Safety | Integrity | Quality | Respect | Sustainability

Our Code of
Business Conduct
English
Safety | Integrity | Quality | Respect | Sustainability

2
We are all responsible

Our vision is to enhance the performance

of the world’s energy industry, and how we
do business is as important as why we do
business. We act ethically, lawfully, and in
accordance with our core values and our
foundational beliefs in all that we do.
We never compromise on safety, integrity,
quality, respect and sustainability in the
decisions we make, and our Code of Business
Conduct is built on these foundational beliefs.
Our Code gives us a common language and
playbook for decisions and actions that help
us live our core values. The Code applies to
all of us – no matter what our role, no matter
where we work.
It is up to all of us – we must all uphold the
principles in the Code to ensure that we meet
our ambitions and succeed today and in
the future.
 

Doug Pferdehirt
Chief Executive Officer
Safety | Integrity | Quality | Respect | Sustainability

Table of contents

2
Introduction
What is TechnipFMC’s Code of Business Conduct? 4
What is our role? 5
What are our core values? 6
What should you do if you have a concern? 8
Will you get in trouble for reporting? 9
Our response to concerns 10
Getting trained on our Code of Business Conduct 11

Protecting people and the environment

Behavior at work 14
Fair employment practices and equal opportunity 15
Health, Safety, and Environment (HSE) 17
Human rights 18
Community involvement 19
Immigration compliance 19
Security 20

Protecting assets and information

Protection of intellectual property 24

Accurate books and records 26
Information security 30
Privacy and personal data 35
Insider trading and stock tipping 36

Protecting business and brand

Anti-corruption 41
Gifts, entertainment, and hospitality 46
Donations and charitable contributions 49
Conflict of interest 50
Money laundering 53
Export controls and trade compliance 54
Competition and antitrust laws 56
Quality leadership 58
Political activities 59
Corporate image and brand 60
External communications 61
Social media 62

Table of contents | 3
Safety | Integrity | Quality | Respect | Sustainability

What is TechnipFMC’s
Code of Business Conduct?
This Code of Business Conduct (our Code) is built on
our core values and foundational beliefs.
The Code describes the decision-making and behaviors
expected of you and of the company when dealing with
each other and our stakeholders. It is intended to give
you additional guidance to ensure that we do business
and conduct ourselves in a TechnipFMC way.
This Code works in conjunction with our policies
and procedures, which are published on our internal
website. Do not hesitate to refer to them when you
need a fuller explanation of TechnipFMC’s principles.

4
What is our role?

Each of us plays a role in maintaining the

company’s reputation, and together we create
the TechnipFMC culture.

Our Code applies to each of us:

All directors, officers, and employees

All employees of our subsidiaries and affiliates
 nyone who represents TechnipFMC or acts
A
on our behalf, including contract employees,
partners, subcontractors, suppliers, contractors,
agents, and sales agents

We are all expected to:

Live Lead Support

Read and understand the guidance Help other team members follow our Create an environment that encourages
provided in this Code of Business Code through leading by example and other team members to raise ethical
Conduct and our policies, and live providing training on the issues your concerns early.
them every day. business faces most often.

Report Stop
Report behaviors that may violate Intervene, without hesitation, to stop
the guidelines set out in our Code any activity by others that conflicts
and our policies. with our policies or our Code.

Sharing our Code:

We aspire to develop business relationships with like-minded

clients, subcontractors, suppliers, and business partners who
are guided by a similar set of principles of business conduct.

This Code should be shared and discussed with clients,

suppliers and our business partners to better explain our
rules of conduct and reinforce our culture of accountability.

Introduction | 5
What are our core values?

Our values reflect how we do business and conduct

ourselves every day. They define our aspirations and
the company we want to be. They are the drivers
in building a global, collective sense of identity.
Values guide how we act — with ourselves, each
other, and our clients, partners and stakeholders —
to reinforce the TechnipFMC way.
We have values because our individual behaviors
and actions make a difference. Applying our values
every day helps us achieve our ambitions and
succeed today and in the future — as we enhance
the performance of the world’s energy industry.

6
Our core values

Our core values are the drivers that guide how we act in a
distinctly TechnipFMC way, so we can deliver on our purpose
and achieve our vision. We bring our values to life through our
behaviors — specific, observable and measurable actions.

Realizing possibilities Achieving together Building trust

We relentlessly progress and seek We work as a single team, We collaborate transparently to
new, innovative solutions, exploring all collaborating and sharing in order address what truly matters and
opportunities to maximize our potential to make the greatest impact always deliver what we promise

We strive for ever better We work as one team We listen to improve

We continuously improve and We prioritize collective success and We listen carefully to deeply
innovate how we work and what work toward common goals together understand what matters most
we deliver and focus on how to address it
We share knowledge
We take initiative We communicate openly and We partner constructively
We proactively work to reach volunteer our knowledge and We work closely and transparently in
our highest potential in everything insights to help others reach true partnership, tackling challenges
we do their best with a positive mindset

We learn from success and failure We embrace diversity of thought We seek to outperform
We learn from every step we take We welcome new ideas to unlock our We are focused on doing the job
to constantly progress and find shared potential — no one knows as right and aim to deliver beyond
better ways much as everyone the expected

Our foundational beliefs

Our foundational beliefs are the cornerstone of our values

that describe how we fundamentally do business and what
we never compromise on, no matter the circumstances.

Safety Integrity Quality

We will not compromise on health, We hold ourselves to the highest We deliver the highest quality
safety, and security moral and ethical principles in everything we do

Respect Sustainability
We treat everyone honestly, fairly, We act responsibly, always considering
and courteously our impact on the planet, people, and
communities in which we operate

As you read through our Code, you will see how the
foundational beliefs are tangibly embedded in each chapter.

Introduction | 7
What should you do if
you have a concern?
If you are unsure how to resolve a situation, Are the actions legal?
ask yourself these questions:

Are the actions consistent with

TechnipFMC’s foundational beliefs
and core values?
Do the actions set a good example?
Would I be comfortable talking
about the actions with my
colleagues, family, and friends?
Have I asked for advice from others
who have knowledge of the topic so
I can make an informed decision?
If you answer no to any of these questions, a violation
of our Code or policies has occurred or may occur, and
you have the responsibility to report it.

The important thing is to not leave your concerns

unresolved.

You can report your concerns through any Your direct manager or someone
of these channels:
else in your management.
No matter what reporting channel you use, the Chief
Compliance Officer will receive the complaint and make
sure the information is collected and stored securely.
The Chief Compliance Officer or
anyone in Corporate Compliance.
Any officer of the company.
Your Human Resources
representative.
Your regional legal department.
An independent third party via the
dedicated reporting hotline.

8
Will you get in trouble
for reporting?
TechnipFMC has a zero-tolerance policy on
retaliation against employees for reporting
suspected violations of our policies or Code
of Business Conduct.
We encourage employees and others to raise
questions and concerns to ensure that we are
leading by example.
Retaliation against anyone who makes a good-
faith report of possible violations of our Code
or policies, or cooperates with an investigation,
is strictly prohibited.
Report the details of retaliation to your
Regional Compliance Counsel, anyone in the
Corporate Compliance department, or to
the Chief Compliance Officer right away.

