The FMCTechnologies

Code of Business Conduct

Living our
core values

FMCTechnologies, Inc.

Code of Business Conduct

Contents
Message from our President and CEO .................... 4

Integrity outside ............................................21

Be the One ......................................................... 5

Integrity with our

customers and suppliers ...................................... 22

Your role .................................................................. 6

Avoiding improper payments ............................. 22

Expected behaviors ................................................. 8

Giving and receiving gifts and entertainment...... 24

Raising concerns ..................................................... 9

Competing globally............................................ 25

Responding to concerns ....................................... 10

Quality achieving customer success................... 26

Integrity inside ...............................................11

Avoiding conflicts of interest
FMCTechnologies first ........................................ 12
Valuing our people................................................. 14

Fair employment practices................................. 14

Safety................................................................ 14
HSE 12 Golden Rules.................................. 15
Privacy............................................................... 15
Protecting company assets.................................... 16

Contracts........................................................... 26
Integrity with governments .................................. 27

Global trade restrictions...................................... 27

Political activity................................................... 28

Global immigration compliance.......................... 28

Integrity with others.............................................. 30

Promoting human rights.................................... 30

Environmental stewardship................................ 30

Charitable contributions...................................... 30

Transparency in financial information................... 17

Money laundering prevention............................. 17

Insider trading and stock tipping........................ 18

Intellectual property and confidential

business information............................................. 19
Social media........................................................... 20

FMCTechnologies, Inc. (NYSE: FTI) is the global market leader in subsea systems and a leading
provider of technologies and services to the oil and gas industry. We help our customers
overcome their most difficult challenges, such as improving shale and subsea infrastructures
and operations to reduce cost, maintain uptime, and maximize oil and gas recovery.
Visit www.fmctechnologies.com or follow us on Twitter @FMC_Tech for more information.

03

FMCTechnologies

Be the One

Message from our

President and CEO
At FMC Technologies our vision is clear
we will be the undisputed leader in
our markets, recognized for setting
technical, performance and safety
standards in all of our businesses,
and for enabling customer success.
To help us achieve this vision, we have
identified our core values which drive
our actions and shape our culture. We
have all come to FMC Technologies
with different experiences and
perspectives, and it is our core values
that unify us as one company.
We believe how we do business is as
important as why we do business. We
act ethically, lawfully and in accordance
with our values in all that we do. At
FMC Technologies we live our values
through the decisions we make and
the behaviors we exhibit, and we all
accept the responsibility to be the one
to live these values.

Our Code of Business Conduct will help

us see the ethical dimension to our
everyday decisions and help us address
those issues in a way that is consistent
with our core values. The Code gives us
one common language when it comes
to ethics and integrity, and we will hold
ourselves and each other accountable
to demonstrate the behaviors
described in the Code.

Doug Pferdehirt
President and CEO

This Code describes expected

behaviors and the behaviors to be
avoided, and is intended to give you
practical guidance so that you can live
our core values no matter where you
work, no matter what your role.
Please read this Code carefully,
understand its contents and apply its
principles in the course of your work.

Be the One
04

05

FMCTechnologies

Be the One

Your role
To Be the One does not mean you
are alone. Each of us plays a role in
maintaining the companys values,
and together, we create the
FMCTechnologies culture.
Our Code applies to each of us:
All directors, officers, and employees
All employees of our subsidiaries
and affiliates
Anyone who represents us or acts
on our behalf, including contract
employees, suppliers, contractors,
agents, sales agents, and distributors.

FMCTechnologies core values

We are all expected to:

Live Read and understand the
guidance provided in this Code of
Business Conduct (our Code), our
standards and policies, and to live it
every day.
Lead Help other team members
follow our Code through leading
by example and providing training
on the issues your business faces
most often.
Support Create an environment
that encourages other team
members to raise ethical concerns
early.
Report Report behaviors that may
violate the guidelines set out in our
Code, standards or our policies.
Stop Intervene, without hesitation,
to stop any activity by others that
is in conflict with our core values
or our Code.

Safety & Sustainability

Quality
We embrace the Five Absolutes of
Quality. Through strict conformance
to requirements, a prevention mindset
and a zero-defect performance
standard, we eliminate the price
of nonconformance and create
customer success.

