Agent Compliance System (ACS)

ASA – Refresher session

Schlumberger-Private
Targeted population: P&S, Legal/Contract, GM Controllers, HR

Date: August 27, 2015

Presenters:
Romuald Louyindoula Mayamona
Monggal Aritonang
Agenda

1. Overview

2. ACS Users

3. Key Stakeholders

Schlumberger-Private
a. Contract
b. Human Resources

4. How to identify an Agent

5. Existing Agents re-assessment

6. Useful links
Overview
What the Agent Compliance System (ACS)?
Schlumberger’s internal system for the identification, risk assessment, approval, and management of Agents.
Prevent Schlumberger from potential financial and reputational damages while using Agents in furtherance of its business interests

Why an Agent Compliance System?

1. The use of Agents represents one of Schlumberger’s main risk
2. The FCPA and UK Bribery Act, requires companies to devise and implement “adequate procedures” to prevent bribery
3. Schlumberger will be held accountable under applicable anti-corruption laws for the improper actions made by its Agents
4. Agents managed in an inconsistent manner, in the past

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5. Penalties for breaching anti-corruption laws have been increasingly applied recently to O&G companies (reputation and operation
affected)

What’s an Agent?
• Visa permits Agents
• Customs clearing brokers Freight forwarders
• Tax consultants or law firms representing
Schlumberger before government authorities
• Suppliers assisting SLB to obtain Permits or Licenses
for Hazmat, explosives, etc.

• Sales Agents
• Distributors
• Consultants acting as a central point of contact for
the client in a specific project
• Marketing Agents who pursue opportunities to
extend an existing project and/or find new projects
 ACS Users – Workflow & Tasks

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As focal point between Schlumberger and the Agents, the ASL Requestor (Supplier Manager / Leader) has to manage Agents’
expectations in terms of timing, ensure that information provided is accurate, and let them know that information submitted in the system
cannot be modified.
Managed in ACS Managed in ASL Managed outside ACS & ASL
ACS Users - Escalation Approval Process
INITIAL REVIEWS FINAL REVIEWS & APPROVAL DECISION

3 Yes (Recommend) Automatic

approval

Low ALL AGREE? 3 No (Not Recommend) Automatic

Risk
Agent
rejection
4
1
Split Decision GeoMarket* Approval or
GeoMarket*
Legal Manager rejection
Counsel

Schlumberger-Private
3 No (Not Recommend) Automatic
2
rejection
GeoMarket* Medium ALL AGREE?
P&S Risk
Manager Agent 4
Yes or Split Decision GeoMarket* Approval or
Manager rejection
3

GeoMarket* 4 5 6 7 8
Controller High Yes Area Approval
Yes or Split Decision
GeoMarket* Area P&S Area Area
Risk General or
Agent Manager Manager Controller President
Counsel rejection

No
Rejection

ALL AGREE - 3 No (Not Recommend) Automatic

rejection

* GeoMarket, Region or Group as applied for NAM

Key Stakeholders - Contracts
You are at the end of the onboarding of the Agent, and have to make sure that any risks identified during the review process are covered in the contract

Please take the appropriate following actions based on the scenarios below:

 If you are asked to set-up a contract with an Agent (this could include but not limited to: Sales Agents, Marketing and/or Distributors)
 Verify the Agent status in ASL
 If the Agent is not available in ASL, direct the Business Requestor to the P&S Team in order to start the set-up of the Agent in ASL/ACS

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 Get the contract signed only when the Agent is APPROVED in ACS
 Stop immediately the contract negotiation if the Agent is REJECTED in ACS, and get further instructions from the P&S Team

 If the Agent was approved in the ACS

 Review with the GeoMarket Legal Counsel any risk identified during the ACS approval processes and insert relevant provisions in the final contract to ensure said risks are
fully covered
 Perform the contract negotiation, as per the standard business conduct clauses & procedure
 Deviations from Business Standard clauses must remain exceptional. If requested modifications affect the substance of one or more business conduct clauses or the Agent
resists including some of the standard business conduct clauses, the Contract Manager and Legal Counsel shall seek approval from the relevant General Counsel. Otherwise,
the Contract Manager shall seek approval from the relevant Legal Counsel.
 Get the contract signed and uploaded in ASL

Prior to finalize any contractual Agreement with an Agent, check in ASL if the Agent is active or liaise with your local P&S Team to ensure that the Agent
was approved in ACS
Key Stakeholders – Human Resources
Goal
• One of ACS main objectives is to centralize and automate the Agents assessment and monitor their life cycle
It is then a requirement for HR department, Managed Service Providers and Local Staffing Companies to be aware of ACS process, integrate and follow it for any Agents
selection.

Who is responsible to assess if a Contractor is an Agent or not?

• It is, HR Manager or Representative and Recruiting & Staffing Coordinator, responsibility to identify and ensure that the Contractor you are about to hire is an Agent or

Schlumberger-Private
not.

How to identify if a Contractor is an Agent?

