrong customer relationships provide superior nancial

returns, stability and high asset utilization rates that benet both

our shareholders and customers. We provide our customers

with trained and competent workers, advanced technology and

well-maintained drilling units and equipment they need to nd

oil and gas safely, eciently and cost-eectively. Our goal for quality and operational

excellence cultivates mutually benecial relationships with all of our customers.

We continuously look for new ways to improve our performance and assets, and collaborate on

projects to meet our customers’ increasingly complex needs. In return, we expect our customersto meet their obligations in a timely manner, and partner with us to achieve operational, HSE,

and nancial success.

Supplier RelationshipsNoble seeks and prefers to work with vendors who meet their obligations in a timely and

eective manner while sharing our values, demonstrating high standards of ethics and integrity

in all business dealings and complying with all applicable laws, regulations and rules. We expect

our contractors, suppliers and subcontractors to comply with all applicable Noble policies and

procedures when performing any assignment on Company premises.

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N oble promotesand encourages

a culture of safety,

 protecting ouremployees andensuring we deliverthe highest qualityservice to ourcustomers.

HSE & Quality

HSENoble is commied to conducting operations with the highest levels of integrity. In all

circumstances, we look to do the right thing, avoid short-cuts which could undermine the quality

and safety of our operations, and continually improve our procedures. This commitment bothprotects our employees and ensures we deliver the highest quality service to our customers.

We are all responsible for safety, and it is our prime consideration. No job is so urgent that

time cannot be taken to do it right. All employees, from executives and management to rig crews,

must carry out their individual and collective responsibilities and work towards our goal of

working without injuries.

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Field Notes

Noble Corporation • June 2011

In conducting our operations, we should remember:

• All of us, regardless of position, have the express authority and

obligation to suspend any operations, which, in our opinion,

constitute a hazard to the life and health of any person or to the

surrounding communities• It is fundamental that our managers and supervisors be informed

on health and safety issues aecting our operations and to have

procedures to ensure safe operations

• Our managers and supervisors must promote a culture that

encourages open communications and adherence to our safety


Emergency ActionEmergency situations, such as injuries or serious damage to

property, can happen at any time, and we must be prepared and

ready to take action. In an emergency, our primary concerns are to:

• Protect the health and safety of our people, property and the


• Ensure timely notication of supervisors and management

• Comply with all applicable laws and regulations including

required agency notications

We all have a responsibility to ensure that information about

emergency situations is escalated in a timely manner and to the

proper people within Noble.


Four Basic Steps for Safety

1. Conduct good job planning

2. Execute work per the agreed job plan

3. Stop the job when work has deviated rom the plan

4. Identiy and communicate lessons learned,

both good and bad

See Administrative Policy Manual Section 3 for more details

Q:I recently saw an event wsomeone got hurt bu

looked like the medic avoided gthe employee certain medicationorder to make our saety numbersbetter. What should I do?

A:It is important to underssaety incidents in orde

prevent similar incidents in the uStart by asking or an explanarom the medic as there may be oreasons or the type o treatmprovided. I you’re still concealert your supervisor, and contacNobleLine i the issue continues.

Q:I am new to Noble, but out top o my class du

introduction / orientation schoolmy rst hitch, a situation arose whattempted to stop the job as I had taught. However, my supervisorme “not to worry” and that I shwork as directed. What should I d

A:You should ask your superor urther explanation

their comments and discuss whatlearned in orientation. I you areuncomortable, talk with yourManager, and contact the NobleLthe problems persist.


Failure to ollow procedures and report an incident

may violate Noble policy and also break the law.

See Administrative Policy Manual Section 3 for more details

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The culture o a workorce is a product o its

leadership. Our saety culture is ounded on vepillars:

1. Demonstrate Genuine Care and Concern 

Working sae comes rom a genuine, heartelt

desire not to see the lives o employees, their

amilies and loved ones negatively impacted.

2. Measure and Respond to Exposure 

The seriousness o all incidents are

determined by the Risk Potential o the

incident and not by the actual consequence.3. Conduct Safety Perception Audits 

HSE audits must extend to measuring the

eectiveness o the leadership and the

company culture—the hearts and minds

o people.

4. Make Safety Personal 

Leadership must ensure that saety is

always promoted in a orm that is

relevant on a very personal level.

5. Celebrate Successes 

Employees need to know that their

eorts are being recognized.

Safety Culture

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Field Notes

Noble Corporation • June 2011

QualityWe focus on continuous customer satisfaction and quality

improvement. To achieve this, we must adhere to our policies and

procedures and continuously monitor and respond to our customers’

requirements and their needs, both current and future.

We have a commitment to provide our customers with drilling

equipment, tools and services that are reliable, cost eective and of

the highest quality. We also have a commitment to maintain a highly

skilled and competent workforce in order to provide the highest

quality of service to our customers.

Environmental SustainabilityAll of us have the responsibility to be good stewards of the

environment. Our collective eorts will assure that the current

generation and subsequent generations enjoy the benets of these

endeavors through a cleaner environment. We strive to:

• Provide training in environmental management to our employees

• Eliminate accidental releases of pollutants into the environment

• Limit waste

• Use environmentally sensitive products

• Work within governments and the industry to create practical

environmental laws and regulations


A commitment to quality benets our customers as well

as improves the saety and eciency o our operations.