Introduction | 9
Our response to concerns

We treat all reports of suspected violations of our Code

confidentially and will share the information only with
those who “need to know” to investigate and properly
resolve the issue.
If you are asked to participate in an investigation, you
must assist honestly and openly. In certain circumstances
and in accordance with applicable laws, when
investigating concerns, TechnipFMC may access, review,
and disclose information processed or stored by the
company’s equipment, devices, or computers.
We will quickly investigate all reports and take necessary
action, including disciplinary action when appropriate.

Situations that can lead to disciplinary action include:

Violating the Code, standards, Asking others to violate our Failing to report a known or
or policies. Code, standards, or policies. suspected violation of our
Code, standards, or policies.

Failing to cooperate honestly and Retaliating against anyone who Knowingly reporting a false
openly with an investigation of makes a report of a possible allegation of possible violation of
a possible violation of our Code, violation of our Code, standards, our Code, standards, or policies.
standards, or policies. or policies.

Anyone who is responsible for inappropriate conduct

or retaliatory measures will be subject to disciplinary
sanctions in accordance with applicable rules and
regulations, which can include actions up to termination.

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Safety | Integrity | Quality | Respect | Sustainability

Getting trained on our

Code of Business Conduct
Several Code of Business Conduct training courses will
be made available. Our training programs are key to
reinforcing ethics, compliance, and competence in our
company. You are expected to accept Code-related
training requests. Speak with your manager about
any training you wish to take.

Introduction | 11
Safety | Integrity | Quality | Respect | Sustainability

Our Code of Business Conduct

Protecting people and

the environment

Behavior at work 14
Fair employment practices and equal opportunity 15
Health, Safety, and Environment (HSE) 17
Human rights 18
Community involvement 19
Immigration compliance 19
Security 20
Safety | Integrity | Quality | Respect | Sustainability
Safety | Integrity | Quality | Respect | Sustainability

Behavior at work

We believe that all our employees are entitled to fair

treatment, courtesy, and respect, wherever they are
working – in the office, on vessels, on industrial and
construction sites, or in client offices.

How to behave Always

Trust the team and do not accept any disparagement of Be open-minded, transfer our knowledge, and share
colleagues. Every achievement and every failure should information as needed, subject to TechnipFMC’s rules
be shared. on confidentiality.

We will maintain a culture of trust and mutual respect Create a positive work environment and report any
and dialogue throughout our business. We listen, harassing behavior.
motivate, and support others to achieve common
Foster an objective approach based on mutual respect to
objectives, and we value the contributions of others.
recognize each other’s contributions.
We do not tolerate any form of abuse or harassment and
Encourage your team to report any instance of harassment
will not tolerate any action, conduct, or behavior that is
such as physical or social isolation (silent treatment) or
humiliating, intimidating, or hostile.
indecent proposals for employment advantages.

Speak up and tell a person if you are upset by his or

her actions or behavior. Explain why and ask that the
behavior stop.

Never

Engage in physical or verbal behavior that could be

characterized as offensive, intimidating, malicious,
or insulting.

Make unwelcome sexual suggestions or advances.

Make racial, ethnic, religious, age-related, or sexual jokes

or insults. If you are not sure whether something is
appropriate, assume that it is not.

Distribute offensive materials, including inappropriate

pictures, jokes, or cartoons.

Disclose personal information or spread malicious rumors.

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Safety | Integrity | Quality | Respect | Sustainability

Fair employment practices

and equal opportunity
Our hiring and employee development decisions are
fair and objective. Therefore, employment decisions
will be based only on qualifications, performance,
skills, and experience.

How to behave Always

Because we strive to create a positive work environment, Make sure your employment decisions related to
it is not uncommon for us to attract members of the same recruitment, selection, evaluation, compensation,
family to be our employees. development, etc., are not influenced by: race, color,
religion, gender, age, ethnic origin, nationality, sexual
We ensure that employment-related decisions are based on
orientation, marital status, or disability.
relevant qualifications, demonstrated skills, performance,
and other job-related factors.

We ensure that our suppliers, customers, and business Never

partners are aware of our goal of creating a diverse and
Tolerate unlawful discrimination related to employment.
tolerant workforce.
To avoid even the appearance of a potential conflict of
interest, do not:

Maintain a direct or indirect reporting relationship with

a family member.

Interfere in any aspect of your relatives’ employment

(recruitment, selection, evaluation, compensation,
development) during their career with the company.

Protecting people and the environment | 15

 We strive to implement
the most efficient and
environmentally friendly
solutions available while
protecting our people and
reducing the impact of
our activities at all times.

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Safety | Integrity | Quality | Respect | Sustainability

Health, Safety, and

Environment (HSE)
At TechnipFMC, we strive to implement the most effective,
efficient and environmentally friendly solutions available
while protecting our people and reducing the impact of our
activities at all times. We will not compromise safety, health,
security or environmental sustainability to achieve results.
We are committed to fostering an incident-free environment
worldwide, based on the principle that all incidents are
preventable. Our clients, shareholders, suppliers, contractors,
partners and employees have the right to expect excellent
HSE performance from us.

How to behave Always

The key to HSE success is a strong culture where all Know and comply with the applicable health, safety, and
employees work together to prevent incidents and take environmental rules and regulations.
ownership of HSE, regardless of their position. A strong
Understand the risks related to a job and implement the
HSE culture relies on visible and effective leadership
required measures and actions to protect health, safety,
and communication of procedures that focus on actively
and the environment and prevent incidents before
managing risks present in execution of our projects.
beginning operations.
This drives a high awareness of our procedures and
empowers our people to get personally involved when Intervene if health, safety, or environmental rules are not
an HSE risk exists. duly respected, and stop an unsafe act or condition.

We expect all our employees to know their role in our

As a manager, you have further responsibility to always:
HSE culture and procedures and why they exist. We
also expect them to act as HSE leaders and take specific Act as role models for others by demonstrating positive
and effective actions that protect the health and safety HSE behaviors.
of our people and minimize the impact of our activities
Make employees, contractors, and suppliers aware of
on the environment.
applicable HSE rules, procedures, and expected behaviors,
and their role in HSE culture wherever we operate.

Ensure that effective health, safety, and environmental

management systems and procedures are in place
and functioning at each area, and that a positive HSE
culture exists.

Ensure that people reporting to them receive the required

HSE-related training, including training in TechnipFMC’s
HSE culture change program (Pulse).

Follow up and correct HSE issues that are brought to

their attention.

Encourage employees to stop working when there is an

unsafe condition and welcome intervention.

Praise good HSE practices and challenge poor ones.

Protecting people and the environment | 17

Safety | Integrity | Quality | Respect | Sustainability

Human rights

We are committed to recognizing human rights on a

global basis. We do not tolerate use of child, forced,
indentured, or involuntary labor, regardless of where
we conduct business.
We will not work with suppliers that source minerals
from conflict zones. We will do business only with
those who respect human rights and uphold labor laws.

How to behave Always

TechnipFMC’s reputation is built on the personal behaviors Treat people with dignity and respect.
of our employees across the world. All of us must
Act without discrimination or prejudice.
understand and follow these principles:
Create an environment that is free from harassment.

Ensure that our business partners and suppliers do not

engage in inappropriate labor practices, including child
or indentured labor.

Promote equality in the workplace with salaries based

on merit.

Cooperate with regular inspections and audits to verify

that our values are implemented throughout the company.

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Safety | Integrity | Quality | Respect | Sustainability

Community involvement

The communities in which we work are important

stakeholders for TechnipFMC, and we strive to be a
responsible corporate citizen.
How to behave

Our employees are encouraged to ensure that TechnipFMC Anticipate and minimize potential disruptions to
is a responsible corporate citizen in our communities. the community.