Use the 3 screening question to ascertain whether the Contractor is an Agent or not; if Agent, please:
• Contact your local P&S and pass-on all information regarding the Agent to enable the contractor on-boarding process in ASL
• Let The Staffing Company or the Contractor know that he will receive a notification by e-mail to complete Schlumberger online Compliance Questionnaire, and provide
required documentation; if the Contractor doesn’t have an e-mail, a paper based copy of Questionnaire will be provided
Any Contractor identified as defined in the Contractors Management and Headcount Classification shall be hired only once approved in ACS.

What type of information and support HR has to provide to P&S?

• The Business need description, Contractor’s accurate details (name, telephone number, email address, etc.), any other relevant information
• Full assistance to facilitate smooth communication.
How to identify an Agent – 3 screening questions
1 Will the supplier / contractor / vendor interact or use third party to interact with Government Officials on behalf of Schlumberger?

2 Will the supplier / contractor / vendor main activity / service enable him to interact with a Schlumberger Client or its representatives with the ability to influence that
client’s decision to gain or retain business, or obtain any other benefit for Schlumberger?

3 Will Schlumberger issue a power-of-attorney to the supplier / contractor / vendor?

Schlumberger-Private
For P&S
• The questions are displayed at Step 5 during the on-boarding process in ASL, for new Agents;
• For existing records in ASL, the questions are available in the tooltip “Start Agent Compliance” under Agent Compliance Tab.

For Human Resources

• For Opus-Connect Countries (Denmark, NAM, Norway, Netherlands, Mexico and United Kingdom), the questions are embedded in IQN/TAPFIN system, and some forms
used by the Managed Service Providers (MSPs);
• The identification process for non Opus-Connect Countries varies as per local hiring procedures; the requirement remains to have the questions available in the any
Request Form used by or with Staffing Companies.

In case of uncertainty
• Please contact the Business Requestor, your GM P&S Manager or Legal Counsel
Existing Suppliers / Agents re-assessment - Plan
What is expected from you?
• Run all potential high risk Agents within H2 - 2015
• Other Agents to be re-assessed at the GM discretion, ideally during contracts renewal.

Activities - Sequencing

Description Timeline RACI Status

Schlumberger-Private
1 - Run entire database through Dow Jones to identify potential High
Risk Agents July 2015 ACS Team & Dow Jones - RA Completed

2 – Review the screening results for potential High Risk Agents

August 2015 ACS & TCC Team - RA Ongoing
identified and make recommendations; and send lists to Area / GMs

3 - Run into ASL/ACS all of the Agents identified as High Risk after GM P&S - RA
Dow Jones screening results & TCC inputs H2 - 2015 Open
ACS Team - CI

P&S Team – RA
4 - Run all remaining existing Agents through the ASL/ACS At GMs discretion Open
GMLC & Contract Mgr. - CI
Existing Suppliers/Agents re-assessment – Pre-requisites
ASL Integration with ACS for Existing Agent Supplier
ASL has been upgraded and provides a feature to update an existing supplier to an Agent in case of:
• Scope change qualifying a supplier as an Agent;
• Re-assessment to be done for an existing Agent, or any other conditions which may be applied.

Verify following details prior to check it as Agent in ASL

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1. Record must be Active
2. It has a valid Supplier Manager
3. It has a valid Primary Responsible Model
4. Supplier Management Model is either Local, Coordinated or Center-Led
5. Supplier Contact (Procurement / RFQContact) is up to date ( with correct name, title,
telephone, email address, etc.).

Follow the standard

ACS
ACS Process
Existing Suppliers / Agents re-assessment – Process
1. In ASL, select an existing supplier / agent
2. Open and edit the record
3. Go to the Agent Compliance section as shown in red box below and check the box to mark the supplier

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4. Click Save. After 15-30 minutes, you will receive an email from ACS asking to start the ACS process
ACS useful links
Agent Standard

Agent Compliance Questionnaire

Agent Compliance Due Diligence Procedure

ACS Dashboard

Schlumberger-Private
ACS in Tableau
Contact us
For process support
 ACS Administrator – ACS-Admin@slb.com

For Technical support

 Please raise an IT ticket, to SharePoint Applications – ACS

For any assistance in your Area

Please contact your respective ACS Project Leader / Champion

Schlumberger-Private
 ASA & MEA – Monggal Aritonang MAritonang@slb.com
Schlumberger-Private
Schlumberger-Private
Appendix
Role and title correspondence
This document uses standard Schlumberger role titles. If you are from EMS, SPM or WesternGeco Marine,
please find below the equivalence role title in the ACS processes.

SLB role titles used in this document WesternGeco – Marine EMS SPM

GM Legal Counsel Marine Attorney Center Contract Manager Legal Counsel

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GM P&S Manager Marine Sub-Category Manager Center Supply Chain Manager Project P&S Manager

GM Controller Marine Controller Center Controller Asset / Operations

Controller

Asset Manager
GM Manager VP Marine Center Manager East. or West. Hem VP Business, Development
& New Venture

Area General Counsel WG Legal Counsel Product Group Legal Counsel SPM General Counsel

Surface Equipment & Services Category

Area P & S Manager Product Group Supply Chain Manager None
Manager

Area Controller WG Controller Product Group Controller VP Commercial & Finance

Area President WG President Product Group Manager SPM VP