See Administrative Policy Manual Section 3 for more details

Q:We had a minor incidentled to a small leak. Gene

we report leaks to the environmagency but they likely wouldnotice i we did not. What should

A:We have a responsibilitollow all laws and regula

and alert appropriate authoritiany incident. Alert your superand management so that the inccan be reported properly.

Q:Our BOP was damagedinstallation. We may be

to do the repairs ourselves, buttype o BOP repair must be certi

the manuacturer. The certied rprocess is lengthy and may reqdowntime. What should we do?

A:Our commitment to quincludes making sure

equipment and tools are maintaat the highest standards. This mwe must make sure that all reare up to code and have all nececertications. Take the time to ge

 job done right.

Q:I was asked to carry oprocedure that I believe

be in violation o environmregulations. What should I do?

A:I you are uncertain, nperorm procedures w

may violate environmental   Discuss the situation withsupervisor. I you are still uncer

contact the NobleLine.


You can promote environmental sustainability in your

day-to-day job by identiying recycling opportunities,

limiting waste or misuse o supplies, and preventing

improper disposal o waste.

See Administrative Policy Manual Section 3 for more details

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Respect for theindividual

and a mind-set

of accountabilityunderscoreNoble’s approachto all businessrelationships—bothwithin and outsidethe Company.

Workplace Conduct

Mutual RespectWe are fully commied to providing a workplace free from oensive or harassing conduct.

This commitment involves respect for our employees and our business partners.

Noble will not permit or condone harassment on the basis of race, color, sex, religion,

national origin, age, citizenship, disability status, membership or application for membership in a

uniformed service, engaging in legally protected activity, or other characteristic protected by law.

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Field Notes

Noble Corporation • June 2011

Harassment can take many forms, including:

• Abusive language

• Unwanted advances

• Demeaning comments or jokes

• Hazing• Oensive language or gestures

Non-RetaliationWe do not tolerate retaliation in any form in response to reports

made in good faith. Retaliation includes actions such as ring,

demoting or transferring someone, as well as avoiding or excluding

the person from professional activities.

Workplace ViolenceWe prohibit all violence, whether implied or actual, against our

coworkers, visitors and anyone else on our assets and premises,

or in contact with our employees. We regard threats of violence as

very serious. Any threatened or actual violence should be reported

immediately, and may be subject to disciplinary action.

To maintain a violence free workplace, weapons or any other

objects designed to inict harm are prohibited on our premises. If you

feel a coworker or anyone on Noble premises may become violent,

speak to your supervisor or an HR representative.


Open Door Policy

We encourage honest and open communication. All o

our employees are ree to seek inormation rom their

supervisor regarding issues that are troubling them.

These inormal discussions oten enable problems to be

cleared up without delay, and allow our management

to make decisions with the best interests o our

employees in mind.

See Administrative Policy Manual Section 4 for more details

Q:A coworker oten teasesabout my appearance. I k

they do not mean any harm andidn’t bother me at rst, but the teis now making me uncomort

What should I do?

A:It is important to letother employee k

that their behavior makes youuncomortable. I you do not wto discuss this with the emplspeak to your supervisor or anrepresentative. I the behavior doestop, contact the NobleLine. Resouare available to help you.

Q:I orwarded an Internet to a coworkers Noble e-

address. Some people might nd joke oensive, but I know that henot be oended. Can I get in troub

A:Never distribute oematerial in the workp

While your intended audience mabe oended, you cannot predict else may see the material and ho

may impact them.

Q:I recently had a heargument with a cowo

 During the argument he threatenhurt me. What should I do?

A:Threats o violence, wheexplicit or implied, sh

be taken seriously. I you eel undiscuss the situation with supervisor or an HR representativ


I you eel a coworker or anyone on Noble premises

may become violent, speak to you supervisor or an HR


See Administrative Policy Manual Section 4 for more details

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Internet and Social MediaOur computer and telecommunications systems should be used for Company purposes.

Reasonable and appropriate incidental personal use is permied, but we should all exercise

discretion when using Company resources for personal activities. Personal use of our Internet

and computer resources should not:

• Consume more than a trivial amount of resources

• Interfere with our productivity

• Preempt any Noble business activity

Under no circumstances should Noble Internet or computer resources be used to obtain,

post or review any pornographic or otherwise illegal or inappropriate material.

We should not assume that any communications sent from Noble communication devices

are private. All Noble communications are property of the Company, regardless of the device

used to send the communication, including personal computer and mobile phone devices.

Blogging and other online dialogue are far-reaching and public forms of communication.

Only certain employees are authorized to publish information about Noble. Company

information posted on blogs or websites by unauthorized employees may not only be an

inappropriate disclosure, but may inadvertently trigger legal disclosure obligations. In addition,

spreading rumors or criticisms of Noble online, even on personal social networking sites,

could harm our reputation and impair our business. Please refer to the related sections on

Business Communications and Public Disclosure.

Alcohol and Drugs

We strive to maintain a safe, healthy, ecient and eective work environment. Abuse ofalcohol, drugs and other controlled substances impairs our ability to provide a safe and healthy

environment for all employees.

To maintain this environment, certain substances are prohibited from Noble’s and our

customers’ facilities:

• Alcohol

• Drugs, including prescription medication not prescribed by a licensed physician

• Drug paraphernalia


The Internet is a public orum; it is important to

protect your own condential inormation, as well

as the Company’s, on the Internet. Your Noble

communications may be monitored by the Company.