Always Mitigate any negative impacts to local communities

from our activities.
D
 esign sustainable development initiatives with a focus
on long-term added value. Contribute to local employment growth by fostering
training and transfer of skills and technology.
Engage with local communities impacted by our activities
in close coordination with our clients and contribute to Respect local cultures and be aware of local practices
social and economic self-sustainability. and traditions, legislation, and cultural factors that may
impact behaviors and decisions.

Safety | Integrity | Quality | Respect | Sustainability

Immigration compliance
We are committed to making sure the employment,
travel, transfer, and residence of employees conform
to applicable immigration and employment laws.

How to behave Always

We do not hire or recruit anyone not legally authorized Ensure that you have appropriate visas and other permits
to work in the country in which employment is sought. before traveling into a country.

Each of us is accountable for maintaining our immigration Ensure that you have the appropriate work permits
status in compliance with the laws of the countries in required to be an employee of TechnipFMC.
which we work.
Never

Travel without a passport or other applicable identification.

Misrepresent your identity or fail to disclose applicable

information relating to immigration or employment.

Protecting people and the environment | 19

Safety | Integrity | Quality | Respect | Sustainability

Security

Our objective is to ensure the security of TechnipFMC

employees and our clients and business partners at
our work sites wherever we operate.
Our employees travel all over the world. We are
committed to ensuring their protection during transit
and at their final destinations.

How to behave

Security requires the commitment of everyone to ensure

the protection of all. You are the primary caretaker of
your security. This is why it is essential that you know and
respect the security measures in place at your worksite,
whether that is in an office, a plant, or construction site.

Always Immediately report to your security manager:

 ollow the TechnipFMC security recommendations
F If you are the victim of a theft in the office, on site, or
and travel requirements for the country where you while traveling.
are working.
If you witness a security breach.
 hen you receive a security message following a change
W
in the security of your work environment, comply with the If you receive a package or letter of suspicious origin.
new security measures and ensure that your colleagues Do not open it or try to identify the contents.
are aware of the message. If you see a suspicious or unauthorized person in the
Be aware of the emergency procedures applicable to your office or in a restricted area.
worksite so you know what to do in case of an incident, If you see anything suspicious.
including the location of the muster point.

Follow the general security precautions to reduce your While traveling:

exposure to risks during travel. Ensure that you have a means of communication that
If you receive a package or letter of suspicious origin, do works in your destination country.
not open it or try to identify the contents. Immediately Read the latest security information before traveling to
contact your security manager. a foreign country.
If you see a suspicious or unauthorized person in the Pay attention to personal belongings in crowded places
office or in a restricted area, immediately contact your and public areas.
security manager.
Beware of questionable offers such as advantageous
 nsure that you have the local manager’s duty phone
E exchange rates, sightseeing visits, organized tours,
number in case of a security incident. and offers of free services.
Make sure your badge is visible when you are working in Be sensitive to cultural and religious differences when
the office or on a project site. traveling in a foreign place.
Accompany all visitors in the office or on a project site.

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Safety | Integrity | Quality | Respect | Sustainability

Security requires
the commitment of
everyone to ensure
the protection of all.

Protecting people and the environment | 21

Safety | Integrity | Quality | Respect | Sustainability

Our Code of Business Conduct

Protecting assets
and information

Protection of intellectual property 24

Accurate books and records 26
Information security 30
Privacy and personal data 35
Insider trading and stock tipping 36
Safety | Integrity | Quality | Respect | Sustainability
Safety | Integrity | Quality | Respect | Sustainability

Protection of intellectual
property
Our know-how, technology, and execution are our
differentiation. This is the result of our ideas, our
techniques, and our processes. Collectively this
is called TechnipFMC’s intellectual property, or
confidential information. Our intellectual property
is embodied in our product offerings and becomes
the basis for the solutions that solve our clients’
increasingly complex requirements.

We must all protect

TechnipFMC’s patents,
copyrights, trademarks,
trade secrets, and other
proprietary information.

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Safety | Integrity | Quality | Respect | Sustainability

How to behave Always

We must all protect TechnipFMC’s patents, copyrights, Respect the patent rights of other parties when designing
trademarks, trade secrets, and other proprietary information our products or services.
and be very careful not to unintentionally or improperly
Protect confidential information entrusted to us by our
share our intellectual property.
customers, subcontractors, and suppliers with the same
At the same time, TechnipFMC must ensure that it respects care as TechnipFMC’s confidential information.
the intellectual property rights of others. We must comply
Follow our processes for identifying, capturing, and
with all laws, regulations, and contractual obligations
publishing information about our technical innovations.
regarding the valid intellectual property rights of others.
Disclosing new ideas too soon could jeopardize our
We are responsible for protecting third-party intellectual
ability to obtain patent protection for our innovations.
property that we are authorized to use, and therefore
we must all take the same care with our customers’, Execute timely patent disclosures, applications,
subcontractors’, and suppliers’ intellectual property as we and assignment documents required to protect our
do with our own. intellectual property.

To avoid these risks and to protect our intellectual property, Collaborate with caution. Sharing information about our
we must ensure that new products, software, processes, technology developments and innovations with others,
and services are reviewed for new inventions or trade even our customers, can erode our ability to protect
secrets, and that they do not infringe on the intellectual those innovations.
property rights of others.
Remember, your confidentiality obligations continue
after you leave TechnipFMC.

Discuss the use of third-party intellectual property or

confidential information with your legal department.

Comply with the use of TechnipFMC’s branding.

See the section on Corporate image and brand for
more information.

Never

Divulge a previous employer’s confidential or

proprietary information.

Provide information about a new service or product before

a patent application has been filed or the Intellectual
Property Department has decided not to pursue a patent.

Discuss TechnipFMC confidential or proprietary

information with third parties, except when such
discussions are covered by a duly approved and
executed confidentiality agreement.

Disclose a third party’s proprietary information when

TechnipFMC has an obligation to keep it confidential.

Protecting assets and information | 25

Safety | Integrity | Quality | Respect | Sustainability

Accurate books and records

Accurate books and records refers to all the financial

and non-financial business information that we
record and report. These must be done honestly,
accurately, exhaustively, and objectively to protect
our credibility and reputation, meet our legal and
regulatory obligations, fulfill our responsibility to
shareholders and other stakeholders, and inform and
support our business decisions and actions.
While our work to ensure accurate books and records
is most visible in the finance, treasury, accounting,
payroll, tax, and controlling departments, all
employees play a role in ensuring the accuracy
and completeness of our financial information.

How to behave

When you are booking a financial transaction, creating

purchase orders, completing your timesheet, or filing an
expense report, you are creating a financial record that needs
to comply with these guidelines. We never tolerate fraud.

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Safety | Integrity | Quality | Respect | Sustainability

Always Maintaining accurate books and records requires:

M
 ake accounting decisions based on TechnipFMC’s Creating records that are up to date, accurate, reliable,
financial standards and recognized accounting verifiable, and in line with applicable rules, laws,
standards. regulations, and company policies.

S
 peak to your Controller if you are uncertain of the Presenting fair, complete, accurate, timely, and
right way to record or report a transaction. understandable reports for internal and external users.

