Conduct and Ethics

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Conduct and Ethics

Governance Hotline


National Oilwell Varco, Inc. has established a hotline for any parties with an interest in National Oilwell Varco Inc. including, but not limited to employees and investors, to communicate with National Oilwell Varco Inc.'s non-management directors. Such communication, including complaints and concerns, can be reported confidentially and anonymously, where allowed by local law, via phone, email or mail to the contact information below. This hotline is part of the procedures established by National Oilwell Varco Inc.'s audit committee for the receipt, retention, and treatment of complaints received by the company, in accordance with SEC regulations.

Phone:
1-800-676-4380

Mail:
Attn: VP Internal Audit
National Oilwell Varco, 7909 Parkwood Circle Drive
Houston, Texas 77036-6565, USA

Email:
risk.mitigation@nov.com

Concerns and complaints are received and reviewed by a corporate Risk Mitigation team. Significant matters regarding accounting, internal accounting controls, or auditing matters will be communicated to the Chair of the Audit Committee. 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.

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.

Conflict Minerals Policy

Political Contributions

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.

Political Contributions

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").

Board Oversight

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.