See Administrative Policy Manual Section 3 for more details

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Field Notes

Noble Corporation • June 2011

Anyone under the inuence of alcohol is prohibited from

engaging in Noble business or operating Noble equipment. Under

certain circumstances with pre-approval from executive management,

alcohol may be permied, such as at Noble sponsored social events.

Data PrivacyWe all have a right to privacy. At times, Noble must gather and

maintain certain information about our employees, but the Company

will only gather information that is required by law or necessary for

corporate operations. Noble will only make this information available

to authorized employees who need to use the information to conduct

our operations.

Maintaining the security and integrity of stored personal

information is vital. Noble will maintain all employee information

securely and with proper controls in place to ensure that onlyauthorized employees are able to access and view the information.

These controls are designed to adequately prevent accidental or

fraudulent loss of employee information.

Certain additional laws govern the transfer of personal

information between countries. Noble is commied to complying

with all applicable data privacy laws, both locally and globally.


I you eel you may have a dependency on drugs or

alcohol, get help. As a condition o your employment,

you may rom time to time be subject to testing or

illegal drug or alcohol use.

See Administrative Policy Manual Section 4 for more details

Q:I just ound out thatwon a new project wi

new customer. I want to postinormation on a social networsite as this is an important project

I will likely get a chance to work oIs it OK to post online?

A:No. The Internet isar-reaching orm

communication. Be very careul npost any Company inormation onbecause it may be condential oryet made public and could even violation o law.

Q:  Do I need to take any sp

steps beore accessing Noble e-mails on my personal mphone?

A:While your mobile phis your personal de

Noble e-mails are Comproperty. You should always looprotect Company property. Cerprecautions, such as using screen loregistering your phone with N

IT and enabling sotware or remwiping o the device will help to mthe communications more secure.

Q:We recently had an emplinjured on a rig. O

employees are eager to knowcondition. Can I give them his meupdate?

A:  Details about the mcondition o an indivi

may be legally restricted. Conthe HR or Legal Department bedisclosing any detailed meinormation.


Certain types o inormation, such as medical updates

about sick or injured employees, may be subject to data

privacy laws, including the Health Insurance Portability

and Accountability Act (HIPAA) in the United States or the

Data Protection Directive in the EU.

See Administrative Policy Manual Section 3 for more details

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Learning and DevelopmentAt Noble, our success rests on thousands of individual decisions our employees make every

day. Noble is commied to empowering our employees with the proper tools and training to

meet our objectives.

Noble provides training and development to help our employees reach their highest

potential, so we can support Noble’s goals of sustainability and industry leadership. It is critical

that Noble continue to aract, develop, and retain a highly skilled and motivated workforce.

Noble oers training in the areas of:

• Safety, operations, management and leadership programs

• Task-oriented training focused on specic skills

• Development programs to improve

• Supervisory and leadership capabilities

• Organizational communications

• Teamwork


Take control o your career and use the training

available to gain the necessary skills and tools to excel.

See Administrative Policy Manual Section 4 for more details

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Field Notes

Noble Corporation • June 2011

Equal OpportunityNoble is an equal opportunity employer. We do not willfully

discriminate against employees and applicants for employment

 based on:

• Race

• Color

• Sex

• Religion

• National origin

• Age

• Citizenship status

• Physical or mental disability of an otherwise qualied individual

• Membership or application for membership in a uniformed

government service

• Other characteristic protected by applicable law

To the greatest extent possible, we base personnel actions

including recruitment, hiring, training, promotion, compensation

and discipline solely on the employee’s qualications, merit and



Discrimination based on any o the actors listed above

not only goes against the Noble Way, but may alsoviolate the law.

See Administrative Policy Manual Section 4 for more details

Q:I have an employee woror me who I eel has

potential to advance. However,employee is still inexperienced will need to develop his skills urWhat can I do to help?

A:Noble is committed tolearning and developm

both in technical and career skilour employees. Consult our Learand Development program and out and apply or training that help them urther advance their ca


I supervise a group one minority emplo

Unortunately, the minority emplhas had requent perormissues. I am araid o being accusediscrimination i I give the worknegative review. What should I do

A:It is important to proregular and consis

perormance eedback. Recogno positive and negative perormissues should always be careully

consistently documented. Alwayair and honest in your evaluationsback up your conclusions with and examples. I you need assistacontact an HR representative.

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N oble employees areto communicate

in a responsible and

 productive manner.

Business CommunicationsAll outside inquiries or requests for information should go through the proper channels.

Such requests for Noble information could come from the media, investors, analysts, government

ocials, or members of the public. Requests of this nature should be forwarded for handling byauthorized management and the Corporate Communications Department.

Noble’s reputation and public image could be tarnished if we make inaccurate public

statements. Such statements could also violate the law. Noble has designated employees who are

trained and authorized to speak on our behalf.

We all communicate on a daily basis both internally and with our customers and vendors.


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Field Notes

Noble Corporation • June 2011

Whenever we communicate, we should be careful to:

• Protect condential business information

• Not mislead

• Not write speculative opinions

• Not exaggerate

• Not speak casually about sensitive or condential maers

• Not joke about serious maers

Related Sections: Internet and Social Media and Public Disclosure

Political Activity/LobbyingNoble’s business requires us to maintain relationships with

governments and government ocials in countries around the world.Many of our employees frequently interact with government ocials

and regulators in order to ensure that we are operating lawfully and

with all necessary authorizations and permits. Whenever we interact

with these government ocials, we should act with professionalism

and conduct ourselves with integrity. Maintaining these relationships

is crucial to our business.