Inform your supervisor when you believe a record Safeguarding company assets to minimize risk of
or report does not accurately reflect the underlying financial loss.
transaction.
Developing and maintaining robust costing systems that
R
 eport any concerns or irregularities in auditing or provide high-quality financial information and support
internal controls first to your line manager. If you feel the company’s strategic management initiatives.
that this does not resolve the issue, consider using one
of the other reporting channels.
Never
B
 e conscious of the confidential nature of the financial
information you handle. Do not give or grant access Falsify a report, document, or record, or make a
to confidential information to outsiders or use it for deliberately false or misleading entry in them.
personal gain. When in doubt, ask your manager before
Record invalid transactions; especially if they are likely to
you distribute information.
defraud anyone of money, property or honest services.
K
 now the external and internal reporting standards
Establish accounts, companies or arrangements to
and ensure they are followed.
circumvent or frustrate TechnipFMC controls, policies
E
 nsure that all transactions are properly authorized or procedures.
and recorded accurately and completely.
Influence others to do anything that could compromise the
S
 ubmit, record, and authorize only valid transactions. integrity of TechnipFMC’s financial records and reports.

R
 ecord transactions in a timely manner, minimizing Commit TechnipFMC to contractual or other financial
errors caused by delays between transactions and obligations unless you are authorized to do so.
their recording.
Process transactions without proper validation.
E
 nsure that all counterparties are appropriately set
Sell, transfer or dispose of company assets without the
up in the company’s systems. This includes customers,
proper documentation and authorization.
suppliers, agents, professional advisers, joint-venture
partners, and any other business partners. Obstruct or influence the authorized activities of a
regulator. This might include concealing, altering,
E
 nsure that no undisclosed or unrecorded amount,
destroying or tampering with information.
fund, or asset is established or maintained.

W
 atch out for unauthorized payments or invoices as
described in the Anti-corruption section of this Code.

E
 nsure that all books and records are supported
by documentation to provide an auditable record
of the transaction.

C
 ooperate fully with all reviews, including internal
and external audits.

R
 eport any concerns or irregularities concerning
accounting, auditing, and internal controls.

Protecting assets and information | 27

Safety | Integrity | Quality | Respect | Sustainability

Warning signs

“The expense report

includes incomplete and
inaccurate expenses.”

28
Beware of any activities that do not respect the
following principles:
 uthorization. The transaction you are recording
A
or the information you are distributing has been
authorized by the correct person(s).
 alidity and clarity. Our financial records should
V
reflect only events that have actually happened,
or events we know with a high degree of
certainty will happen.
 ppropriate accounting treatment. Records and
A
reports are created in line with the applicable
rules, which are consistently applied.
 ompleteness and accuracy. The information
C
captured in our financial (and non-financial)
systems, including business expenses, must be
complete and accurate.
 issemination of information. Exchange
D
information with your colleagues in all applicable
entities, locations, and departments in relation
to the events and transactions you are recording
while respecting the rules of confidentiality.
 imeliness. Every manager should establish firm
T
but realistic timelines for processing financial
records and set deadlines for financial reporting,
and employees should strive to adhere to them.

Protecting assets and information | 29

Safety | Integrity | Quality | Respect | Sustainability

Information security

Information security seeks to preserve the

confidentiality, integrity, and availability of
information to reduce the risk and the impact of
potential threats to our business and operations.
Protection of TechnipFMC know-how is crucial to
preserving our business and competitiveness on a
daily basis. Information security aims to protect
this know-how and reduce the risk of IT disruptions.

Although cyberattacks are

complex, they always start
with an imprudent act or a
lack of awareness.

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Safety | Integrity | Quality | Respect | Sustainability

How to behave Always

Comply with the security standards and with the rules Beware of suspicious emails and phone calls, especially
related to the use of our information systems. Learn from someone you don’t know.
about internal control procedures and contractual
Be wary of emails that contain a link.
confidentiality clauses, especially on projects. Read
information security news and alerts from the Security Remain vigilant and report any potential incident
and IT departments. involving confidential or sensitive information.

Although cyberattacks are complex, they always start Keep a discreet attitude in all circumstances.
with an imprudent act or a lack of awareness. Therefore,
Take care of confidential data.
the most important thing you can do is read awareness
information and remain vigilant at all times, especially TechnipFMC’s data must remain on TechnipFMC’s IT
when handling emails, browsing the web, or taking systems, as a rule of thumb.
outside phone calls.
Protect your laptop with a startup password in addition to
the Windows password. If your laptop does not have one,
contact your IT Helpdesk.

Secure IT tools, technology, and inventory to prevent loss.

Regularly account for IT tools, technology, and inventory.

Never

Open links or attachments in suspicious emails.

Send any work-related data to your personal email

address.

Connect to your TechnipFMC mailbox from a

public computer.

Use public sharing websites to exchange professional

documents.

Enter confidential information into online translation tools.

Use your TechnipFMC email address to register on

websites for a private use.

Use the same password for all websites.

Disclose your travel plans on social media.

Leave your laptop or smartphone unattended in a

public area.

Give any information about TechnipFMC to unknown

persons over the phone.

Use company assets for personal gain.

Store personal information on your company devices

and expect that information to remain private.

Protecting assets and information | 31

Safety | Integrity | Quality | Respect | Sustainability

Warning signs

“The email indicates

that it comes from a
reputable company,
but it originates from a
private email address.”

32
Most cyberattacks come through one of
three channels:

Email
A malicious email usually has the following
characteristics:
It contains an attachment and/or a link to an
external website.
It comes from an external email address.
It looks like it was sent by a well-established
institution (including TechnipFMC).

Web
Be vigilant when you browse the web.
 o not click on a link that seems suspicious,
D
and do not download any file from an
untrusted source.

Phone calls
External fraudsters may use them to try to obtain
information about TechnipFMC. Watch out if:
 n external number appears on your phone’s
A
caller ID.
 he caller takes on the identity of someone in
T
TechnipFMC or one of its partners.
To crosscheck that the phone call was from a
legitimate TechnipFMC person, try contacting the
person the caller claims to be by phone or email.

Protecting assets and information | 33

Safety | Integrity | Quality | Respect | Sustainability

All of us are
expected to respect
the right to privacy
and confidentiality
of personal data of
other employees.

34
Safety | Integrity | Quality | Respect | Sustainability

Privacy and personal data

Personal data is information related to an individual

who is or can be identified.
TechnipFMC is committed to protecting personal
data stored in information systems by designing
and implementing appropriate security and access
measures, and we are committed to handling
personal data responsibly.
Access to personal data is limited to employees who
have appropriate authorization and a clear business
need for that information.

How to behave Always

We respect the personal lives of employees and do not If you are authorized to access personal data, you must:
take an interest in their conduct outside work unless such
Access only information with a valid business reason
conduct has an impact on the performance of the employee
and use it only for that purpose. Adhere to the highest
or affects the reputation or legitimate business interest
standards of confidentiality when using personal data.
of TechnipFMC.
Ensure that such information is not provided to anyone
All of us are expected to respect the right to privacy and
outside of TechnipFMC without the proper authorizations.
confidentiality of personal data of other employees.
Hold the information for only as long as necessary to meet
the business reason for which the authorization was given.

Notify Human Resources or your Regional Compliance

Counsel if you find unprotected personal data.

Collect only the information necessary to perform

your work.

Save only required personal data.

Transfer personal data internationally in compliance with

the privacy laws of the receiving and sending jurisdictions.
Check with the legal department to ensure that you know
the requirements.