We protect the health and safety

of our people and promote
the sustainability of the environment
and the communities where we
operate.

Collaboration
We promote an environment of
open and sharing cooperation
within the company and with our
suppliers and customers.

Customer-Centered

Innovation

We create value by building close

partnerships with our internal and
external customers to achieve
mutual success.

We believe the best is yet to be

invented. We encourage purposeful
creativity and thoughtful risk taking
to create value for all stakeholders.

Valuing People
Integrity
We do what is right and we do what
we say. We always act ethically,
lawfully and in accordance with our
values.

We have the best people, invest

in their development and provide
opportunities for their growth.
Our strength and success comes
from respecting people, embracing
diversity, and valuing
different cultures.

This Code of Business Conduct will help us recognize situations

that can lead to ethical challenges and help us to address those
issues in a way that is consistent with our core values.

06

07

FMCTechnologies

Be the One

Raising concerns

Core values our expected behaviors

Safety &
Sustainability

Collaboration

Innovation

Valuing People

Expected Behaviors:

Expected Behaviors:

Expected Behaviors:

Expected Behaviors:

Proactively share
experiences and information
within the company.
Focus on common goals
rather than individual
achievements.
Encourage interaction
and teamwork guided
by clear direction and
structured feedback.
Embrace and share
best practices.
Act as one global company.

Constantly look for better

ways of doing things.
Foster an environment
of innovation and seek
breakthrough ideas
and initiatives.
Proactively share information,
best practices and ideas
throughout the company.
Balance the pursuit of
innovation against the
value of standardization.
Pursue creativity without
fear of failure.

Provide equal opportunity and

fair treatment to all employees.
Maintain a great
work environment.
Foster a culture of workforce
diversity and value a
multicultural approach.
Take responsibility for
improving existing skills
and acquiring new skills
and knowledge.
Help others advance
by providing tools
and opportunities for
professional development.

Take responsibility for

preventing injuries.
Follow all safe work
practices and policies.
Report and address all injuries
and unsafe working conditions.
Protect the safety and health
of all employees, visitors
and communities where
we operate.
Operate efficiently to preserve
natural resources.
Commit to corporate
responsibility and support
our local communities.

Integrity
Expected Behaviors:
Never compromise our
values for results.
Accept accountability for
your own actions and those
of your team.
Raise concerns without
hesitation and address
issues with no retaliation.
Speak the truth and insist
on an open and trusting
environment.
Lead consistently by actions,
not justwords.

08

CustomerCentered

Quality

Expected Behaviors:

Insist on clear requirements

and agree on them upfront.
Recognize and celebrate
individuals who demonstrate
a prevention mindset.
Develop, implement
and maintain zero-defect
capable processes.
Understand the price of
nonconformance and
personally strive for zero
defects in everything we do.
Work to requirements
and standard operating
procedures; avoid waivers
and workarounds.

Help internal and external

customers succeed by insisting
on measurable requirements.
Deliver only conforming
products or services to
our customers.
Build alliances with
customers and suppliers
who share our values.
Cultivate long-term
relationships with our external
customers and suppliers.
Share performance metrics
with customers to achieve
mutual success.
Live our values to build the
FMCTechnologies brand.

Expected Behaviors:

FMCTechnologies provides several

ways to ask questions about our Code
or report concerns or potential
violations:
Your direct supervisor
Human Resources
Legal department
Ethics Hotline
Any officer.

Q: If Im aware of a Code violation but

I cannot provide any proof, should
I still report it?
A: Yes. It is not your responsibility to
investigate a Code violation before
reporting it. We will handle the investigation
process.

We encourage employees and others

to raise questions and concerns to
ensure that we are living our core
values. Retaliation against anyone who
makes a good faith report of possible
violations of our Code, standards or
policies, or cooperates with an
investigation, is strictly prohibited.

FMCTechnologies Ethics Hotline can be

reached in several ways:
877-488-8343, toll-free in the U.S.
001-503-748-0519, collect outside the U.S.
www.ethicspoint.com
Our hotline is managed by a third party that can take reports in the following languages:
English, French, German, Portuguese, Spanish and Mandarin.