At times, we may also use lawful channels to inuence or beer

understand government policies and regulations. To accomplish

these goals, we may hire outside consultants or advisors who must

maintain the same professionalism and integrity that we expect fromour own employees. Don’t contact the government on behalf of Noble

to inuence legislation, regulations or decision making without prior

approval from the Legal Department.

Political DonationsOur policy prohibits political donations made on behalf of Noble.

No employees are authorized to make donations to politicians,

political parties or candidates for oce on Noble’s behalf. If you wish

to make personal political donations, make clear that the donation is

personal and not related to Noble.


• Informationputine-mailsisdiscoverableand

may be monitored by the Company

• Communicationswithacompetitorcould

violate air competition laws

• Becarefulwhenwritinge-mails,keepingin

mind the context and the possible audiences

• Noble’sbusinessisNoble’sbusiness

See Administrative Policy Manual Section 3 for more details

Q:A representative rom a news agency recently c

me to ask me my opinion on resaety issues in the oil industry. Wshould I do?

A:All outside inquiries sh  go only through autho

personnel. Even though you may a personal opinion, others in the pumay assume it is Noble’s opinion. Rthe news agency to our CorpoCommunications Department.

Q:Many times my e-mailsorwarded to several peo

am worried that some people may

understand the context o the e-and make incorrect assumptWhat should I do?

A:While e-mails oer an way to communicate qu

and eciently, make sure youalways include sucient detail in responses so that the context is eunderstood. Also, always conswhether e-mail is the best orm

communication. Sometimes, a pcall or ace-to-ace response mabetter.

Q:I am upset about regulations in the oil indu

that I think are unair. I want to wa letter to my congressman askingto change the laws. What should I

A:When writing your lemake sure it is clear that

are not speaking on Noble’s beNever use your Noble e-mail, Nletterhead or your Noble address wcommunicating with elected oor candidates or elected oce.

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W hen acting onNoble’s behalf,

always look to put

Noble’s interestsbefore any personal gain.

Conflict of Interest

Conflicts of InterestIn conducting our business, we always expect one another to act fairly and honestly in all

relationships. This means that our business decisions should be made free from any conicts of

interest. In general, we and our families should never:

• Use our position or inuence to get an improper benet

• Use condential Noble information for our own personal gain

• Take advantage of inside information for personal gain

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Field Notes

Noble Corporation • June 2011

Conicts of interest can occur when our outside activities or

interests conict or appear to conict with our responsibilities to

Noble. Conicts of interest can occur when:

• An employee, consultant or family member has an interest in an

outside company doing business with Noble where there is anopportunity for preferential treatment to be given or received;

• An employee or consultant serves in a management or director

capacity at another company in the contract drilling or energy

services industry;

• An employee or consultant discloses condential information

about Noble’s business without permission to someone outside

the Company;

• An employee buys, sells or leases equipment or property to or

from Noble without permission;

• An employee accepts gifts or extravagant entertainment from

someone soliciting business from Noble.

Avoid these or other activities that could have the appearance

of a conict of interest, whether or not an actual conict exists. We

should always strive to deal fairly and openly with our customers,

vendors and competitors.

Related Sections: Gits and Hospitality and Anti-Bribery


• Familyisabroadtermandincludesyourand

your spouse’s immediate and extended amilies

• Ifyouwishtoparticipateinapersonalactivity

which you eel may create a confict o interest,

put all details in writing and obtain proper

approval rom your supervisor or HR rst

• Youarenotallowedtoworkforacompetitor

as a consultant or board member.

See Administrative Policy Manual Section 7 for more details

Q:My spouse is a sales manor one o our vendors. In

new position, I am responsibleprocurement and will have to wwith my spouse’s company. I know

I will be able to deal airly and wiin Noble’s best interest. Is this a cono interest?

A:Yes. Conficts o interest caeither real or apparent.

conficts exist when outside intemay directly infuence decmaking. Apparent conficts exist wa skeptical viewer might reasonbelieve interests exist that may ca

decision to be infuenced. You shcontact your supervisor as this would be a real confict.

Q:I am considering taking a ptime job in addition to my

at Noble. Would this be a confiinterest?

A:Consider several abeore taking another job

this job impair your ability to per

your job at Noble? Will youcompeting against Noble or woror or acting as a vendor or Nobthe answer to either o these questis yes then taking the job will cra confict o interest. Regardleswhether you believe there may confict o interest, you should rspermission rom your supervisor.

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Gifts and HospitalityOur relationships with our customers and suppliers are an important part of our business.

To maintain those relationships, from time to time it is customary to oer nominal forms of gifts

and hospitality. However, we should avoid situations where gifts and hospitality can inuence

our business decisions or create real or implied obligations, either for Noble or our businesspartners. Gifts should always:

• Be legal

• Serve a valid business purpose

• Be of modest value

• Be authorized

We may never give or accept gifts that are illegal in nature, gifts in cash or cash equivalents,

or gifts that will or appear to inuence Noble or our business partners in making a business

decision. We may never give a gift that could be seen as a bribe or a method of obligating

someone else to provide a good or service for Noble’s benet. In general, we may never give gifts

to a government ocial, as these gifts could violate certain laws and regulations.