Never

Retain the data for longer than is necessary to complete

the business purpose for which it was collected.

Protecting assets and information | 35

Safety | Integrity | Quality | Respect | Sustainability

Insider trading and

stock tipping
Sometimes, during our work, we learn information about
TechnipFMC, our customers, subcontractors, or suppliers
that has not yet been made public. If we were to make
stock transactions based on this “material information”
before it is disclosed to all investors, we would have an
unfair advantage.
Using non-public material information for your personal
benefit (including stock market transactions) is called
“insider trading.” Passing non-public material information
along to others, even family members, so that they may
use the information for personal gain is called “stock
tipping.” These practices erode investor confidence and
violate our core values, this Code, and the law.

Always Never

Keep all non-public material information about Conduct stock transactions based on non-public
TechnipFMC confidential. material information.

Treat all non-public material information about our Pass along non-public material information to others.
customers and suppliers with the same degree of
Write or purchase options on TechnipFMC securities.
confidentiality you would give TechnipFMC’s information.

Respect all “blackout notices” that prohibit buying or

selling TechnipFMC stock during certain periods.

36
Safety | Integrity | Quality | Respect | Sustainability

Good to know

How do I know if
information is material
or not?

Information is considered “material” if a reasonable

investor would consider that information important
in making a decision to buy, hold, or sell stocks.
Examples of material information are projections
of future earnings, loss of a significant project,
or other sensitive business plans or strategies.
Any information that could be expected to affect
TechnipFMC’s stock price, whether positively or
negatively, should be considered “material” and not
be shared with anyone.

Protecting assets and information | 37

Safety | Integrity | Quality | Respect | Sustainability

Our Code of Business Conduct

Protecting business
and brand

Anti-corruption 40
Gifts, entertainment, and hospitality 46
Donations and charitable contributions 49
Conflict of interest 50
Money laundering 53
Export controls and trade compliance 54
Competition and antitrust laws 56
Quality leadership 58
Political activities 59
Corporate image and brand 60
External communications 61
Social media 62
Safety | Integrity | Quality | Respect | Sustainability
Safety | Integrity | Quality | Respect | Sustainability

Anti-corruption

At TechnipFMC, all acts of corruption (including bribes, kickbacks,

and self-dealing) are strictly forbidden. We compete fairly on the
strength of our technology, service, and execution excellence.
We do not accept corruption in any form and do not make or
accept improper payments to obtain or retain business with
those in government or the private sector or as a reward for
awarding subcontractor or supplier contracts. We are committed
to complying with all international and national legislation
against illegal payments, including prohibitions on facilitation
payments (to expedite routine and administrative government
action) except in extraordinary circumstances where the safety
or security of an employee is in immediate danger.

We compete fairly on
the strength of our
technology, service, and
execution excellence.

40
How to behave Always

To ensure that our partners share our commitment to ethical Contact your Regional Compliance Counsel for guidance if
business practices and to ensure that our partners’ other you are unsure which Compliance Procedure to apply.
relationships (including family relationships) do not create
Ensure that records of expenditures properly reflect the
the appearance of a potential conflict of interest, we conduct
nature of the transaction.
detailed due diligence of all potential business partners
before entering into a relationship. Select business entertainment venues and activities that
reflect our values.
TechnipFMC has established anti-corruption policies and
procedures that help us prevent, detect, and react to Conduct appropriate due diligence on all consultants,
improper dealings whenever they arise. We must all ensure suppliers, business partners, and agents, and ensure that
that we follow these policies and procedures and that we third parties understand TechnipFMC’s policy of zero
never engage in corruption of public or private individuals tolerance for corruption.
or entities.
Pay all consultants, agents, and business partners in the
country where they performed work.

Use the reporting channels to report any act of corruption

or any attempt to conceal corruption.

Seek advice from your manager or Regional Compliance

Counsel if you have any doubt about payments that you
have been requested to make.

Never

Make payments or provide other objects of value such as

gifts, loans, discounts, and excessive hospitality, or using
the company’s funds or assets to improperly influence a
decision under any circumstances.

Offer, give, promise, or solicit — either directly or through

a third party — any payment or supply of services,
gifts, or leisure activities to obtain or retain a market or
competitive advantage. This rule applies to transactions
with government officials, companies, and private persons.

Act in a way that violates local law or the customer’s own

rules and business guidelines.

Provide anything of value that creates the appearance

of impropriety.

Provide anything of value to gain or retain an improper

advantage.

Protecting business and brand | 41

Safety | Integrity | Quality | Respect | Sustainability

Warning signs

“I’m not sure why my

client is involving his
brother—a government
official—in our project.”

When dealing with business partners, we may

encounter warning signs that the business partner
may be making improper payments or is otherwise
exerting undue influence over decisions to award
or retain business.

42
Safety | Integrity | Quality | Respect | Sustainability

These warning signs (sometimes referred to as

“red flags”) include:
 request by a commercial consultant to have
A
a commission paid before the announcement of
an award decision.
 nwillingness by a third party to reveal its
U
ultimate ownership structure.
 ompensation requests not in line with
C
services provided.
 ack of support for services vaguely described
L
in invoices or the inability to provide details
of the actions taken on behalf of TechnipFMC.
 equests for payment in a country other than
R
where the service was provided.
Involvement of government officials,
including family members or other relatives
of government officials.
If you observe any warning signs, promptly contact
your Regional Compliance Counsel or the Corporate
Compliance Department for assistance in resolving
the issue.

Protecting business and brand | 43

Safety | Integrity | Quality | Respect | Sustainability

Good to know

Who is considered a
public or government
official?

These terms are broadly interpreted to include

any person working for a governmental body,
any political party candidate, and any business
owned and/or operated by a government official.
In addition, “government” includes all branches,
levels, and subdivisions of any government.

44
Safety | Integrity | Quality | Respect | Sustainability

Government officials include, but are not limited to:

 ny elected or appointed government official
A
or representative.
 current or former employee, official, contractor,
A
consultant, or representative of a government
or any department, agency, or state-owned or
state-controlled enterprise.
 ny current or former employee or person acting
A
for or on behalf of a government official, agency,
or enterprise performing a governmental function,
such as a licensing official or a tax agent.
 ny political party, officer, employee, or person
A
acting for or on behalf of a political party or
candidate for public office.
 person in the service of a government, including
A
members of the military, police, or civil service.
Family members and relatives of any of the above.

Protecting business and brand | 45

Safety | Integrity | Quality | Respect | Sustainability

Gifts, entertainment,
and hospitality
Although appropriate entertainment can provide an
opportunity to build or solidify client relationships
or to gain greater insight into key subcontractors
and suppliers, there are some forms of gift-giving
that could be viewed as inappropriate and could
constitute corruption.

How to behave

If you are presented with a gift or offered hospitality

or entertainment, or if you are offering someone a
gift, hospitality or entertainment, you need to evaluate
whether you may receive or give such gifts in line with the
requirements of the company’s policies and procedures.

Always Never

Tell your manager about any gift or invitation offered or Grant or accept any excessive gifts or entertainment,
accepted, whatever its value. whether monetary or non-monetary, directly or indirectly,
to or from any government official, client, supplier, vendor,
Inform your business partner about TechnipFMC’s policy subcontractor or any other third party.
on gifts and entertainment at the beginning of every new
business relationship. Let gifts or entertainment influence decisions or be seen
as having an influence on those receiving them.
Speak to your manager if a supplier or a subcontractor
offers you gifts or invitations of significant value. Solicit gifts or invitations.

