Code of Conduct

The Noble Energy Code of Conduct lays out our expectations for directors, officers, employees and contract staff worldwide. It applies to our majority-owned affiliates and their employees as well as to business partners such as service providers and agents. We consider it an integral part of our governance structure and make it available in various languages and formats, including an interactive version on our website, so that all those affected or interested can become familiar with its components and our process for ethical decision-making.

To support our commitment to integrity, we offer an externally managed, anonymous and confidential reporting hotline (NobleTalk℠), available 24 hours a day, 365 days a year. NobleTalk℠ offers toll-free or collect-call access and a web intake form for anyone to report concerns or ask questions. NobleTalk℠ support is available in multiple languages. Employees are also encouraged to report matters internally to our Global Compliance, Human Resources and Legal departments.

In 2015, 43 cases were reported through NobleTalk℠. The majority of these reports dealt with conflicts of interest, personnel relations, time-keeping concerns and general inquiries. Three cases resulted in disciplinary action.

Alleged violations are tracked, assigned an investigator and managed in our case management database allowing categorization, streamlined workflow and internal reporting. All NobleTalk℠ matters and dispositions of closed matters, including any disciplinary or remedial actions, are reported quarterly to the Audit Committee of our Board of Directors.