Agent Compliance Due Diligence Procedure

Agent Compliance Due Diligence Procedure
Reference: SLB-Compliance-P002
Version: A001
Release Date: February 1st, 2015
Owner: Yann Aubin
Authors: Zhan Alimbayev, Doris Bajah, John Benson, Kasondra
Fehr, Michael Hantel, Firdous Jan Jan Mohamed, Jorge
Monteiro, Jorge Vazquez
Private
Procedure SLB-Compliance-P002
Legal Information
Copyright © 2013 Schlumberger, Unpublished Work. All rights reserved.
This work contains the confidential and proprietary trade secrets of Schlumberger and may not be copied
or stored in an information retrieval system, transferred, used, distributed, translated or retransmitted in
any form or by any means, electronic or mechanical, in whole or in part, without the express written
permission of the copyright owner.
Trademarks & service marks

“Schlumberger,” the Schlumberger logotype, and other words or symbols used to identify the products
and services described herein are either trademarks, trade names or service marks of Schlumberger and
its licensors, or are the property of their respective owners. These marks may not be copied, imitated or
used, in whole or in part, without the express prior written permission of Schlumberger. In addition,
covers, page headers, custom graphics, icons, and other design elements may be service marks,
trademarks, and/or trade dress of Schlumberger, and may not be copied, imitated, or used, in whole or in
part, without the express prior written permission of Schlumberger.
Copyright@2013. Schlumberger, Unpublished Work. All rights reserved. 2

Revision History
Rev No Effective Date Changes Prepared by Reviewed by
(Name) (Name)
st
A001 February 1 , 2015 Z. Alimbayev, Y. Aubin,
Legal Counsel, Director of
UKG & NOR; Compliance
D. Bajah,
AAGC, EAF;
J. Benson,
Senior Legal
Counsel,
Corporate;
K. Fehr, A&F
Manager;
Michael Hantel,
GC,
Compliance;
F. Jan, GC,
Compliance;
J. Monteiro,
Forensic
Accountant;
J. Vazquez,
Senior Legal
Counsel,
Compliance
Approved by Yann Aubin, Director of Compliance

TABLE OF CONTENTS
1. Statement of Procedure 5
2. Objective 5
3. Scope 5
4. Implementation and Monitoring 5
4.1. Risk-based Compliance Due Diligence 5
4.2. Responsibilities 6
4.2.1. Responsibilities of Procurement & Sourcing 7
4.2.2. Responsibilities of Legal 7
4.3. Data Verification 8
4.4. Sources of Information 8
4.4.1. Internal Sources 8
4.4.2. External Sources 9
4.5. Evaluation of Results 14
4.5.1. Identification of Red Flags 14
4.5.2. Determination of Mitigation Measures 15
4.5.3. Risk Level Adjustment 15
4.6. Recommendation 16
4.7. Compliance Due Diligence Report 16
5. References 17
6. List of Appendices 17

1. Statement of Procedure
The Agent Standard requires that Agents be screened through Compliance Due Diligence (CDD)
before they are approved to do business with Schlumberger. The main purpose of performing a
CDD is to reach a reasonable level of confidence that the prospective Agent is capable of
performing the requested services in a manner that fully complies with Schlumberger’s Code of
Conduct and applicable laws.
This Procedure is intended to be used in conjunction with the Agent Standard and the Agent
Compliance Due Diligence Guidelines provided in Appendix 1 to this procedure. Any term in
capital letters is defined in the Agent Standard and have the same meaning as the one it has on
the Agent Standard.
2. Objective
This CDD Procedure contains tools and resources which must be used to conduct any
Compliance Due Diligence Agents as required by the Agent Standard.
3. Scope
The CDD Procedure is mandatory to any CDD conducted on an Agent of Schlumberger. As CDD
focuses on an Agent’s Corruption Risks, documentation or information requested from the Agent
or any external third party should be related to those risks.
4. Implementation and Monitoring

4.1. Risk-based Compliance Due Diligence
Agents are classified by their level of Corruption Risk (Low, Medium or High risk). A
preliminary classification is made of every Agent after the Agent Compliance
Questionnaire is completed and available in the Agent Compliance System (“ACS”). The
initial Agent’s risk level is an indicator of the Corruption Risks posed by the Agent and a
tool to determine the efforts and resources to be allocated to the CDD.
Accordingly, 3 levels of Compliance Due Diligence have been defined:
 Level 1 Low Risk Agents: “Key verifications”.