Ask for your manager’s approval before offering gifts or Offer or accept gifts, or provide a service that you would
invitations to representatives of a government official. have difficulty explaining to your colleagues, your family,
or the media.
Accept or offer restaurant invitations only for business-
related purposes. Offer gifts or provide hospitality, even of minimal
value, with frequency that can create the appearance
Understand local customs and laws before offering or of impropriety when aggregated.
receiving gifts, leisure activities, or other benefits.
Offer gifts, entertainment, or travel to government
 ake into account the company policy of the person
T officials without prior approval.
receiving the gift or invitation.
Offer gifts or provide hospitality in the form of cash.
 ake sure all gifts offered and received are supported
M
by accurate documentation, including invoices and Accept gifts or hospitality from potential suppliers
receipts, where applicable. who could place you in a situation of obligation,
especially during critical phases of a decision-making
Seek advice from your manager or from your Regional or award process.
Compliance Counsel if you are not completely sure.
Accept an offer that exceeds what is considered acceptable
at TechnipFMC.

46
Warning signs

“My supplier wants to give

my wife and me tickets
to the theater and have
dinner on his expense.”

Some gifts and hospitality are, by their nature,

illicit and thus prohibited by TechnipFMC.
These include cash payments, personal services,
loans, gifts, invitations of an improper nature
or to inappropriate places or events, meals
in which the commercial partner does not
participate, and gifts or invitations at periods
when important commercial decisions are
being made.

Protecting business and brand | 47

 When contributing to local
communities on behalf of
TechnipFMC, ensure that
such giving is in line with
our core values and
foundational beliefs.

48
Safety | Integrity | Quality | Respect | Sustainability

Donations and charitable

contributions
Social donations and contributions are gifts given for
a charitable purpose or to support a particular cause.
A donation or charitable contribution can be in the form of
cash, services, and new or used goods. They also include
emergency or humanitarian aid, development aid support,
and medical care assistance.
As a responsible corporate citizen, TechnipFMC believes in
contributing to the communities where we conduct business
by supporting worthy causes, organizations, and activities.
However, in certain circumstances, donations could be
considered disguised illegal payments. To avoid these
risks, TechnipFMC funds only associations and foundations
or takes part in sponsorship projects whose activities are
legally acceptable and in line with the values and priorities
of the company. Any donation or contribution on behalf
of TechnipFMC shall be approved in accordance with
the relevant policies concerning social donations and
charitable contributions.

How to behave Always

When contributing to local communities on behalf of Promote the development of local communities through
TechnipFMC, ensure that such giving is in line with our charitable donations that are in line with our values,
corporate values, charters, policies, and procedures. If policies, and procedures.
there is a local charity or social program that, in your
Ensure that charitable organizations do not use donations
opinion, shares the company’s values, inform your
for illegal purposes.
Regional Compliance Counsel. All approved donations
must be properly accounted for and accurately reported Make all donations in good faith and ensure that proper
on the company’s books. approvals are obtained in line with the company’s policies
and procedures.

Never

Give donations that are unreasonably large in value.

Give any donation if it is illegal under local laws

and regulations.

Protecting business and brand | 49

Safety | Integrity | Quality | Respect | Sustainability

Conflict of interest

A conflict of interest may occur when an employee

has a financial, business, or personal interest or
activity that interferes or appears to interfere with
TechnipFMC’s interests. There are many situations
that are or could be perceived as conflicts of interest.

How to behave Always

You are expected to make informed business decisions Act only in TechnipFMC’s interest when conducting
in the best interest of the company. Any situation in professional activities. Refrain from taking advantage
which your personal interests, or the interests of your of any situation, either directly or through a third party,
close relations, are or appear to conflict with TechnipFMC’s for your own gain or that of others.
interests must be avoided.
Disclose in writing to your manager and your local legal
counsel all of your outside interests that create or could
Financial interests
appear to create a conflict of interest.
A close relative is an owner or investor in a privately-
Get approval prior to taking a position with an outside
owned customer of TechnipFMC.
business while working for TechnipFMC.
You accept expensive event tickets or gifts from a
Understand the concept of conflicts of interest.
supplier or customer.
Remain aware of any actual or apparent conflicts.
 ou learn about a business opportunity at work and
Y
decide to pursue it for yourself. Know how to remove yourself or protect against the
dangers a conflict of interest presents, such as removing
Personal relationships yourself from the position that creates the conflict by
delegating to someone else.
You supervise or are supervised by a close relative
or partner. Disclose any conflicts to your manager and seek advice
on how to avoid the conflict, remove yourself from it, or
You are considering hiring a close relative or partner
protect yourself and the company from the consequences
as an employee or contractor.
of the conflict.
You have a relationship with a supplier that
inappropriately influences your business decisions.
Never
You have a romantic relationship with a subordinate.
Misuse TechnipFMC resources for personal gain.
Political relationships This includes TechnipFMC office equipment, time,
and intellectual property. Any information you obtain
You work on a political campaign during working hours.
through your position at TechnipFMC should not be
You express your political views in a setting where used for personal gain.
your audience may think you are speaking on behalf
Assume that a conflict does not matter because it is
of TechnipFMC.
too small or petty.

Let a conflict linger for a long time before taking action.

50
Safety | Integrity | Quality | Respect | Sustainability

Warning signs

“He uses his company

laptop to conduct other
business on the side.”

In our work, we may come across a situation

that could create a conflict of interest. Warning
signs (sometimes referred to as “red flags”)
of such a conflict include:
 close relative works for a supplier or
A
a customer.
 ou conduct business on the side for your
Y
personal benefit (not for the company’s)
with your company laptop.
 ou are asked to serve on the board of a
Y
competitor, supplier or customer’s company.

Protecting business and brand | 51

 Conduct appropriate due
diligence on all subcontractors,
suppliers, consultants,
and agents.

52
Safety | Integrity | Quality | Respect | Sustainability

Money laundering

Money laundering occurs when someone involved

in a criminal activity such as terrorism, narcotics,
bribery or fraud “launders” the proceeds of the crime
to prevent detection and appear legitimate.
As part of ensuring that our financial records are
accurate, complete, and transparent, it is also
necessary for us to exercise appropriate diligence
on subcontractors, suppliers, and other vendors to
prevent money laundering.
Appropriate due diligence also prevents “reverse
money laundering,” whereby legitimate funds may
be used, knowingly or unknowingly, to finance
terrorist activities.

Always Never

C
 onduct appropriate due diligence on all subcontractors, Try to investigate any case of money laundering on
suppliers, consultants, and agents. your own.

E
 nsure that all payments to subcontractors, suppliers, Reveal your suspicions of money laundering to the
consultants, and agents are made in accordance with other party in the transaction, but seek advice from
our financial standards, including the requirement that your manager or Regional Compliance Counsel.
payment be made in the country in which the work was
performed.

A
 sk questions if an agent or consultant proposes a
transaction structure that seems unusually complex.

M
 ake careful inquiries about the origin of any money
we receive or acquire.

C
 heck the legitimacy of the destination of any payment
we make.

Seek advice from your manager or Regional Compliance

Counsel if you have any doubt about payments that you have
been requested to make, including facilitation payments.