09

FMC Technologies

Integrity inside

Responding 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. When investigating
concerns, FMCTechnologies may
access, review and disclose information
processed or stored by the companys
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, our standards
or policies
Requesting others to violate
our Code, standards or policies
Failing to report a known or
suspected violation of our Code,
standards or policies
Failure to cooperate honestly and
openly with an investigation of a
possible violation of our Code,
standards or policies
Retaliating against anyone who
makes a report of a possible violation
of our Code, standards or policies
Knowingly reporting a false allegation
of possible violation of our Code,
standards or policies.
Discipline can include loss of pay,
change in role or responsibility,
suspension, termination or
reimbursement to the company for
losses resulting from the violation.

10

Integrity
inside

11

FMCTechnologies

Integrity inside

Avoiding conflicts of interest

FMCTechnologies first
When conducting company business,
we each have a duty to put
FMCTechnologies interests before our
own personal gain. A conflict of interest
can arise when personal interests,
activities or relationships interfere with
our objectivity and loyalty to
FMCTechnologies.
The appearance of a conflict can be
just as damaging to an employee
and our companys reputation as
an actual conflict.

Some conflicts of interest are obvious,

such as a kickback payment for
awarding FMCTechnologies business to
a vendor. Other conflicts of interest may
be less obvious, such as conducting
business with a firm owned by a family
member, even when that firm appears
to be offering the best value.

It is best to avoid circumstances that

can give rise to even the appearance of
a conflict of interest. The examples
below describe situations that could be
viewed as a conflict of interest and
should be avoided or disclosed.

Outside
employment

Financial
interests

Personal
relationships

Political
relationships

A close relative works

for a supplier or
customer.
You conduct business
on the side for your
personal benefit
(not for the
companys) with
your company laptop.
You are asked to
serve on the board
of a competitor,
supplier or customers
company.

A close relative is an
owner or investor
in a privatelyowned customer of
FMCTechnologies.
You accept expensive
event tickets or gifts
from a supplier or
customer.
You learn about a
business opportunity
at work and decide to
pursue it for yourself.

You supervise or are

supervised by a close
relative or partner.
You are considering
hiring a close
relative or partner
as an employee or
contractor.
You have a
relationship with
a supplier that
inappropriately
influences your
business decisions.
You have a romantic
relationship with a
subordinate.

You work on a
political campaign
during working hours.
You express your
political views in
a setting where
your audience
may think you are
speaking on behalf of
FMCTechnologies.

To avoid conflicts:
Disclose to avoid later
misunderstanding and to ensure
transparency, you must disclose any
situation that can be viewed as a
potential conflict of interest to your
supervisor or Human Resources.

12

Seek approval if you must be

directly involved in a transaction for
FMCTechnologies with a family
member or close friend (or other
situation giving rise to the
appearance of a conflict of interest),
it may be necessary for you to seek
approval before proceeding. Please
contact the legal department which
can assist you with obtaining any
required approval. Executive officers
and directors must seek approval of
our Board of Directors (or its
designated committee).
13

FMCTechnologies

Integrity inside

Valuing our people

The strength of our company is
our people and their diversity.
FMCTechnologies employs women
and men of many nationalities and
backgrounds, all working together to
achieve common goals and objectives.
We strive to hire the best people and
provide opportunities for our
employees to excel.

Fair employment
practices
To ensure the growth and development
of our employees, you must:
Base all employment decisions on
job qualifications and merit
Never discriminate based on race,
color, gender, religion, national origin,
age, disability, sexual orientation or
veteran status
Create a harassment-free
work environment:
Dont threaten or intimidate
Never make unwanted
sexual advances
Dont post or distribute photos,
jokes or messages that could
be offensive or degrading.

Safety
We accept our responsibility to protect
the health and safety of our employees,
their families, our contractors, visitors
and the public.
Destination Zero is our commitment to
safety and a focus on our common
goal as a company: zero safety
incidents, worldwide, every day. We
expect all employees to behave using
these three key safety behaviors:
Prevent safety incidents by refusing
to do work perceived to be dangerous
to our personal health or safety
Report situations that have
the potential to harm an
employee, partner, or someone
in our community
Intervene without hesitation,
to stop a job or any unsafe behavior.
Any employee who believes a situation
or activity is unsafe or puts anyone at
risk has the obligation to intervene and
stop the job. A job can resume only
when a safe alternative is developed.
FMCTechnologies is committed to
performing work safely or not at all.
As part of our commitment to
Destination Zero, we should never
perform our work while under the
influence of alcohol or illegal drugs.

