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•	Production Enhancement

•	Cementing

•	Completion Tools

•	Production Solutions

•	Pipeline & Process Services

•	Multi-Chem

•	Artificial Lift

•	Baroid

•	Sperry Drilling

•	Wireline and Perforating

•	Drill Bits and Services

•	Landmark Software and Services

•	Testing and Subsea

•	Consulting and Project Management

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•	Maintained the Conflict-Free Sourcing Policy Statement on the external website of Halliburton at http://www.halliburton.com/en-US/about-us/supplier-relations/conflict-minerals-policy.page?node-id=hgeyxt74, which is applicable to our global operations including our Supply Chain, and informed direct suppliers via our RCOI email;

•	Maintained our standard Master Purchase Agreement and standard Purchase Order Terms & Conditions templates to include conflict-free sourcing and disclosure requirements;

•	Operated a cross-functional internal team among Procurement, Material Management, Finance, Information Technology, and the Law departments led by our Procurement, Materials & Logistics (PM&L) Performance Management Group;

•	Retained a third-party service provider to query our applicable suppliers using the CMRT;

•	Established a system of controls and transparency by developing a due diligence process using the CMRT, including evaluating and scoring the risk presented by each smelter, refiner, and respondent (supplier providing a CMRT) based on the smelters and refiners indicated and due diligence program described;

•	Contracted for a portal to provide Halliburton better reporting and data validation capabilities, with 2016 supplier information provided from our Enterprise Resource Planning (ERP) system, which allows our suppliers to access our request via a familiar tool used by many issuers, maintaining the participation rate;

•	Stored relevant records in an electronic database on a SharePoint site;

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Emphasized supplier education and training, utilizing a third party provided learning management system; provided all in-scope suppliers access to a “Conflict Minerals” training course, which is tracked and evaluated based on completion, with all suppliers encouraged to complete all modules within this course; and educated 3TG suppliers with various conflict minerals resources (including 3TG definition, CFSI website, link to download the most current CMRT, and our third-party service providers’ supplier portal instructions);

•	Continued to offer the CFSI eLearning Academy “Conflict Minerals” course for applicable Halliburton Supply Chain employees, including sending step-by-step instructions to walk our employees through the course information and access; and

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Continued to make our Ethics Helpline available for suppliers to report any violations of the law or violations of our Code of Business Conduct. The CFSI has also established a grievance mechanism which its members, stakeholders, and the public can utilize to raise concerns about the initiative, the audit program, protocols, SOR operations that fall in scope of the Conflict-Free Smelter Program (CFSP), audit quality and auditor competencies, minerals supply chains and upstream/downstream initiatives.

•	Identified direct suppliers that supply products to Halliburton which may contain 3TG, which were selected in good faith based on the following criteria:

◦	Products supplied to Halliburton plants within the Reporting Period;

◦	Harmonized Tariff Codes and Material Groups of supplied products that may contain metal;

◦	Product sales from Halliburton procurement plants to third party customers; and

◦	Halliburton newly acquired manufacturers with the reporting obligations pursuant to Rule 13p-1 under the Securities Exchange Act of 1934;

•	Conducted a survey using the CMRT and our third-party service provider’s supplier portal, which included a phone number and email address for suppliers and internal stakeholders to correspond;

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•	For distributors, created a product list so distributors could work with second-tier suppliers and asked distributors for a product-level CMRT, including directly interacting with second-tier suppliers requesting their responses;

•	Implemented deadlines for suppliers’ CMRT submissions, including requiring our direct suppliers to provide an updated CMRT if additional information becomes available;

•	Followed up with non-responsive suppliers requesting their responses, through phone calls and emails, including several escalation emails from both Halliburton and our third-party service provider and a second phone call campaign to high-spend suppliers;

•	Our third-party service provider reviewed suppliers’ CMRTs and their reported SORs list, identified any inconsistencies, and required suppliers to take corrective actions and update their submission as needed;

