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Vendor and Supplier Anticorruption Expectations

Anadarko expects its vendors and suppliers to act ethically and obey anticorruption laws including the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, and local laws. We also expect you to have a written contract with us before you enter an Anadarko worksite or begin work. The points in this document are important to our anticorruption program. Our employees are required to follow them and, when you are working for us, we expect you to follow them too.

No Bribes

Do not offer or accept bribes of any kind whether directly or through someone else. A bribe can be anything of value intended to wrongly influence another person – whether that other person is in the government or in the private sector. “Anything of value” includes cash, gifts, loans, services, entertainment, meals, travel, favors, hiring someone’s relative, donating to someone’s favorite charity, etc.

Public Officials 

Take extra care if your work for Anadarko includes interacting with public officials. Have clear written anticorruption policies and training for your staff. Do not give public officials anything of value such as gifts or entertainment, or pay for their travel, or pay per diems without written approval from our legal compliance team; and never make political contributions in connection with your work for Anadarko. And remember – if you shouldn’t do it, then getting someone else to do it for you is still wrong.

No Facilitating Payments

Small payments to public officials for routine actions they should do anyway, such as issuing permits or releasing goods from customs, are prohibited.

Avoid Cash Payments

When working for Anadarko, avoid paying with cash. Cash is easily misused and difficult to track. Except in case of emergency, you must get written approval from our legal compliance team before paying in cash. You must also get receipts. Include an explanation for why you paid in cash along with a copy of our written approval and the original receipts when you send your invoice to Anadarko.

Sponsorships & Donations 

Sponsorships and donations, even if well-intentioned, can create corruption risk. Do not give donations or enter into sponsorships in connection with your work for Anadarko unless you have written approval from our legal compliance team.

Accounting Records & Controls

Keep accurate and transparent accounting records that show expenses, payments, and other transactions in reasonable detail, including receipts for any payments to government agencies. Have risk-based internal controls to authorize payments and to prevent and detect violations of anticorruption laws – whether by you or by your suppliers or subcontractors. Our contract may also give us audit rights.

Human Rights

Human trafficking and forced labor exist in many parts of the world today. Make sure your labor requirements do not inadvertently contribute to the problem. Pay particular attention if you use labor agents or temporary foreign laborers. These situations are at higher risk for abuse. Also, if you house workers in remote camps, be sure conditions are clean and safe and that the workers are treated with dignity and respect.

Subcontractors & Due Diligence

If you use subcontractors, conduct proper due diligence to make sure they are duly registered and legally qualified for business in the country, and that they have a good reputation and are likely to obey anti-corruption laws and respect human rights. Pay careful attention to any agent or intermediary acting on your behalf. Remember, you can be fined and even sent to prison if your subcontractors – especially your agents or intermediaries – violate anticorruption laws. Contractually require your subcontractors to obey those laws.

Speak Up With No Retaliation

Speak up if you have questions or concerns; talk to our local management or contact the anonymous Anadarko hotline (+1.877.781.2434). Tell us if anyone, including our staff, violates or asks you to violate these expectations. We prohibit our employees from retaliating against anyone for raising concerns or reporting misconduct in good faith. We expect you to also prohibit retaliation.

For More Information

If you do not understand these expectations or have trouble complying with them, we can help. Notify our local management for assistance. Read more about Anadarko's values and code of ethics.

 

Legal Disclaimer: This is a summary of expectations. It does not (i) amend, interpret, modify, supersede, or waive the terms of any contract or work order (although in some instances it may be incorporated by reference into a contract); (ii) permit or require anything inconsistent with applicable law, our Code of Ethics, our Anticorruption Compliance Manual, or any contract or work order; or (iii) create or evidence a contract or third party beneficiary relationship or expectancy. If you have a contract or work order with us and it conflicts with this document, the contract or work order prevails.

 

 

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