We strive to hire the best people and provide

opportunities for our employees to excel.
14

HSE 12 Golden Rules

Around-the-clock safety

1. Mechanical lifting No Touch Policy

7. Hot Work

Adhere to the No Touch policy. Tag lines and/or

push/pull sticks will be used to guide loads lifted
by cranes, hoists, forklifts or other mechanical
lifting equipment. Under no circumstances should
a person guide or handle a suspended load with
their hands.

Always complete a hot work permit prior

to using an open flame or spark-producing
equipment outside the designated area. Remove
combustibles and re-check the area frequently
after the work is completed.

2. Lift Truck Operations

Only a certified and authorized person is allowed
to operate a lift truck.

Always complete an entry permit prior to

working inside a confined space. Have
an escape plan ready.

3. Lifting, Carrying and Handling

9. Environmental Conservation

Always follow your manual handling training,

if in doubt, dont try to move an object or load.
Gloves are required for lifting, carrying and
handling parts, tools and equipment. Gloves
should not be worn when there is a risk of the
glove being caught and pulled into rotating or
moving equipment.

Always dispose of environmental waste

in approved containers.

4. Working at Height

8. Confined Space Entry

10. Driving Motor Vehicles

Always wear a seatbelt when riding in a motor
vehicle and never text or use a cell phone when
the vehicle is in motion.

11. Working in High-Risk Countries

Protect yourself from a fall when working

at height.

Before traveling to a high-risk country, always

assess the risks and be familiar with the
FMCTechnologies Crisis Plan.

5. W
 orking with
High Pressure Equipment

12. Management of Change

Only authorized and competent persons are

allowed to conduct pressure testing. Always
check for trapped pressure.

6. Energy Isolation

All changes to equipment, procedures, personnel,

systems, process, organization, product materials
or substances cannot proceed without a formal
HSE Management of Change assessment.

Isolate hazardous energy prior to conducting

work on any system. A lock, tag and try system
shall be used to isolate energy.

Privacy
As part of our everyday work, many of
us have access to personal information
about other employees, customers or
vendors. We must protect this
information at all times.

Collect only the information

necessary to perform our 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.

15

FMC Technologies

Integrity inside

Protecting company assets

Transparency in
financial information

In our workday we use technology and

tools provided to us by the company.
It is our responsibility to use those tools
and technology properly.

We all have a role to play in ensuring

the accuracy and completeness of our
financial information.

Secure tools, technology and

inventory to prevent loss (including
loss of information through
cyber-attack)
Account for tools, technology and
inventory regularly
Use only properly licensed software
Do not use company assets for
personal gain (although incidental
personal use of computers and cell
phones is permitted as long as the
use does not interfere with job duties)

Dont store personal information

on your company devices and dont
have an expectation that personal
files stored on a company device
are private
Do not use the intranet
to access sites that could contain
security threats (malware or other
malicious code)
to view external content that could
impact network performance
to access external content that could
be offensive, degrading or in
violation of the law.

Ensure all transactions are properly

authorized and recorded accurately
and in a timely manner
Make accounting decisions based on
FMCTechnologies financial standards
and recognized accounting standards
Submit and approve only valid
business expenses for reimbursement
A ssist with all reviews, including
internal and external audits, to
ensure transactions are fairly and
accurately recorded, and to detect
inappropriate transactions.
Not only is accurate information critical
for making responsible business
decisions, but inaccurate financial
information could mislead investors and
damage the companys reputation.

16

Money laundering
prevention
As part of ensuring that our financial
records are accurate, complete and
transparent, it is also necessary for us
to exercise appropriate diligence on
suppliers and other vendors to prevent
money laundering. Money laundering is
when someone involved in criminal
activities (terrorism, narcotics, bribery
or fraud) launders the proceeds of
their crimes to prevent detection and
appear legitimate. Appropriate due
diligence also prevents reverse money
laundering where legitimate funds may
be used (knowingly or unknowingly) to
finance terrorist activities.
To protect FMCTechnologies from these
risks, you should:
Conduct appropriate due diligence on
all suppliers, consultants or agents
Ensure that all payments to suppliers,
consultants or agents are made in
accordance with our financial
standards, including the requirement
that 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.