 Level 2 Medium Risk Agents: “Enhanced assessment”.
 Level 3 High Risk Agents: “Exhaustive investigation”.
While the scope of due diligence will remain essentially the same across all levels of
CDD, the depth of investigation, i.e. the quantity and type of information and/or
documentation to be analyzed to back up conclusions will vary with the Agent’s risk
level. Accordingly, the effort needed to complete CDD will increase with the Agent’s risk
level.

Figure 1 – Three levels of Compliance Due Diligence based on Agent’s risk
Agent Risk Level Due Diligence Level
Level 3 – Exhaustive investigation
+
External intelligence (ie. embassy
reports, adhoc reports, external due
High Risk diligence providers reports)
Level of effort and resources

 Interviews of Agents and selected
commercial references
Level 2 - Enhanced evaluation
Medium Risk
+ 

Additional database search
Selected interviews with internal
stakeholders
Level 1 – Key verifications
Low Risk  Agent Compliance

Questionnaire verification
 Basic database search
The ACS generated Agent’s risk level needs to be confirmed or adjusted by the Legal
Counsel after Compliance Due Diligence is completed, as provided in Section 4.5.3 of
this Procedure.
4.2. Responsibilities
Process and Responsibilities Overview
The CDD Procedure includes the following key steps which are split between
Procurement & Sourcing and Legal as shown below:

Figure 2 – Compliance Due Diligence process and responsibilities overview
Responsibilities
Procurement &
Legal
Sourcing
Identify additional Issue

Verify Assess results
Collect Collect Red Flags and recommendation
consistency of and validate
initial data additional data Mitigation on prospective
collected data Red Flags
Measures Agent
Collect : Verif y inf ormation Review and assess Collect additional Identif y additional Review risk level
• Agent obtained is results f or all key data as required: Red Flags. with supporting due
Compliance complete and up to areas of risk • External Due diligence
Questionnaire : date. provided by ACS Diligence Reports For each Red Flag documentation.
internal • International identif ied, def ine
Main activities
questionnaire, Review and Watch lists Mitigation Document all due

external validate system • Interviews with Measures if diligence steps.
questionnaire and generated red prospective agent applicable.
commercial f lags. • Sites visits Issue a Yes/No
ref erences • Etc… recommendation
• Online screening f or hiring
report prospective Agent.
Agent Risk score

Agent Risk score adjusted by
generated by ACS
GMLC
as required
(increased, decreased or maintained)
4.2.1. Responsibilities of Procurement & Sourcing
The Supplier Manager / Leader (SML) will act as the main liaison between the
Agent and Schlumberger. The SML is responsible for collecting initial data, i.e.
the Agent Compliance Questionnaire as well as the online screening report on
the Agent. The SML will also ensure the Agent Compliance Questionnaire is
complete and that the required documentation is uploaded in the ACS before
submitting the Agent record to the Legal Counsel.
If any of this information is missing at any stage of the CDD, it is the

responsibility of the SML to collect that information and to provide it to the Legal
Counsel.
4.2.2. Responsibilities of Legal
The Legal Counsel’s responsibilities start when he/she receives the initial data
collected on the Agent by the SML. At that point, the Legal Counsel shall:
 Review and verify data collected;

 Collect and verify additional information, as required;
 Review results, validate Red Flags generated by the ACS, identify additional
Red Flags and define appropriate Mitigation Measures if applicable following
Sections 4.5.1 and 4.5.2 of this Procedure;
 Adjust level initially provided by ACS as required following Section 4.5.3 of this
Procedure;
 Produce a Due Diligence report including key findings and recommendation to
approve or reject Agent, according to Section 4.7 of this Procedure.