Related Sections: Gits and Hospitality and Anti-Bribery

Insider DealingBecause of our employment at Noble, we are at times privy to certain information that is

considered “material non-public information” concerning Noble. “Material” information is

information that a reasonable investor would consider important when deciding to buy or sell

stock. “Non-public” information is information that is known within the Company but has not

 been publicly released.


• Ifyoufeelthatacceptingagiftfromoneof

our business partners will obligate you to

provide preerential treatment to that partner,

do not accept the git. We should always beree rom conficts o interest when making

business decisions

• Noblestandardsforgiftgivingshouldbe

applied when receiving gits as well

See Administrative Policy Manual Section 7 for more details

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Field Notes

Noble Corporation • June 2011

Q:One o our vendors has oto take me on a hunting

Can I accept the oer?

A:Consider two points be

accepting any git rombusiness partner. First, is the gihospitality related to conducor discussing business? Secondthe git or hospitality reasonin value considering your leveNoble and your interactions the business partner? I the anto these questions is no or uncobtain approval beore accepting

  git. Either way, you should co

with your supervisor i a git coulconsidered more than o modest v

Q:My riend is interestedinvesting in Noble stock

has asked me i now is a good to invest. I know we have a ew contracts coming up. What shoutell her?

A:Because you have inormaabout Noble that may

both material and non-public, aoering advice or opinions abuying and selling Noble’s securAdvising your riend could considered “tipping,” which is illeg

It is illegal to buy or sell Noble securities based on “material

non-public information.” Some examples of potential material non-

public information include:

• Financial forecasts

• Sales information• Stock splits

• Proposed mergers and acquisitions

• Marketing plans

• New or lost contracts

• Changes in top management

It is also illegal to “tip” others outside of Noble. “Tipping”

occurs when you advise others outside Noble when to buy or sell

Noble securities based on material non-public information.

Certain employees may be asked not to buy or sell Noblesecurities during a specic time period (“blackout period”). In these

circumstances, the aected employees should not buy or sell Noble

stock until notied by the Company.


• Ifyouareunsurewhetherinformationis

“material” consider the impact on Noble’s

stock price; i you think the inormation may

aect Noble’s stock price, the inormation islikely material

• Insidertradingrestrictionsapplytoemployees,

their spouses, minor children and other adults

living in an employee’s households

• Employees,ofcersanddirectors,orfamily

members, may not engage in trading o

publicly traded options on the Company’s stock

or engaging in short sales o the Company’s


“Material” - Inormation that a reasonable investor

would consider important when deciding to buy or sell


“Non-Public” - Inormation that is known within the

Company but has not been publicly released.

See Administrative Policy Manual Section 7 for more details

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N oble is commiedto maintaining

the highest level of 

 professional andethical standards inthe conduct of ourbusiness.


Anti-Bribery and Anti-CorruptionWe place the greatest importance upon our reputation for honesty, integrity and high ethical

standards. We have a fundamental commitment to comply with all applicable laws, foreign and

domestic, governing the conduct of our operations worldwide. This commitment includes lawsagainst bribery and corruption such as the United States Foreign Corrupt Practices Act (FCPA)

and the United Kingdom’s Bribery Act.

The foundation of anti-bribery laws is the prohibition against the payment or oer of

payment of anything of value in order to assist in obtaining or retaining business or to secure

any improper advantage.

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Field Notes

Noble Corporation • June 2011

These laws also prohibit making any payment or oer of

payment of anything of value to any other person, such as an agent

or consultant, while knowing or having a reasonable belief that all ora portion of the payment will be given or oered to a foreign ocial.

Because of this, it is important that authorized agents and consultants

uphold the same values of honesty and integrity that we ask of our

own employees.

Government OfficialsThe FCPA prohibits payments to non-U.S. government ocials,

and it denes foreign ocials are broadly. The denition includes:

• Any ocer or employee of a government or any department,

agency or instrumentality thereof• Any person acting in an ocial capacity or on behalf of any

such government or governmental department, agency or

instrumentality (including government-owned companies, such

as national oil companies, or NOC’s)

• Any ocer, employee or other person acting for, or on behalf

of, a “public international organization” (such as the World

Bank, the International Monetary Fund, or the Inter-American

Development Bank)

The UK Bribery Act prohibits improper payments to government

ocials and to others who are not government ocials. Nobleemployees must be in compliance with all anti-bribery laws,

including the FCPA and UK Bribery Act as applicable.

Gifts and hospitality for government ocials are very sensitive

areas. Before oering gifts of any sort to a government ocial, take

extreme caution to ensure that the gift is consistent with Noble policy.

Under anti-bribery rules, excessive hospitality can also be considered

a bribe. You should always consult Noble’s policy or contact the

Corporate Compliance or Legal Department before giving a gift of

any kind to a government ocial, or if you are requested to provide

any hospitality to a government ocial, such as travel, lodging, mealsor entertainment.

AgentsIn some circumstances, we may have a need to hire an agent in

order to conduct our business. We dene agents as third-parties who

represent or act on behalf of Noble. Agents are sometimes companies

or individuals and are often referred to as intermediaries, sponsors or

Q:We have some markeitems, such as coee mugs

calendars with Noble logos. Onour contacts at a government owcustomer requested a ew items.

we give him marketing items?

A:Small items designed marketing or promotion

  generally acceptable, as these are reasonable in nature and arethe purpose o promoting Nobusiness. I you are ever uncontact Corporate Compliance.


