|Code of Conduct for Directors and Officers|
|Code of Ethics for Senior Financial Officers|
|Business Ethics Policy for Employees|
|The U.S. Export Controls & Economic Sanctions|
|The U.S. Foreign Corrupt Practices Act Policy and Procedures|
National Oilwell Varco, Inc. has established a hotline at the phone number shown above for any parties with an interest in National Oilwell Varco Inc. including, but not limited to employees and investors, to communicate directly and confidentially with National Oilwell Varco Inc.'s non-management directors.
This hotline is part of the procedure established by National Oilwell Varco Inc.'s audit committee for the receipt, retention, and treatment of complaints received by the company regarding accounting, internal accounting controls, or auditing matters; and the confidential, anonymous submission by employees of concerns regarding questionable accounting or auditing matters, in accordance with Section 301 of the Sarbanes-Oxley ACT. This hotline may also be used by any parties interested in making a concern regarding National Oilwell Varco Inc. known to the company's non-management directors. All calls made to the hotline will be confidential and controlled, and will be submitted directly to a non-management member of National Oilwell Varco Inc.'s board of directors.
Your call will be answered by an independent, automated system 24 hours a day, 365 days a year. A transcript of your call will be delivered to an independent director and member of National Oilwell Varco Inc.’s audit committee.
Conflict Minerals Policy
NOV is committed to compliance with Section 1502 of the Dodd-Frank Act, which requires disclosure of whether NOV’s purchase of certain minerals for use in its products have directly or indirectly aided armed groups in the Democratic Republic of Congo or surrounding countries. NOV’s Conflict Minerals policy and compliance program were developed in accordance with Annex I of the Organization for Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
NOV Policy on Political Contributions
National Oilwell Varco fully supports its employees involvement in the political process. However, employee participation in the political process must be done on the employee's own time and expense. Employees may never use National Oilwell Varco property, facilities, time or funds for political activities. Employees must not make any political contribution as a representative of National Oilwell Varco. National Oilwell Varco does not allow use of its own corporate funds or resources for participation or intervention in any political campaign on behalf of, or in opposition to, any candidate for public office, or allow use of such funds or resources to influence the general public, or segments thereof, with respect to public elections or referenda.
National Oilwell Varco does not make contributions or payments or otherwise give any endorsement of support which would be considered a contribution to political parties or candidates. Furthermore, National Oilwell Varco does not use corporate funds to make contributions to political candidates, political parties, political committees, or other such political entities.
National Oilwell Varco belongs to several trade associations and pays regular dues to these groups. National Oilwell Varco does not make additional, non-dues contributions to these organizations to fund the groups' political expenditures.
No Political Action Committee
National Oilwell Varco does not have a political action committee ("PAC").
National Oilwell Varco is committed to conducting business ethically, with integrity, and in accordance with law. National Oilwell Varco has various codes of conduct and ethics designed to focus its Board, management and its employees on areas of ethical risk, provide guidance to personnel to help them recognize and deal with ethical issues, provide mechanisms to report unethical conduct and help foster a culture of honesty and accountability. National Oilwell Varco's Board of Directors has oversight responsibility over these codes of conduct and ethics, and the Board, or appropriate committee thereof, will periodically review and assess the appropriateness of these codes and policies.