The Code is provided to all employees, who must acknowledge receipt to our Sr. Vice President of Human Resources.
The Company will provide periodic training on the Code, as well as periodic risk based training on key subject areas within the Code for relevant personnel.
If you are a director, officer, or have significant responsibility at the company, you must submit an annual Code compliance certificate.
We monitor and audit compliance with the Code.
We maintain systems that are reasonably designed to detect and report employee misconduct.
We document our compliance efforts and results.
We review the Code annually.
We periodically review our Code and recommend changes to our Board of Directors when appropriate. We look at changes in the company’s risk profile, international and industry best practices, and specific areas in need of improvement identified in response to past issues.
Our Chief Compliance Officer, in consultation with our Legal Department, Chief Executive Officer and the Audit Committee of our Board of Directors, as appropriate, addresses questions regarding how the Code is interpreted.
Antitrust: Laws and regulations designed to protect trade and commerce from unfair business monopolies in the interest of promoting competition.
Company accounting policies:
The Noble Energy, Inc.
Accounting Policy Manual
, available on the company intranet, provides for transactions to be recorded in accordance with United States Generally Accepted Accounting Principles (US GAAP), as well as Securities Exchange Commission (SEC) rules and regulations.
Consolidated financial statements: The company’s consolidated financial statements include: a Balance Sheet, Statement of Operations, Statement of Comprehensive Income, Statement of Shareholders’ Equity, and Statement of Cash Flows.
Harassment: Sexual or non-sexual conduct that is offensive, fails to respect the rights of others or interferes with work.
Incentive-based compensation: Includes, but is not limited to, annual cash bonuses, non-qualified stock options or restricted stock
Intellectual property: This could include copyrights, patents, trademarks, design rights, logos, brands, maps, and seismic information and data.
Lobbying: Communication (oral or written) with certain government officials and employees for the purpose of influencing any U.S. federal, state, or local legislation, program, policy, position, or other government action. Lobbying also includes preparation, research and other activities in support of such communications.
Includes, information that has not been disseminated in a manner that makes it generally available to the investing public.
information includes, without limitation, the following forms of information: financial, business and marketing decisions or other strategic plans; earnings, financial and business forecasts; competitive bids; potential transactions; proprietary data; inventions, designs and trade secrets; geological and geophysical information; and any information that would damage the company's business or reputation if it became public knowledge or was disclosed to a competitor.
Non-U.S. Government Official:
Any official, officer, employee, or representative of any
- non-U.S. federal, state or local government department, agency or
- instrumentality—whether elected or appointed—including but not limited to the
- following: any government-owned or government-controlled commercial
- enterprise, or any person acting in an official capacity for or on behalf of any such
- government department, agency or instrumentality; any official or employee of a
- public international organization or political party; any candidate for political
- office; any individual who is considered a government official under local law;
- and employees of national oil companies.
The company’s consolidated financial statements must “present fairly” its financial position, results of operations, and cash flows in conformity with U.S. GAAP.
In order to be presented fairly, our financial position, results of operations and cash flows must be in conformity with U.S. GAAP which includes whether:
(a) the accounting principles selected and applied have general acceptance;
(b) the accounting principles are appropriate in the circumstances;
(c) the financial statements, including the related notes, are informative of matters that may affect their use, understanding, and interpretation;
(d) the information presented in the financial statements is classified and summarized in a reasonable manner, that is, neither too detailed nor too condensed; and
(e) the financial statements reflect the underlying transactions and events in a manner that presents the financial position, results of operations, and cash flows stated within a range of acceptable limits, that is, limits that are reasonable and practicable to attain in financial statements.
Generally accepted accounting principles recognize the importance of reporting transactions and events in accordance with their substance. The substance of a transaction or event may differ materially from its form.