Protecting business and brand | 53

Safety | Integrity | Quality | Respect | Sustainability

Export controls and

trade compliance
We provide products and services to companies around
the world. Most of these countries have customs laws and
foreign policy-based trade controls, including economic
sanctions and embargoes, that govern the import or export
of the products or services we offer. Some countries have
laws requiring the boycott of other countries, while others
have laws that prohibit participating in boycotts.
Trade regulations can target countries, business sectors
within countries, or individuals or organizations sometimes
referred to as state sponsors of terrorism or specially
designated nationals.

How to behave Never

We must strictly comply with all customs laws and trade Execute a cross-border shipment without contacting the
controls that apply to us, wherever we do business. logistics department.

Carry equipment or spare parts in your luggage without

prior approval, in accordance with TechnipFMC processes
Always
and procedures.
Ensure adherence with all applicable processes and
policies when conducting an import or export.

Use only approved customs agents and freight forwarders.

Provide complete and accurate information about final

destination, end user, and end use for all shipments.

Provide a complete and accurate listing for all items

included in a shipment.

Check with the legal department before transferring

technology (engineering drawings, source code, etc.)
from one country to another.

Ensure that temporary imports are managed in accordance

with import license or customs documents.

Remember that carrying equipment or spare parts in your

luggage (known as “hand carry”) is subject to the same
trade restrictions and customs clearance obligations as
any other shipment to that country.

54
Good to know

Are export and import

regulations restricted
to physical objects?
No. Certain regulations also apply to intangible
assets. Because of the diversity of our workforce,
we must be aware of these “deemed exports” and
treat them in the same manner as physical exports.
A deemed export results when a discussion about
technology with a citizen of a country subject to
trade restrictions is viewed as an export of the
technology to that restricted country.

Protecting business and brand | 55

Safety | Integrity | Quality | Respect | Sustainability

Competition and
antitrust laws
We are committed to competing fairly and in compliance
with applicable laws governing competition and
antitrust. These laws seek to protect markets by
fostering fair and robust competition.
Specifically, these laws seek to prevent collusion among
competitors and to prevent companies with dominant
market position from abusing their market power.
They also require prior review and approval for certain
transactions, such as mergers and acquisitions, that could
substantially reduce or affect competition in the market.
At TechnipFMC, our objective is to conduct our business
with the highest standards of honesty, integrity, and
fairness and to offer opportunities for success to all our
suppliers, partners, and subcontractors in a spirit of fair
competition and mutually beneficial collaboration.
It is necessary to have meetings with our competitors
from time to time. However, extreme care should
be taken to define the purpose and scope of these
discussions up front to avoid even the appearance of
inappropriate collaboration.

56
Always Never

F
 amiliarize yourself with competition law in your business Agree with competitors to:
and jurisdiction. Ask legal for advice.
- Exchange information regarding prices, sales volumes,
C
 arefully note the origin of any information you may terms of sale (including contractual terms), market
collect on the market regarding competition. shares, production capacities, or cost structure,
including by telephone or during informal meetings.
C
 onsider whether the reasons for entering into an
agreement with a competitor are legitimate. - Discuss the commercial or industrial policy
of TechnipFMC.
K
 eep records of meetings with competitors.
- Participate in collective action aimed at, or having
P
 ay particular attention to exclusivity agreements and
the effect of, preferring or eliminating a competitor,
other similar agreements.
granting it preferential treatment, or exercising pressure
P
 ay particular attention to the existence and operation or retaliatory measures, or boycotting a customer.
of purchasing groups in which the company desires
- Abuse purchasing power, including prohibiting work
to participate.
with or otherwise discriminating against specific
S
 eek guidance from your legal department if you have suppliers or customers, unless legitimately and
to deal with R&D or transfer technology agreements. objectively justified.

S
 eek guidance from your legal department and obtain Communicate or exchange information with competing
approval from the proper level of management before buyers regarding our purchasing policies.
entering into any trade association.
Give any confidential information about a supplier to
its competitors.

We are committed to competing

fairly and in compliance with
applicable laws governing
competition and antitrust.

Protecting business and brand | 57

Safety | Integrity | Quality | Respect | Sustainability

Quality leadership

Quality leadership refers to the value of outputs that

we deliver to our internal and external customers.
The products, services and projects should all
contribute to optimal, reliable and safe results that
meet requirements each and every time.
TechnipFMC’s goal is to be a leader in our industry
by providing excellent quality in whatever we do,
and maintaining reliable products, asset integrity and
services and project execution and installation lifecycle.

Always

Know and comply with our Quality Policy. Aim to do things better, faster, and more cost-effectively
while always respecting applicable standards and
Cultivate a culture of quality leadership through
requirements.
consciously meeting requirements, continuous learning
and improvement through an empowered workforce. Intervene if quality behaviors and standards are not
demonstrated.
Drive accountability and ownership for prevention at all
levels within the organization. Take personal accountability to performing and improving
your job through leadership competencies that result in
Be responsible to engage in the improvement of the
improving business result.
processes that you operate.

When interfacing with the Supply base ensure that our

suppliers constantly meet requirements and drive culture
of continuous improvement and prevention.

Follow documented processes when executing work.

Track conformance and identifying issues when they occur.

Address all nonconformance issues through root cause

analysis and application of prevention.

58
Safety | Integrity | Quality | Respect | Sustainability

Political activities

TechnipFMC observes strict political, religious, and

philosophical neutrality. Therefore, TechnipFMC’s
policy is to not make financial contributions to political
candidates, elected representatives, political parties,
or religious institutions.
TechnipFMC also respects the personal political
affiliations of its employees. Nevertheless, these
affiliations must not affect the activities or image
of TechnipFMC, nor may they affect the political
neutrality of the company.

Always Never

P
 articipate in political activities in your own name and Use TechnipFMC premises, equipment, or any other
outside of work. assets for political activities.

R
 espect the beliefs of others. Make a political statement on behalf of TechnipFMC or
associate TechnipFMC with your personal political views.
R
 ecuse yourself from political decision-making processes
that concern TechnipFMC. Use TechnipFMC’s corporate image to support your
political views.
E
 xercise your freedom of opinion and political activity
outside the scope of your employment, at your own Use your position at TechnipFMC to urge anyone to make
expense and on an exclusively personal basis. political contributions or to support a political party.

E
 xplain clearly that you represent only your own personal Use or allow the use of TechnipFMC’s assets or resources
views when participating in political activities. for a political campaign, party, or candidate.

G
 et your manager’s approval before communicating in Use donations for community benefit to hide
TechnipFMC’s name with government representatives political contributions.
on political matters.

T
 hink of TechnipFMC’s reputation and how the public
would perceive your actions when interacting with
government representatives.

S
 eek advice from your manager or Regional Compliance
Counsel if you are solicited for a political donation.

N
 otify your manager if a government official contacts
you outside your normal activities.

Protecting business and brand | 59

Safety | Integrity | Quality | Respect | Sustainability

Corporate image and brand

Our brand is an asset we need to protect.

It is what makes us unique to our stakeholders.
It is the personality that we express not only
through our visual communications, but also
through our collective and individual behaviors.

How to behave Always

You have a role to play in protecting and preserving Act as a brand ambassador and behave in conformity
our image. You are an ambassador of TechnipFMC with our principles as detailed in this Code.
and, as such, you must behave in conformity with our
Maintain and protect TechnipFMC’s reputation.
principles as detailed in this Code.
Communicate consistently with all of our stakeholders.
Everyone in TechnipFMC is a brand ambassador, and
each of us must maintain and protect TechnipFMC’s
reputation. Consistent communications with all of
our stakeholders is the foundation for our brand, our
corporate image, and our commercial success.

