2011 Annual Report - SBM Offshore

Anti-Corruption Policy and Compliance guide with all partners, agents, suppliers and other intermediaries,
requiring them to comply with all published requirements. Any intermediary who does not comply with
anti-corruption or anti-bribery laws or the Company’s policies is deemed to be in breach of contract and will have
their contract terminated.
Annual certification process
The Company completes an annual certification of compliance exercise to monitor employees’ compliance with its
Code of Conduct. The certification of compliance concerns all employees in positions of responsibility and in
corporate and managerial roles. These certificates contain a personal confirmation that individuals understand the
Company’s Ethical Standards, and that both they and their teams operate in accordance with them.
SBM Offshore’s goals for 2012
In 2012, the Company is committed to continual improvement of its compliance programmes. To that end, the
Company has retained a specialist law firm to further enhance its existing anti-corruption policies and procedures.
It includes its processes related to the retention and oversight of consultants and other third parties and its system
of internal controls, with the goal of ensuring that the Company's compliance programme is consistent with
established best practices in this area.
The Company plans to give all its employees access to its ethics e-learning course and to continue its due
diligence campaign. The management will encourage all employees to protect and enhance the Company’s high
ethical reputation.
This is a customized selection from the SBM Offshore N.V. Annual Report 2011
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