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Compared the SORs identified by the supply chain with the CFSI CFSP, or an equivalent third-party audit program such as the London Bullion Market Association (LBMA) and Responsible Jewelry Council (RJC), to validate suppliers’ submission, and forwarded the name of the alleged SOR to the CFSI if we have plausible evidence, after completing a due diligence process, that the SOR meets the CFSI definition of a smelter or refiner; and

•	As a member of the CFSI, we:

◦	support engagement by the CFSI with SOR(s) and the obtainment of information on country of origin and transit and transportation routes used between mine and SORs;

◦	support the CFSI CFSP, which includes an assessment of whether SORs have carried out all 5 steps of due diligence for responsible supply chains of 3TG from the DRC and adjoining countries; and

◦	support spot checks and/or audits at SOR facilities.

•	Adopted a risk management plan to review due diligence of suppliers and SORs;

•	Monitored and tracked direct suppliers and selected SORs that were identified as not meeting our requirements;

•	Performed risk mitigation efforts by following up with direct suppliers for validation and additional information, also encouraging all smelters without CFSP “Compliant” status to participate in an independent third-party audit program and sending thank you emails to smelters with CFSP “Compliant” status for their participation with CFSP;

•	Responded to supplier and customer inquiries in a timely manner by both Halliburton and our third-party service provider;

•	Provided findings and progress reports periodically to senior management, including the senior director of PM&L Performance Management and the senior manager of Risk Reporting & Management;

•	Each facility that meets the CFSI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on 3 scoring criteria: Geographic proximity to the DRC and covered countries; CFSP audit status; and known or plausible evidence of unethical or conflict sourcing;

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When high risk facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through our third-party vendor, submissions that include any of the high risk facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to Halliburton, and escalating up to removal of these high risk smelters from their supply chain.

◦	As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these risks from the supply chain.

◦	In addition, suppliers are guided to an online learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.

•	Attended webinars and reviewed articles to understand new developments and best practices; and

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•	As a member of the CFSI and through our financial support by joining, we:

◦	exercise leverage over upstream suppliers indirectly by requiring SORs to undergo an independent third-party audit, which requires due diligence, traceability, chain of custody, risk assessment, and mitigation activities upstream;

◦	support the CFSI’s efforts to monitor whether SOR(s) demonstrate significant and measurable improvement within a reasonable time frame from the adoption of their risk management plans; and

◦	support the CFSI’s independent third party audits of the SOR’s due diligence practices through the CFSP.

•	Supported CFSI efforts with our membership (Halliburton member code is HALL);

•	Reviewed meeting notes from the CFSI Smelter Engagement Team (SET) and Due Diligence Team; and

•	Thirty-nine companies, including Halliburton, have sent joint letters via email to notify 52 not “conflict-free” smelters stating the expectations of compliance with CFSI.

•	Report annually on supply chain due diligence by filing with the SEC a Form SD and Conflict Minerals Report; and

•	Report annually on our company website at

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•	243 SORs (79.15%) have received compliant status; meaning audited and found compliant with the relevant CFSP protocol;

◦	22 SORs identified to source 3TG from the DRC or adjoining countries. However, to the best of our knowledge, none of these SORs are known to source minerals that benefit armed groups in the DRC and adjoining countries.

•	16 SORs (5.21%) have received active status, meaning engaged in the program but not yet certified compliant; and

•	the remaining 48 SORs (15.64%) have not received compliant or active status. These will be noted as “Other” in Annex I.

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•	Researching the supplier selection methodology to increase the accuracy of supplier and material list;

•	Encouraging suppliers to evaluate the business relationship with the SORs that refuse to proceed with an independent third-party audit program;

•	Providing assistance and education for conflict minerals programs for suppliers so that the compliance requirements can escalate down to more tiers of our supply chain;

•	Encouraging eligible SORs’ identification from the suppliers; and

•	Directly contacting identified SORs without a CFSP “Compliant” status in our supply chain to participate in an independent third-party audit program.

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