4.3. Data Verification
In order to verify the accuracy of the information provided by the Agent the following
steps must be followed:
 Ensure that information provided is coming from reliable sources;
 Verify that documents provided are complete and up to date;
 Authenticate questionable “official” documents with the issuer, as applicable;
 Cross-check information in multiple sources to ensure it is consistent, as applicable.
In some situations, the verification of information gathered may reveal gaps or

inconsistencies which need to be addressed. If not resolved after investigation, these
gaps or inconsistencies should be highlighted to management.
4.4. Sources of Information
The Agent’s Risk Level will drive the source of information that must be reviewed by the
Legal Counsel. In Appendix 2 of this CDD Procedure the Legal Counsel will find the
Compliance Questionnaire with the different source of information that must be reviewed
taking into account the Agent Risk Level. The fact that a source of information is not
mandatory for a certain Risk Level does not preclude consulting that source if necessary to
evaluate an identified Red Flag.
The list of sources provided in Appendix 2 is not exhaustive. During the CDD the Legal
Counsel could identify additional sources of information not covered in this DD Procedure.
.
4.4.1. Internal Sources
Internal sources of information are any type of information sources within Schlumberger that
will enable the Legal Counsel to obtain relevant information on an Agent or pertaining the
proposed transaction with the Agent.
4.4.1.1. Business Requestor
To assess the risk that an Agent possess to Schlumberger, it is key to

understand, in particular, what is the business need, what value the Agent is
going to bring to Schlumberger, types of services to be provided and how and
where the Agent is going to be paid.
The Business Requestor is in the best position to provide the Legal Counsel
responsible for the CDD of any given Agent with all of this information.
The Legal Counsel must contact the Business Requestor if during the CDD has
any doubt or question regarding the topics described above.
Document the conversation with the Business Requestor and upload the minute
or e-mail in ACS.
4.4.1.2. Employee Recommending the Agent

The employee recommending the use an Agent can be a valuable source of

information. This person could answer the following questions:
(i) How did you find the Agent?
(ii)Why are you recommending the use of the Agent?
(iii)
What was your experience while working with the Agent?
(iv)During your relationship with the Agent did you notice any unethical
behavior?
(v) How do you rate the services provided by the Agent?
If during the CDD it is not clear why the employee is recommending the use of
the Agent the Legal Counsel must contact him for clarification.
Document the conversation with the employee and upload the minutes or e-mail
in ACS.
4.4.1.3. Internal Expert
The involvement of an internal expert during the CDD will be driven mainly by the
type of service the Agent is going to provide or applicable legal framework. The
Legal Counsel must contact the internal expert if during the CDD has a question
on their expertise.
For example, Schlumberger is entering a business with a local sales agent in
order to take advantage of a tax incentive regime. In that case the Legal Counsel
must contact the tax manager in order to validate the legitimate business
purpose of proposed relationship with the sales agent.
Document the conversation with the expert and upload the minutes or e-mail in
ACS.
4.4.2. External Sources
An external sources of information is any type of source available outside Schlumberger

where the Legal Counsel can obtain relevant information pertaining an Agent.
4.4.2.1. Agent Interview
The objective of interviewing the Agent and its Key Employees is to assess its
integrity, reputation, culture and commitment toward compliance and to clarify
any outstanding issues raised during the review of the Agent’s information. The
interview questionnaire should be tailored based on the specific facts
surrounding the Agent.
When possible in person interviews are preferable. This will allow the Legal
Counsel to assess the interviewee body language and facial expressions when
certain questions are asked. This is also a way of getting to know the Agent’s
office or facility.

Data privacy laws of the relevant country where the interview is taking place must
be examined in advance. Privacy laws often aim to protect some of information
that a due diligence process is seeking to uncover. An individual’s criminal
history or interactions with the justice system are deemed sensitive data under
many countries’ privacy laws.
Therefore, before conducting any interview the Legal Counsel should verify if the
scope of it does not exceed the legal boundaries of the relevant country’s
personal data privacy laws.
Below are some areas of investigation that should be covered during the Agent’s
interview:
 What is the general integrity reputation of the Agent?