60
Safety | Integrity | Quality | Respect | Sustainability

External communications

Given our global presence, financial market

reporting regulations, and renowned technical
expertise, TechnipFMC must be particularly
vigilant with respect to external dissemination
of information. Any misinterpretation could
negatively affect the company’s image and
financial performance.

How to behave Always

Only the following people are authorized to release external Whoever you meet, share information with care.
information:
Disclose only information that is public, meaning it
T
 he Executive Chairman, the Chief Executive Officer, and has been published on TechnipFMC’s website.
the Chief Financial Officer.

B
 y delegation and within the framework of internal
Never
procedures for legal and financial disclosure review,
Communications, Public Relations, or Investor Relations Speak with the media. If you must speak to the media,
Department managers. remember that there is no “off the record.”

Any external company communications must be authorized

by at least one of the above. TechnipFMC personnel are not
authorized to provide or issue company-related information
to outside parties without the company’s express
authorization.

We must be particularly vigilant

with respect to external
dissemination of information.

Protecting business and brand | 61

Safety | Integrity | Quality | Respect | Sustainability

Social media

Social media is changing the way we communicate,

work, and live. TechnipFMC respects the right
of employees to use social media as a medium
of self-expression.
However, everything our employees post about
TechnipFMC can impact the company’s reputation.
Equally, everything published online remains for a
very long time and, in some cases, cannot be undone.
Therefore, social media should be used responsibly.

How to behave Always

Speak for yourself and be transparent. It is important to Post content that represents your own personal views.
understand the difference between mentioning the company
For security reasons, keep work-related travel or
and speaking on behalf of it. Communications personnel are
geographical positions confidential.
TechnipFMC’s only official spokespersons in the social space.
Obtain written permission from the relevant
Whenever you participate in social media and discuss
communications manager prior to posting any
topics related to the company, make it clear that you are
TechnipFMC photo, video, or logo.
expressing your own opinions and that your comments
do not represent the company. Comply with laws and regulations governing intellectual
property rights, including copyrights and trademarks.
Be responsible and respectful. When communicating
online, pay particular attention to issues that are sensitive
to TechnipFMC’s business and its clients, partners, and
Never
suppliers, such as the price of oil and gas, oil spills, and
other sensitive topics. In all discussions, use facts and Publish online anything that would not be publicly
references for your statements when possible. If you are available to journalists, clients, and competitors.
unsure whether a post is appropriate to share, it is better
not to post it at all. If you realize you have published an Post confidential, sensitive, or proprietary information.
inaccurate statement, acknowledge your mistake and Post comments about persons or companies that could
correct it as soon as possible. be perceived as negative or defamatory.
Be polite and keep in mind that cultural differences may
impede understanding. Avoid using remarks that could be
interpreted as offensive, and use a respectful tone even
when disagreeing with others.

Protect information, confidentiality, privacy, and intellectual

property. TechnipFMC rules apply to social media, and your
obligations as a TechnipFMC employee are the same in the
digital world as in the physical world. When using social
media, never share confidential or sensitive information
such as financial and commercial data or any information
related to ongoing projects, research and development,
legal matters, or strategy.

62
Safety | Integrity | Quality | Respect | Sustainability

Chapter title
in two lines
At TechnipFMC, all acts of corruption (including bribes, kickbacks,
and self-dealing) are strictly forbidden. We compete fairly on
the strength of our technology, service, and execution excellence.
We do not accept corruption in any form and do not make or
accept improper payments to obtain or retain business with
those in government or the private sector or as a reward for
Everything our
awarding subcontractor or supplier contracts. We are committed
to complying with all international and national legislation
employees post
against illegal payments, including prohibitions on facilitation
payments (to expedite routine and administrative government
about TechnipFMC
action) except in extraordinary circumstances where the safety
or security of an employee is in immediate danger.
can impact
TechnipFMC has established anti-corruption policies and

our reputation.
procedures that help us prevent, detect, and react to improper
dealings whenever they arise.

How to behave Always

The company strictly prohibits making payments or - Ensure that records of expenditures properly reflect
providing other objects of value such as gifts, loans, the nature of the transaction.
discounts, and excessive hospitality, or using the
- Select business entertainment venues and activities
company’s funds or assets to improperly influence a
that reflect our values.
decision under any circumstances.
- Conduct appropriate due diligence on all consultants,
All of us must refrain from offering, giving, promising, or
suppliers, business partners, and agents, and ensure
soliciting — either directly or through a third party — any
that third parties understand TechnipFMC’s policy of
payment or supply of services, gifts, or leisure activities
zero tolerance for corruption.
to obtain or retain a market or competitive advantage.
This rule applies to transactions with government officials, - Pay all consultants, agents, and business partners in
companies, and private persons. the country where they performed work.

- Use the reporting channels to report any act of

corruption or any attempt to conceal corruption.

- Seek advice from your manager or Regional

Compliance Counsel if you have any doubt about
payments that you have been requested to make.

Never
- Act in a way that violates local law or the customer’s
own rules and business guidelines.

- Provide anything of value that creates the

appearance of impropriety.

Protecting
Protecting people and thebusiness and brand
environment | 63 | 63
Safety | Integrity | Quality | Respect | Sustainability

Chapter title in one line

At TechnipFMC, all acts of corruption (including bribes, kickbacks,

and self-dealing) are strictly forbidden. We compete fairly on
the strength of our technology, service, and execution excellence.
We do not accept corruption in any form and do not make or
accept improper payments to obtain or retain business with
those in government or the private sector or as a reward for
awarding subcontractor or supplier contracts. We are committed
to complying with all international and national legislation
against illegal payments, including prohibitions on facilitation
payments (to expedite routine and administrative government
action) except in extraordinary circumstances where the safety
or security of an employee is in immediate danger.

How to behave Always

The company strictly prohibits making payments or - Ensure that records of expenditures properly reflect
providing other objects of value such as gifts, loans, the nature of the transaction.
discounts, and excessive hospitality, or using the
- Select business entertainment venues and activities
company’s funds or assets to improperly influence a
that reflect our values.
decision under any circumstances.
- Conduct appropriate due diligence on all consultants,
All of us must refrain from offering, giving, promising, or
suppliers, business partners, and agents, and ensure
soliciting — either directly or through a third party — any
that third parties understand TechnipFMC’s policy of
payment or supply of services, gifts, or leisure activities
zero tolerance for corruption.
to obtain or retain a market or competitive advantage.
This rule applies to transactions with government officials, - Pay all consultants, agents, and business partners in
companies, and private persons. the country where they performed work.

To ensure that our partners share our commitment to - Use the reporting channels to report any act of
ethical business practices and to ensure that our partners’ corruption or any attempt to conceal corruption.
other relationships (including family relationships) do not
- Seek advice from your manager or Regional
create the appearance of a potential conflict of interest,
Compliance Counsel if you have any doubt about
we conduct detailed due diligence of all potential business
payments that you have been requested to make.
partners before entering into a relationship. Contact your
Regional Compliance Counsel for guidance if you are Never
unsure which Compliance Procedure to apply. - Act in a way that violates local law or the customer’s
own rules and business guidelines.

- Provide anything of value that creates the

appearance of impropriety.
TechnipFMC.com © TechnipFMC 2018. COBC 18.1

64