17

FMC Technologies

Integrity inside

Intellectual property and

confidential business information
Insider trading
and stock tipping
Sometimes, in the course of our work,
we will learn information about
FMCTechnologies, our customers or our
suppliers that has not yet been made
public. If we were to make stock
transactions based on this information
before it is disclosed to all investors, we
would have an unfair advantage.
Using material, non-public information
for your personal benefit (including
stock market transactions) is called
insider trading. Passing material,
non-public 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 are
violations of our core values,
this Code and the law.

Keep all material, non-public

information about FMCTechnologies
confidential
Treat all material, non-public
information about our customers and
suppliers with the same degree of
confidentiality you would give
FMCTechnologies information
Do not conduct stock transactions
based on material, non-public
information
Do not pass along material,
non-public information to others
Respect all blackout notices. To
reduce the risk of insider trading,
you may receive a notice that you
cannot buy or sell FMCTechnologies
stock during certain blackout periods.
If you are provided a notice, do not
make any FMCTechnologies stock
transactions until you have been
advised that the blackout period
has been lifted
Do not write options on
FMCTechnologies securities.

This can be a very difficult area to

navigate, so please contact the legal
department with any questions.
Tip: 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 FMCTechnologies stock price, whether it
is positive or negative, should be considered material, and not be shared with anyone.

Our history of innovation is one of our

biggest competitive advantages. This
innovation is the result of our
technology, our ideas, our techniques
and our processes these are called
FMCTechnologies intellectual property
or confidential information. Every
employee must protect this information
and be very careful not to
unintentionally or improperly share our
intellectual property. We all must take
the same care with our customers and
suppliers intellectual property as we
would with our own.
To ensure the protection of our
intellectual property, you should:
Respect the patent rights of other
parties when designing our products
and services
Protect confidential information
entrusted to us by our customers
or suppliers with the same care as
FMCTechnologies confidential
information
Follow our processes for identifying,
capturing and publishing information
about our technical innovations.
Disclosing new ideas too soon could
jeopardize our ability to obtain patent
protection for our innovations

E xecute timely all patent disclosures,

applications and assignment
documents required to protect
our intellectual property
Not disclose an innovation that
we have decided to protect as
a trade secret
Collaborate with caution. Our core
values encourage us to collaborate
within our company. However,
sharing information about our
technology developments and
innovations with others, even our
customers, can erode our ability to
protect those innovations. This can be
true, even if we have entered into a
non-disclosure agreement. Before
embarking on any detailed
discussions with other parties about
joint technology developments or
other collaborations, make sure you
have the approval of your manager or
supervisor and you have discussed
the project with the legal department
Remember your confidentiality
obligations continue after you
leave FMCTechnologies.

Tip: Trade secrets can include customer lists, marketing and sales plans, engineering
designs and technical information.

18

19

FMC Technologies

Integrity outside

Social media
Social media has changed the way
we communicate, work and live.
FMCTechnologies respects the right
of employees to use social media as a
medium of self-expression; however,
what we as individuals publish to online
sites should remain our personal views.
Our personal views should never be
attributed to FMCTechnologies and
should not appear to come from or be
supported by the company. Only certain
employees are authorized to use social
media to speak on behalf of
FMCTechnologies.

In addition, only certain employees are

authorized to access social media while
using FMCTechnologies assets. For
those who have access to social media
while at work, we must ensure that the
purpose and the time spent on social
media is in the best interest of the
company.
We should also be careful about our
social networking participation during our
personal time because our conduct, even
while off-duty, can reflect on and impact
the companys reputation. We all must
make sure that our use of social media or
social networking does not disclose the
companys confidential information or
discuss internal information.

The FMCTechnologies way

The wrong way

Make it clear that any opinions expressed via

social media are your own, unless specifically
authorized by FMCTechnologies
Communicate in a professional, respectful
manner.