We need an inspecperormed or one o our

The government inspector inorus that he will need Noble to proor his travel and lodging in oto complete the inspection. Is allowed?

Q:Providing travel and lodor government o

is a sensitive area. I the inspeccannot be perormed without Nproviding or the travel, it ma

allowed. However, travel and lodmust be reasonable and must nbe or the purpose o infuenthe inspector. Contact CorpoCompliance or guidance.

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consultants. We also dene vendors as agents when they perform any services on Noble’s behalf

that involve interfacing with a foreign government or government ocial such as marketing,

customs-clearance, freight-forwarding or other services.

We expect our agents to adhere to the same values of honesty and integrity that we expect

from our employees. We should conduct proper due diligence coordinated through the Corporate

Compliance before hiring an agent to ensure that the agent conducts its business in an ethical

manner. We also expect our agents to annually aest that they are conducting their business in

accordance with anti-bribery laws and Noble’s anti-bribery policies and procedures. We have an

obligation to continuously monitor the conduct of our agents to be reasonably certain that they

are upholding our policies against bribery and corruption.

Agent relationships and the procedures for hiring agents are complex. Whenever we hire or

do business with an agent, rst consult the Corporate Compliance to ensure that proper diligence

(or “veing”) has been conducted.

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Field Notes

Noble Corporation • June 2011

Fair CompetitionOne of the most dicult aspects of our business is competing

in markets with heavy competition. While Noble is commied to

aggressively competing in all markets in which we do business, we

seek to outperform our competition fairly and honestly. We will

seek competitive advantages through working smarter and harderthan our competition, never through unethical or illegal business

practices. We must never take unfair advantage of anyone through

manipulation, concealment or any other intentional unfair practices.

Generally, anti-trust laws prohibit us from performing certain

activities which harm competition, including:

• Sharing Noble pricing and other sales information with our


• Agreeing with competitors to allocate customers, x prices or

limit production• Sharing misleading or unjustied criticism of a competitor’s


Anti-trust laws are strongly enforced. While some activities

covered by anti-trust laws may seem reasonable, we must be careful

to never harm or appear to harm competition in any market in which

we operate.

Q:I am riends with one obusiness partners at an

outside o work. Can I pay ordinner i it is on my personal time

A:Regardless o riendship, uyour own money or bon your own time doesn’t elimthe issue. As a Noble employeeimproper purpose could stillimplied and the expense couldconsidered Noble’s regardlesswhether or not you are reimburse

Q:When I was leaving a orcountry at the end o

hitch, the immigration ocer at

airport asked “do you have sometor me?” while he waited to promy paperwork. It seems clear thwants money beore he will allowto proceed. Should I pay somethin

A:No. Noble’s policy prohsuch payments wit

specic approval. In such a situayou need to explain that you ca

 give him anything and that i you

you could loose your job or evenprosecuted by authorities back hYou are obligated to understandollow Noble’s policy.

Q:I am on the board oindustry group. Our mee

are attended by employees o sevo our competitors. What should I

A:The group should an antitrust statem

that outlines your duties to adiscussions about pricing or ocompetitive matters. This statemshould be read at each meeting. Duyour meetings, make sure to distopics relevant only to your groupavoid discussions o Noble’s or competitors’ business.


• Ifyouareamemberofatradeorganizationwhich has members rom our competitors,

make sure the organization maintains and

enorces its own anti-trust statement

• Ifyouhaveaconcernthatanagreementor

proposed agreement may violate anti-trust

laws, ask the Legal Department; anti-trust

rules are complex and can vary depending on


See Administrative Policy Manual Section 7 for more details

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International OperationsNoble provides services in many parts of the world. Many countries have specic laws

and regulations governing the import and export of assets and goods, international trade and

immigration. As a global company, Noble is subject to many dierent regulations in many

dierent countries and has a responsibility to understand and comply with these laws andregulations to maintain our ability to operate.


• Makesureallduediligencehasbeen

completed beore doing business with a new


• Ifaninvoiceortransactionseemsunusual

speak up and ask questions

See Administrative Policy Manual Section 7 for more details

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Field Notes

Noble Corporation • June 2011

Q:We started using a new reorwarding company. W

I reviewed the invoice, I noticed they shipped some goods throucountry where we have never d

business. Is this OK?

A:International trade   govern not only the o

and destination o goods, but alsocountries through which the gtravel. Alert Global Supply Chaithe Legal Department or reviewapplicable requirements regardingnew country.

Trade ControlsWe must comply with all applicable import and export laws

and regulations and be aware of the country of origin of the items

  being exported and imported, including any restrictions or license

requirements. Imports or exports made on behalf of Noble mustcomply with any applicable trade regulations. Understanding the

countries involved directly and indirectly in both the trade of the

goods as well as the manufacture, origination and transportation of

the goods is imperative, as many countries have rules regulating or

limiting trade with other countries.

International trade laws generally impact our operations and

our indirect operations through our suppliers. We must be compliant

and we must understand our suppliers and how they will provide

services, including how the goods will be manufactured and shipped,

to ensure they are compliant. Contact Global Supply Chain or theLegal Department for guidance and see the Administrative Policy

Manual Section 7 for more details.

Global SecurityNoble will never knowingly participate in activities that

directly or indirectly aid in criminal or terrorist activities around

the world. This includes a commitment to never knowingly buy or

sell technology or goods that will be used for purposes associated

with chemical, biological or nuclear weapons or missiles capable of

delivering such weapons, nor will Noble buy or sell technology or

goods that we suspect will be used for such purposes.