 Are there any known integrity issues?
 Has there been any allegation of corruption, bribery or improper payments?
 How does the Agent deals with Government entities?
 Does the company have a Code of Ethics or similar document?
 Ask the Agent to explain how its compliance program works. The quality of
the documentation as well as whether is truly implemented must be
assessed
 What is the level of compliance awareness of the Agent and its employees?
 Does the Agent’s provide anticorruption training to its employees? Is training
provided to the Agent’s contractors working for Schlumberger? How (e.g.
live, online) is the training conducted?
 What is the Agent policy or approach to client entertainment, gifts, charitable
donations, sponsorship and political contributions?
 What is the Agent’s policy regarding facilitation payments? Are they allowed?
Under which circumstances?
Interviewing the Agent and its Key Employees is mandatory in case of High Risk Agents.
The interview must be documented and added to the DD Report.
4.4.2.2. Commercial References
The Agent needs to provide at least two commercial references regardless of the
Agent Risk Level. If possible, one of the references should be a multinational
company. The commercial reference should be a customer/ client of the Agent or
a financial institution the agent has had dealings with.
The feedback provided by the commercial reference will help the reviewer to
evaluate the Agent’s experience, business ethics, government relations and
integrity reputation.
Although the CDD is focused on identifying potential Corruption Risk it is

important to assess the quality of the services provided by the Agent. A negative
reference on the quality of the services should raise a Red Flag.
Any negative feedback must be followed up with the commercial reference.
The commercial references feedback (written or verbal) must be documented

and uploaded in ACS.

4.4.2.3. Site Visit
When possible it is advisable to visit the prospective Agent’s office and/or facility.
The purpose of this site visit is to verify that it actually exists and that the Agent’s
has the requisite staff and qualifications to perform the services for
Schlumberger.
Site visits should be conducted at the address given by the Agent as its main
business office or operational base. Site visits can provide valuable information
about the Agent’s operation. During the site visit the Legal Counsel should look
for the following:
(i) If the Agent’s office or operation actually exists at the given location;
(ii) Nature and size of the Agent’s facilities. This will provide the Legal Counsel
with an idea if the office/facility of the Agent is in line with its size and
importance;
(iii) Whether the Agent’s name/logo is at the entrance of the office or facility; or
(iv) If the Agent main office is located in a business area or in a marginal
neighborhood.
During the site visit it is advisable to take pictures of the Agent’s office or facility
and incorporate them as part of the DD Report.
A site visit to the Agent’s office/facility is required for High Risk Agents.
4.4.2.4. Corruption Perception Index (CPI)
Use the Corruption Perception Index (CPI) of the country where the Agent is
going to provide the contracted service as an indicator of the level of corruption
of the public sector of the targeted country.
Transparency International developed a ranking of countries according to the

extent to which corruption is believed to exist. It ranks countries on a scale of
zero to 100 using the CPI, with zero indicating high levels of corruption and 100
indicating low levels.
The CPI is one of the most widely-used tools in corporate risk management.
However, it is important to recognize that:
 Corruption happens in all countries, and so even a country that scores well
on the CPI may present risks;
 There is regional variation within countries;
 The CPI is based on perceptions and measures only public sector
corruption;
ICPI is a relevant component of the Agent’s risk profile, but is not a valid risk
indicator by itself. CPI scores should only be used to put the rest of the Red
Flags analysis (Type of compensation, company history, ownership profile, PEP
status, sanctions hits, etc.) into a context. It is not a valid risk indicator by itself.