Using social media in a way that is harmful to

FMCTechnologies, its employees, customers,
business partners, suppliers, competitors or
other stakeholders
Using social media to discuss FMCTechnologies
business without prior authorization.

Integrity
outside
20

21

FMC Technologies

Integrity outside

Integrity with customers

and suppliers
We have earned the trust of our
customers, business partners and
suppliers by building close partnerships
that achieve mutual success. By living
our core values and working under the
Code, we protect and grow that trust
and further strengthen our
relationships.

Avoiding improper
payments
FMCTechnologies competes fairly on
the strength of its technology, service
and execution excellence. The company
does 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
supplier contracts.

Certain reasonable and limited

expenditures for gifts, business
entertainment and customer travel may
be appropriate to build and maintain
customer and supplier relationships
and, in some instances, to fulfill our
contractual obligations. Care should be
taken to ensure that expenditures are
reasonable and cannot be confused
with improper payments, which can
include bribes and kickbacks.

The following dos and donts

will help you navigate between
appropriate business expenditures
and improper payments.

Ask your supervisor, controller or the

legal department if you are ever unsure
about an expenditure.

Do conduct appropriate due diligence

on any consultant, supplier, business
partner or agent that will interact on
our behalf with government officials
to ensure:

Tip: Providing anything of value can create the appearance of impropriety.

This can include money, goods or services provided to an individual or any of their
family members.
Examples of value can include:
A summer job for the daughter of someone who works for a supplier
A scholarship to a family member of someone who works for a customer
A donation to a charity run by the spouse of someone who works for a customer.

Do ensure records of expenditures

properly reflect the nature of
the transaction.
Do select business entertainment venues
and activities that reflect our core values.

There is no family or personal

relationship between the business
partner and the official that could
create the appearance of a conflict
of interest
The party has a reputation for integrity
The party understands our core
values and our Code and agrees
to abide by them
The party is not affiliated with a state
sponsor of terrorism or other speciallydesignated national (see Global Trade
Restrictions on page 27)
The fee is reasonable and customary.

Dont give (or receive) anything of value:

That violates local law or the
customers own rules and
business guidelines
That creates the appearance
of impropriety
To gain or retain an
improper advantage
Above a nominal value ($150 USD)
without prior approval
With such frequency that, although
of minimal value individually,
can create the appearance of
impropriety when aggregated
For gifts, entertainment and customer
travel for government officials without
prior approval
A s a facilitation payment (a payment
to expedite routine and administrative
government action) except in
extraordinary circumstances where
the safety or security of an employee
is in immediate threat
In cash.

Q: Who is a
government
official?
A: A government
official can be
someone in
any branch of
government (or
anyone exercising
governmental
powers), political
candidates or
parties, officers
or employees of
any corporation
owned or
controlled by
the government
including
state-owned oil
companies. For
FMCTechnologies,
this means that
the employees
of our national
oil company
customers are
considered
government
officials.

Do pay all consultants, agents,

suppliers, and business partners in
the country where they performed
work or sold goods.

22

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FMC Technologies

Integrity outside

Giving and receiving gifts and entertainment

Competing globally

This chart provides appropriate

guidance on giving and receiving
gifts and entertainment.

We are committed to competing fairly

and in compliance with all applicable
competition laws. Competition and
anti-trust 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.

Yes

Could the giving or

receiving of the
gift or entertainment
appear to create
an actual or perceived
conflict of interest?

No

You may not

give or accept
the gift or
entertainment
Is the gift or
entertainment
worth less
than $150 USD?*

Yes

Yes

Is the gift or
entertainment
for a government
official?

You must
obtain VP
approval prior
to giving or
accepting
the gift or
entertainment

Yes
No

Unless
prohibited by
law, you may
give or accept
the gift or
entertainment

*if multiple gifts, use the aggregate

annual value

24

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 upfront.

To protect FMCTechnologies from any

competition law risk, you should never
enter into any written or oral agreement
with a competitor to:
Allocate territories, customers,
projects or market segments
Share information on:
Prices
Capacity
Bids
Product or services
Features offered
Margins
Discounts
Prohibit work with specific
suppliers or customers.