Money LaunderingMoney laundering occurs when criminals hide money from

criminal activity in legitimate business dealings. Noble takes steps

to prevent criminals from using business transactions with Noble to

launder illegal funds. Specically, Noble will not do business with

a known criminal or criminal organization, will perform appropriate

 background checks on business partners and aliates, and will report

suspicious transactions or incidents.

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W e should allendeavor to

 protect Noble’s assets

and ensure thatwe are using themeciently.

Protecting our Assets

Theft, carelessness and waste directly impact our ability to do business. Noble will not

tolerate misuse of our Company assets. Our assets take many forms, including property and

equipment, intellectual property, condential information, information technology and even our


Property and EquipmentProperty and equipment are the tools we need to do our jobs. These include computers,

oce supplies, oce facilities and operational equipment. These tools should only be used

while at work and only for business purposes. In certain approved circumstances, reasonable

and appropriate incidental personal use may be permied, but we should all use discretion

when using Company resources for personal activities. Company tools should never be used for

unintended or unauthorized purposes.

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Field Notes

Noble Corporation • June 2011

Noble has procedures governing proper use of property

and equipment, including procedures for safe use and for properly

safeguarding our assets. These procedures should be followedat all times.

Intellectual PropertyOur innovation is essential to our continuing success in the

market. This innovation leads to new inventions, discoveries,

process improvements, computer programs and other proprietary

information. This information is an important asset and must be

protected. We should:

• Never disclose the information to others outside Noble, taking

special care to not discuss sensitive information in public placesor in situations where we may be overheard

• Never use this information for personal benet

• Obtain approval before discussing trade secrets in speeches,

technical papers and Noble publications

All proprietary information we create while working at Noble is

and remains the property of Noble even after employees leave.

Q:My personal truck nrepairs. We have some too

the Noble warehouse that would me x it. Can I use these tools?

A:No. Noble has proced  governing the sae use oproperty and equipment. Using ttools or personal purposes alls ouo these procedures and represunsae and unauthorized use.

Q:As part o my job I oten wwith condential docum

What do I need to do to protectcondential inormation whetravel?

A:Always keep condeinormation in a secure p

I you have condential inormaon your laptop computer, do not cit with an airline. Never leave sensdocuments in an unattended psuch as a parked car. Always be awo your environment when dewith sensitive documents. Do work with sensitive documents

place where others can easily overs

Q:I have trouble remembemy password to log-in

Noble’s network. Can I leave a nomysel on my desk?

A:Passwords are just one ocontrols in place to pro

our assets through our network. Nleave your password in a place wothers can see it or give someone

your password.

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Information TechnologyToday, much of our condential and proprietary information is stored in our IT system.

To protect this information, Noble uses certain IT controls and procedures such as passwords,

encryption and other access controls. Noble will ensure that the controls remain up-to-date and

capable of preventing intentional or unintentional breaches in our information security. To avoid

unintended consequences and jeopardize our security, do not circumvent, alter or remove ITcontrols without proper approval.

Terminated employees must return all Noble equipment, including computer and other

IT resources.


• InformationstoredonyourNoblecomputeris

the property o Noble, even i the inormationis personal in nature

• CheckwithTravelandITbeforeembarking

on international business travel to ensure

necessary precautions are observed to ensure

Noble’s property is protected.

See Administrative Policy Manual Section 8 for more details

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Field Notes

Noble Corporation • June 2011

Q:I created a contract wwe signed with one o

suppliers. Am I responsible or keeour copy o the contract?

A:I you created a documyou may be responsiblethe document as the record hoConsult the Records ManagemPolicy or the proper method duration or retaining documents.


• YoumayreceiveamessagefromtheLegalDepartment inorming you that certain records

are subject to a legal hold; in these instances,

you must comply with records retention

instructions rom the Legal Department

• Whenyoucreateadocumentsubjecttothe

Records Management Policy, make sure to

understand whether you are the record holder

and your responsibilities under the Records

Management Policy

See Administrative Policy Manual Section 8 for more details

Records ManagementRecords are valuable assets. Proper records management allows

us to retrieve information eciently, dispose of records properly,

and respond to legal holds on records.

Our records take many forms, including contracts, invoices,

accounting records, legal documents, receipts and many others.

It is vital to our business that we properly maintain these records

in accordance with our Records Management Policy as well as

applicable laws and regulations.

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W e adhere to aconservative

 nancial policy

and disciplinedoperationalmind-set tounderstand andmanage nancialand operationalrisk and delivershareholder value.


Financial Accounting and ReportingNoble must prepare our books and records accurately and honestly. This responsibility falls

on our employees and management and external accountants who help us prepare our books

and records. We must all contribute to maintaining accurate books and records in our day-to-day activities by accurately completing tasks such as preparing expense reports, time sheets and


Fair and accurate books and records are essential to properly managing our company.

Noble maintains internal controls that help ensure that our records are accurate. We must never

knowingly circumvent these controls by removing the controls or working around them. We

should work to improve existing controls if we feel that the existing controls do not adequately

prevent fraud, waste or inaccurate records.

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Field Notes

Noble Corporation • June 2011

Noble is subject to certain regulations which dictate how we must

maintain our records, such as the Generally Accepted Accounting

Principles (GAAP) and the Foreign Corrupt Practices Act (FCPA).

