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Ethics and Compliance

We expect corporate, professional and personal responsibility from all of our employees and compliance with high ethical standards to achieve operational excellence. In addition to the corporate governance oversight provided by the Board and its committees, management observes and enforces our Code of Business Conduct and Ethics (“Code”) described on our website. Our Code, which was revised and reissued in 2019, provides employees with the tools to make consistent, ethical decisions and emphasizes the duty to report any concerns or violations. Our Code reflects every employee’s responsibility and commitment to our stakeholders: each other, our customers, our suppliers, our environment, our stockholders and society at large.  We have additional ethics and compliance policies and procedures that are also located on our website, including our Code of Ethics for Principal Executive Officer and Senior Financial Officers and our Foreign Corrupt Practices Act Compliance Policy. 

Awareness of our ethics and compliance program is emphasized through training of employees. We foster a culture of trust and transparency and frequently remind our employees that they are encouraged to ask questions and report concerns. To empower every employee to promote responsible behavior, we have implemented an independent and anonymous reporting mechanism for employees to voice concerns pertaining to our Code, policies or compliance with law without fear of retaliation. Our Ethics Hotline, administered by a third-party, provides a convenient and confidential channel for employees and non-employees to report any suspected compliance concerns or complaints. The Company’s legal department carefully monitors, tracks and investigates allegations of violations of the Code and other ethics and compliance policies and procedures. Material hotline complaints are shared with the chair of the audit committee in real time, and are reported to the Board’s Audit Committee on a quarterly basis.           

In addition to our ethics and compliance program, the Company has an active internal audit department.  The activities of, and audits conducted by, the internal audit department serve to monitor and strengthen our corporate governance practices, as well as our internal controls and business and accounting processes which ultimately results in increased compliance.  Our internal auditor has a direct reporting line to our board of directors.

 

How and Why We Invest

We have corporate policies that govern political expenditures and lobbying activities, including policies that address political activities and expenditures in the context of use of corporate funds and assets, anti-corruption, trade compliance and sponsorships and endorsements. 

While these policies and controls are in place, the Company does not have a PAC and we do not engage in lobbying activities or make significant political expenditures, nor does it currently plan to do either in the future.  When the Company has engaged in political activities, it is on regulatory issues that directly impact our business and in a non-partisan manner.    

Some consider trade and professional associations memberships and contributions when referencing political and lobbying expenditures.  The Company belongs to various trade associations such as the International Association of Drilling Contractors, (“IADC”), the Society of Petroleum Engineers (“SPE”) and the American Association of Drilling Engineers (“AADE”) and sponsors employee memberships to these organizations as well as memberships to other professional associations across the various professional disciplines of our employee base. 

We believe membership in such trade and professional associations is beneficial for our employees’ evolving skillsets and industry knowledge and for the Company as a leader within our industry. The cumulative annual spending on these memberships is inconsequential representing only a very small fractional percentage of general and administrative expenses.