Q: A customer
contact has
just sent me a
competitors
bid packet by
mistake. What
do I do?
A: Do not use the
information and
immediately turn
it over to the legal
department. The
legal department
will return it to
our competitor
and provide
assurance that all
copies, including
electronic copies
on email servers,
have been
destroyed.

No
Tip: Take extra care when attending trade shows or trade association meetings where you are
likely to interact with competitors.

Is it more than
$5,000 USD?*

You must obtain

approval of
VP, GC, COO/
President and
CFO prior to
giving the gift or
entertainment
VP: Vice President
GC: General Counsel
COO: Chief Operating Officer
CFO: Chief Financial Officer

No

You must
obtain VP
and one
additional
officer
approval prior
to giving
or accepting
the gift or
entertainment

25

FMCTechnologies

Integrity outside

Quality achieving
customer success
Our priority is to provide products and
services of outstanding quality at all
times. The FMCTechnologies approach
to quality demands the clear and
agreed definition of all requirements
before undertaking every task. We
evaluate our process against the
performance standard of zero defects.
Our ultimate goal is our customers
success.

Contracts
To thoroughly define our customers
requirements, FMCTechnologies
will only perform services or provide
products or systems with an executed,
written agreement or contract.
All contracts must be reviewed
and approved as provided in our
financial standards.

Integrity with governments

Global trade
restrictions
FMCTechnologies provides 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, governing
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
prohibiting the participation in boycotts.
Trade regulations can target countries,
business sectors within countries, or
individuals or organizations who are
sometimes referred to as statesponsors of terrorism or speciallydesignated nationals.
We must strictly comply with all
customs laws and trade controls that
apply to us, wherever we do business.

To give FMCTechnologies greater ability

to manage the movement of goods and
provision of services in a compliant
manner, you should:
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
properly 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.
Notify the legal department of any
requests to participate in boycotts.

Tip: Because of the diversity of our workforce, we must be aware of deemed exports and treat
them in the same manner as a physical export.
A deemed export is 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.

Our priority is to provide

products and services of
outstanding quality at all times.
26

27

FMC Technologies

Political activity
FMCTechnologies encourages
employees to participate in the political
process. We must make it clear,
however, that any political activity
reflects our individual beliefs and not
those of FMCTechnologies. No political
contributions should be made on behalf
of the company without the prior
approval of your manager and the
legaldepartment.

Integrity outside

Global immigration
compliance
We do not hire or recruit anyone not
legally authorized to work in the
country in which employment is sought.
We are committed to making sure the
employment, travel, transfer, and
residence of employees conforms to
applicable immigration and
employment laws. Each of us is
accountable for maintaining our
immigration status in compliance
with the laws of the countries in
which we work.

Each of us is
accountable for
maintaining our
immigration status in
compliance with the
laws of the countries in
which we work.
28

29

FMC Technologies

Integrity with others

Promoting
human rights

Charitable
contributions

We are committed to recognizing

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

We are required to carefully evaluate

and document all charitable donations
or other contributions made on behalf
of the company. We must take special
care with donations to charities made
at the request of government officials or
to charities in which a government
official may serve in an executive or
board capacity.

Environmental
stewardship
We are committed to operating our
business in a way that protects the
environment and promotes the
sustainable use of natural resources.

The Code of Business Conduct is available in multiple languages.

Go to the company intranet or visit www.fmctechnologies.com
to download a copy in the following languages:
Arabic/
Dutch/Nederlands
English
French/Franais
German/Deutsch
Indonesian/Bahasa Indonesia
Malay/Bahasa Melayu
Mandarin/
Norwegian/Norsk
Portuguese/Portugus
Russian/P
Spanish/espaol

30

Headquarters
FMCTechnologies, Inc.
5875 N. Sam Houston Pkwy. W.
Houston, TX 77086,
United States
J +1 281 591 4000
+1 281 591 4102
www.fmctechnologies.com

FMCTechnologies Ethics Hotline

J 877 488 8343, toll-free in the U.S.
001 503 748 0519, collect outside the U.S.
www.ethicspoint.com

All images property

of FMCTechnologies
unless otherwise stated.
The paper used to print the
Code of Business Conduct
is FSC (Forest Stewardship
Council) certified and is
Lacey Act Compliant.

2016 FMCTechnologies, Inc. All rights reserved.