4.4.2.5. Media Search
Media search is mandatory for the three level of Agent’s Risk. The search should
be done using the online screening providers available at each GM or through a
simple web search.
The scope of the search should aim for negative press about the Agent and its
Key Employees or any additional information that could reveal inconsistencies
with the information provided by the Agent.
The online screen provider report will tell the Legal Counsel if the Agent is a
Politically Exposed Persons (PEPs), Government Officials, Relatives and Close
Associates of a PEP, State Owned/Controlled Entities or listed in a global
sanction lists.
The Agent’s name and its Key Employees including shareholders should be the
target of the search. The media search should be conducted both in English and
in the local languages.
The Agent website is another valuable source of information. In the Agent
website the Legal Counsel could find the following information:
 Management Team Biographies;

 Organizational Charts;
 Corporate Governance (Mission Statement and Corporate Governance
Guidelines);
 News Stories and Press Releases;
 With any securities agency filings;
 Annual Reports;
 Code of Conducts and related policies;
It is important to note that allegations of corruption must be distinguished from

formal charges or from convictions.
The results of the media search should be crosschecked with the available
information of the Agent obtained from other sources.
The Legal Counsel should not base its decision only on the results obtained from
a media search.
The online screening provider report must be uploaded in ACS.
4.4.2.6. Corporate Registry Records
In some countries Local Corporate Registries are a useful source of information

to verify if the corporate information (provided by the Agent is true, accurate and
not misleading).
The Corporate Registry records where the Agent is incorporated, and will allow
the Legal Counsel to verify the following information:
 Full name of the Agent’s legal entity;

 Date of incorporation;
 If the Agent’s legal entity is active;
 Details of the initial, past and current directors, shareholders and senior
executives (if listed);
 Share capital;
 If the Agent is entitled to provide the service offered to Schlumberger under
its corporate purpose;
 Tax ID number;
 Registered full physical address; or
 Legal Form/Type (i.e. Limited Company, Joint Stock Company etc.).
The Corporate Registry often provide details on any company name changes
(sometimes done to avoid regulatory restrictions), financial data, information on
related parties, subsidiaries and other partnering companies.
The information obtained from the Corporate Registry records can be used to
narrow the online screen searches and media analysis.
Depending on the country, this search can be conducted online with the payment
of requisite fees. In other countries, it will require attending the actual office in
which the initial registration was conducted and searching physical files to obtain
a photocopy of the necessary information. The local outside counsel can assist
the Legal Counsel in obtaining the corporate records of a prospective Agent.
Please note that in some countries the Corporate Registry records are not
reliable or are not available for the public. In the first place the Legal Counsel will
need to assess if the Agent Corporate record will add value to the Due Diligence.
The Agent’s corporate information must be uploaded in the ACS.
4.4.2.7. Civil and Criminal Records
Civil and criminal records will reveal any civil, criminal and regulatory matter
where the Agent is involved. This is a useful source of information to asses if the
Agent has a history of serial litigation, criminal problems, counterfeiting, etc. The
search should be focused on criminal conviction histories relating to the Agents
and Key Employees, litigation(s) representing fraudulent or unethical business
practices, regulatory actions relating to alleged or demonstrated mismanagement
or fraudulent/unethical business practices.
These records together with the rest of the information gathered on the Agent will
help the Legal Counsel to develop the Agent risk profile.
Be aware that in certain countries civil and criminal records are not available to
the public, not centralized or are simply unreliable.
Civil and criminal records must be obtained for High Risk Agents in those places
where they are available and uploaded in ACS.

4.4.2.7. Professional Associations
Some professions (accountants, lawyers, etc.) need an authorization from a

professional body in order to provide services to third parties.
The Agent’s Professional association can inform the Legal Counsel if the Agent
has been disbarred or if there is any on-going or historical proceeding related
with the Agent unethical behavior, in which case some additional research may
have to be done.
This information is not always accessible to the public so it will depend on the
country where the CDD is taking place.
The Agent’s professional association inquiry is required for High Risk Agents
where they are available and need to be documented an uploaded in ACS.
4.4.2.8. Dunn & Bradstreet or Equivalent Credit Report Agency
Credit Report Agencies maintain historical information pertaining to credit