Noble will maintain our books and records in a manner consistent

with all applicable laws and regulations. In addition, Noble will take

the necessary steps to plan for and comply with new accounting

standards such as the International Financial Reporting Standards.

DisclosureAll public communication made by Noble, such as periodic eet

or nancial reports and other lings with the Securities and Exchange

Commission, must be timely, understandable, fair, complete and

accurate. We must never knowingly misrepresent, omit or cause

others to omit material facts from our public disclosures. We are

commied to the truthfulness of all reports that we present to the


In addition to our own employees, others, such as our

independent auditors, help ensure that our disclosures are fair

and accurate. We must never directly or indirectly induce, coerce,

manipulate, or mislead our auditors to render misleading statements.

Inaccurate public reports can damage our reputation and our

ability to conduct business in the future. Disclosures to the public

must have the approval of the CEO or Executive Vice President.


• Ifyoufeelthatanyofourbooksandrecords

contain errors, misrepresentations or alse

statements, alert the Chie Financial Ocer or

Internal Audit.

• Don’ttakeshortcutsaroundnancialcontrols

These controls help prevent errors, both

intentional and accidental.

• Ifyoufeelthatanyelementofapublic

disclosure is inaccurate, speak up; alert seniormanagement or the Legal Department

• Ourindependentauditorshelpusmaintain

accurate books and records. Always be honest

and truthul with the auditors

See Administrative Policy Manual Section 6 for more details

Q:I have trouble keeping to my expenses when I

traveling, so I normally just estimy total expenses on my expreport. Is this OK?

A:Our expense repoprocedures help ensure

our books and records are accuYour expenses become part o nancial statement. I you misstated your expenses, our nastatements could become misstMake sure to accurately documyour expenses and ollow all exp


Q:Our auditor asked ew questions about s

nancial transactions. I don’t time to research the answer. Can Ihim my best approximation?

A:Our independent audplay an important rol

making sure our nancial statemare air and accurate. Alwaysopen and honest with the aud

and never provide inormathat is exaggerated, alse or poscontains errors. Let the auditor ki you need more time to researchtransaction to give an accurate ansdon’t guess.

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We are fully commied to operating our business with honesty and integrity. We all sharethis responsibility. Noble has dedicated resources and contacts to discuss issues found in this

Code of Business Conduct and Ethics.

Important ContactsHuman Resources: +1-281-276-6655

Compliance: +1-281-276-6178

Legal: +1-281-276-6155

Finance +1-281-276-6212

Internal Audit: +1-281-325-7043

HSEQ: +1-281-637-6021

Reporting Issues and ConcernsIf you have a reasonable and good faith belief that there is or may be a violation of the law,

this Code or any Company policy by the Company or anyone acting on its behalf, then you

are obligated to report the issue, whether or not you are in any way involved. An issue can be

reported by bringing it to the aention of a senior manager of the Company or by contacting an

appropriate employee resource.

Employees are encouraged to talk to supervisors, managers or other appropriate personnel

about suspected illegal or unethical behavior. When in doubt about the best course of action in

a particular situation there are resources available to employees which include the NobleLine.

The NobleLineThe NobleLine is an anonymous resource for all our employees worldwide to report any

concerns – ethical, environmental, safety or otherwise – that are not or might not be addressed

 by our normal chain of command. The NobleLine is toll-free and Available 24/7.

Number: 1-877-285-4162

When calling from outside the United States, you can easily call the NobleLine without a

fee. Just dial the USADirect access number for the country from which you’re calling and follow

the voice prompts. Alternatively, from outside the United States you can also call the following

number collect, reversing charges:

Collect: +1-704-544-2879

Employee Resources

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Field Notes

Noble Corporation • June 2011

You can identify the country-specic direct access code from the

list below or via the Internet at:


Angola 808-000-011

Australia 1-800-881-011 (Telstra)

1-800-551-155 (Optus)

Brazil 0-800-890-0288

or 0-800-888-8288

Brunei 800-1111

Canada 1-800-Call-ATT

or 1-800-2255-288

Cameroon Call Collect

China 108-888 (Northern)

or 108-11 (Southern)

Denmark 800-100-10

Egypt 2510-0200 (Cairo)

or 02-2510-0200 (Other)

Hungary 06-800-011-11

India 000-117

Libya Call Collect

Luxembourg 800-201-11

Malaysia 1-800-80-0011

Malta 800-901-10

Mexico 01-800-288-2872

or 001-800-462-4240

Morocco 00-211-0011

New Zealand 000-911

Nigeria Call Collect

Norway 800-190-11

Philippines 105-11

Qatar Call Collect

Singapore 800-011-1111

or 800-001-0001Spain 900-99-0011

Switzerland 0-800-89-0011

The Netherlands 0800-022-9111

United Arab Emirates 0-800-121 or 0-800-161

United Kingdom 0-800-89-0011

or 0-500-89-0011

Vietnam 1-201-0288

Q:How is it that the NobleLian anonymous resource t

can trust?

A:The NobleLine is han

through a third-party is trained specifcally or this typservice. Issues sent to the NobleLinorwarded to Corporate CompliaI you choose to not give your nto the operator they will still your call. They will also providewith a unique code that you canto call back to provide additiinormation or check on the statuyour report.

Q:What i English is not mylanguage; will they be ab

take my call?

A:The NobleLine operatorssummon a person abl

communicate in your native languIt is important that you are paduring this process as it may take amoments to bring the person online.

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