experience on individuals or businesses. The data is collected from various
sources; most commonly firms extending credit such as credit card companies,
banks and credit unions. They also collect information from public records, such
as bankruptcies.
Business credit reports can provide the Legal Counsel with following information
about the Agent:
 Corporate Information;
 Evidence of bankruptcy;
 Fraud or criminal proceedings in the history of the Agent or its management;
 Payment history;
 Public fillings;
 Credit rating;
The Legal Counsel can request a Dun & Bradstreet Credit Report through the
GM Controller or P&S manager. It is also advisable to find out if they are also
using a local credit agency.
Credit Rating Reports are mandatory for High Risk Agents where they are
available and must be uploaded in ACS as part of the DD Report.
4.5. Evaluation of Results
4.5.1. Identification of Red Flags
Once information is collected through the CDD, the Legal Counsel should identify
potential Red Flags. The presence of one or more Red Flags in a transaction
suggests a need for greater scrutiny and for implementation of mitigation
measures to prevent any potential violation of the Schlumberger Code of
Conduct and related applicable laws.
Red Flags that do not present serious issues at one stage of a relationship with
an Agent may pose significant liability risks at a different stage or in combination
with a different overall set of facts. Thus, the significance of Red Flags must be

considered in the context of all of the facts, rather than in isolation. All Red Flags
raised must be investigated and appropriately addressed.
For that purpose, a non-exhaustive list of Red Flags is provided in Appendix 1.
4.5.2. Determination of Mitigation Measures
Each Red Flag raised should be addressed by determining Mitigation Measure(s)

needed if any. When implemented, these measures should contribute to reduce
or eliminate the anticipated Corruption Risk associated with the Red Flag.
While Mitigation Measures will necessarily vary according to the circumstances,

to be effective, they should be concrete, achievable and consistently
followed up.
Examples of Mitigation Measures include but are not limited to: providing Agent’s
key employees with training on anti-corruption program (when required),
following up expenses invoiced by an Agent on a monthly basis, specific
contractual provisions (i.e. the Agent obligation to perform compliance due
diligence on its sub-agents or to imposed the same compliance terms and
conditions of the agreement with Schlumberger to its contractors, etc.).
4.5.3. Risk Level Adjustment
After CDD is completed, the Legal Counsel must review the identified Red Flags
in order to determine whether the Agent’s risk level initially generated by ACS
accurately reflects the level of risk of the Agent’s relationship. If not, the ACS
generated risk level may need to be increased or decreased.
The Agent’s risk level is evaluated on the basis of the likelihood of a Corrupt Act
happening in the course of the relationship with the Agent. Likelihood is
calculated as follows:
Likelihood = (1) Frequency * (2) Probability
(1) Frequency is rated 1 to 5 and is determined by the frequency of

interactions between the Agent and Government Officials or Clients.
(2) Probability is rated 1 to 5 and is determined by the number and
importance of identified Red Flags and the ability of related Mitigation
Measures to reduce or eliminate the anticipated Corruption Risk
associated with such Red Flags.
The resulting score of likelihood (min. 1, max. 25) is then used to position the
Agent on the Agent Risk Rating Matrix, as presented in the figure below:

Figure 3 – Agent Risk Rating Matrix for final risk level evaluation
Probability
Very High 5 5 10 15 20 25
High 4 4 8 12 16 20
Medium 3 3 6 9 12 15
Low 2 2 4 6 8 10 High risk

Medium risk
Low risk
Very low 1 1 2 3 4 5 Figures indicate final score for
likelihood (min.1. max. 25)
1 2 3 4 5 Frequency
> 5 yrs > Annually > Monthly > Weekly > Daily
The Agent’s risk level obtained is then compared to the risk level provided by ACS. In
case there is a discrepancy, the Legal Counsel should update the risk level in ACS and
provide rationale for risk level increase or decrease.
4.6. Recommendation
The Legal Counsel should base his advice on whether or not to recommend an Agent on
the assessment of the Red Flags identified and the related proposed Mitigation
Measures. If assistance is required, the Area General Counsel must be consulted.
4.7. Compliance Due Diligence Report
For Low Risk Agents, the Legal Counsel should record his recommendation in ACS
without formalizing a CDD report.
For Medium and High Risk Agents, the Legal Counsel must formalize a CDD report,
including the documentation of the steps taken in the Compliance Due Diligence showing
what was done, when, and by whom.
This Compliance Due Diligence Report should contain the following sections at a
minimum:

Section Title Key content
1 Executive summary Agent identity and background.
2 Key findings Results of investigations with respect to every

area of investigation covered.
Areas not covered need to be highlighted.
Please note that key findings may or may not be
lead to the identification of Red Flags.
3 Appendix : List of key steps taken during CDD: interviews

Documentation of conducted, sources of information used,
Due Diligence steps documents reviewed, sites visits made,
documents requested but not obtained.
The CDD report template is provided in Appendix 3. The final CDD report must be uploaded
into ACS.
5. References
The Blue Print in Action – Our Code of Conduct

Agent Standard
6. List of Appendices
Appendix 1: List of Potential Red Flags

Appendix 2: Agent Compliance Due Diligence Guidelines
Appendix 3: Compliance Due Diligence Report Template

Agent Compliance Due Diligence Procedure

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Trademarks & service marks

Copyright@2013. Schlumberger, Unpublished Work. All rights reserved. 2

Approved by Yann Aubin, Director of Compliance

Copyright@2013. Schlumberger, Unpublished Work. All rights reserved. 3

Copyright@2013. Schlumberger, Unpublished Work. All rights reserved. 4

4. Implementation and Monitoring

Accordingly, 3 levels of Compliance Due Diligence have been defined:

 Level 1 Low Risk Agents: “Key verifications”.

Copyright@2013. Schlumberger, Unpublished Work. All rights reserved. 5

Figure 1 – Three levels of Compliance Due Diligence based on Agent’s risk

Agent Risk Level Due Diligence Level

Level 3 – Exhaustive investigation

Level of effort and resources

Level 2 - Enhanced evaluation

Level 1 – Key verifications

Low Risk  Agent Compliance

Process and Responsibilities Overview

Copyright@2013. Schlumberger, Unpublished Work. All rights reserved. 6

Figure 2 – Compliance Due Diligence process and responsibilities overview

Identify additional Issue

questionnaire, Review and Watch lists Mitigation Document all due

Agent Risk score

4.2.1. Responsibilities of Procurement & Sourcing

If any of this information is missing at any stage of the CDD, it is the

4.2.2. Responsibilities of Legal

 Review and verify data collected;

Copyright@2013. Schlumberger, Unpublished Work. All rights reserved. 7

4.3. Data Verification

In some situations, the verification of information gathered may reveal gaps or

4.4. Sources of Information

4.4.1. Internal Sources

4.4.1.1. Business Requestor

To assess the risk that an Agent possess to Schlumberger, it is key to

4.4.1.2. Employee Recommending the Agent

Copyright@2013. Schlumberger, Unpublished Work. All rights reserved. 8

The employee recommending the use an Agent can be a valuable source of

4.4.1.3. Internal Expert

4.4.2. External Sources

An external sources of information is any type of source available outside Schlumberger

4.4.2.1. Agent Interview

Copyright@2013. Schlumberger, Unpublished Work. All rights reserved. 9

 What is the general integrity reputation of the Agent?

4.4.2.2. Commercial References

Although the CDD is focused on identifying potential Corruption Risk it is

Any negative feedback must be followed up with the commercial reference.

The commercial references feedback (written or verbal) must be documented

Copyright@2013. Schlumberger, Unpublished Work. All rights reserved. 10

4.4.2.3. Site Visit

4.4.2.4. Corruption Perception Index (CPI)

Transparency International developed a ranking of countries according to the

Copyright@2013. Schlumberger, Unpublished Work. All rights reserved. 11

4.4.2.5. Media Search

 Management Team Biographies;

It is important to note that allegations of corruption must be distinguished from

4.4.2.6. Corporate Registry Records

In some countries Local Corporate Registries are a useful source of information

 Full name of the Agent’s legal entity;

Copyright@2013. Schlumberger, Unpublished Work. All rights reserved. 12

The Agent’s corporate information must be uploaded in the ACS.

4.4.2.7. Civil and Criminal Records

Copyright@2013. Schlumberger, Unpublished Work. All rights reserved. 13

4.4.2.7. Professional Associations

Some professions (accountants, lawyers, etc.) need an authorization from a