Doing What’s Right:
All the Time
Our Standard of Business
Conduct & Code of
Ethical Behavior.
Doing What’s Right: All The Time
From our founding in 1979, MBI Energy Services has been known not only for the
outstanding services we provide to our customers, but also for a commitment to
values that are timeless. In all things, we strive to:
Build Trust with Integrity
Earn & Sustain Market Share
Gain Results through Leadership
Focus Implicitly on Safety
A Letter from the Executive Team
Dear Friends & Colleagues:
We are quite pleased to formalize our Standards of Business Conduct & Code of Ethical Behavior. You are our trusted
partners in continuing to build the MBI brand. The brand represents us and we represent it. Our corporate brand and our
individual image should never be compromised or called into question. Integrity, for all of us, is the word of the day…each
and every day.
Demonstrating integrity in everything we do builds relationships of trust that ultimately establish bonds that endure. These
relationship bonds are the foundation for new and repeat business with our customers and for long-term careers at MBI.
As leaders, we hold ourselves accountable for upholding the highest standards of behavior. Likewise, we hold you, our
colleagues, accountable for performing and creating an environment of ethics. Such an environment extends far beyond
compliance with law. It encompasses timeless values such as:
Integrity
Responsible Citizenship
Commitment to Service
Respect
Passion for our Customers, and
Safety
“Doing What’s Right: All the Time” is our code of conduct. It provides an overview of how MBI employees, subcontractors,
consultants, and leaders conduct ourselves when we act as representatives of the company. In a certain sense, these
standards define who we are. Ultimately, however, MBI is defined by the collective actions of our great and growing team.
We have high expectations of you and for you. Doing what is right all the time is at the top of our list.
Respectfully,
Jim Arthaud, Tony Hauck and the MBI Executive Team
Who We Are
MBI is a leader in oil field services. We have established ourselves in this position by investing heavily in our customers, our services, and our
people. A significant part of this investment has been financial; however, underlying each and every financial investment is a commitment to
do things right. And to do things safely.
Our customers and our investors expect leadership. Our ongoing position of strength is dependent on excellent performance in everything
we do. This guide, entitled “Doing What’s Right: All the Time” highlights who we are and what we represent from a values perspective.
This document addresses simple and direct matters such as:
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Responding to investigations and legal matters
Our responsibilities as MBI employees
Citizenship
Corporate Sustainability
Reporting suspected violations
Respect for others
Accurate reporting
Proper use of company assets
Dealings with vendors and subcontractors
Maintaining records
Health, safety, the environment, and security
Please carefully review the contents that follow and feel free to address questions to your manager or to a manager on our Human Resources
team. For legal or deeper inquiries from an ethical perspective, you may contact Mr. Patrick (Pat) Weir, Esq., a corporate Vice President and
our Chief Counsel.
MBI Ethics Policy: Simply Stated
We are committed to:
institute the highest measures of conduct in all of our associations and dealings with our constituencies—employees, customers, partners,
communities, suppliers, and investors.
promote a work environment that is positive, where employees and others can ask questions, express work-related personal concerns about
ethics, make inquiries, or report suspected violations without fear of retaliation.
conduct our business with honesty and integrity.
comply with the laws and regulations of the United States and each individual state in which we operate.
communicate our standards of ethical conduct to our employees, agents, consultants, and others who represent or act for us, and will hold
them accountable for their conduct.
Violations of laws, regulations, policies, procedures, or this code may result in
disciplinary action, up to and including termination of employment.
My Responsibilities
Be a model of ethic conduct
Support others in sustaining excellent behavior
If someone approaches you with a question or concern:
• Thank the employee for coming forward
• Listen carefully
• Ask for clarification to fully understand the issue
• Answer questions you can
• You are not required to provide an immediate response
• Seek help if you need it before responding in detail
• Follow up as soon as possible
If the concern requires investigation, refer it to the appropriate resource.
Health, Safety, Environment
MBI Sets the Standards Necessary to:
• Protect our people
• Take action in mitigating hazards or threats to employee safety
• Comply with and seek to exceed all MBI health, safety, and environment
policies
• Support fully any investigations, root cause analyses, or other inquiries from
our customers or government agencies
• Use a thorough and objective investigative process and apply lessons learned
• Ensure that all areas in which we work are clean and environmentally safe
REMEMBER: Each and every MBI employee is authorized to stop work at any time to
ensure the safety of themselves and others.
Respect & Sustainability
MBI’s code of conduct includes treating others with respect at all times
and behaving in a way that promotes a long-term view.
Respect
• Encourage expression of opinion
• Prohibit harassment
• Never engage in any corrupt practice
• Place safety as the highest priority
Sustainability
• Protect the environment
• Deploy sound business practices and technologies
• Manage risk and opportunities
• Define accountability
Protection of Assets & Information
MBI Employees…
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Prevent waste and abuse of assets.
Are well versed in company policy.
Handle, store, and protect sensitive information appropriately.
Obtain proper authorization before receiving or disclosing sensitive
data.
Respect the dignity and privacy of others.
Use special precaution when using social media to protect your good
name, the MBI brand, and the excellent reputations of our customers.
Refer external inquiries for information to the marketing &
communications team.
Report unauthorized access of personal and/or proprietary information.
Conducting Business Ethically
Four Rules to Live By:
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Avoid any perception that favorable treatment is
sought, received or given
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Ensure that the offer or receipt of any gift or
business courtesy is permitted by law and
consistent with reasonable marketplace practices
and customs
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Verify that the rules of the recipient or donor’s
organization are not violated by a gift
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Never, under any circumstances offer, give, solicit
or receive anything that would compromise your
integrity or the integrity of MBI
Wrap up
“Doing What’s Right: All The Time”
• More than a simple slogan, it is the MBI way of doing business.
Our Company values are timeless
We all play an important role
There is no compromise on our ethics policy
Business conducts includes everything we do
Everything we do, we do safely
Acknowledgment & Resources
As an MBI employee, you must acknowledge that you have read and will abide by Doing
What’s Right: All the Time, the MBI Standard of Business Conduct and Code of Ethical
Behavior. You are also acknowledging that you understand that each MBI employee is
responsible for knowing and adhering to the principles and standards described.
If you have good reason to believe that a violation of laws, regulations, policies, procedures,
or the MBI Standard of Business Conduct has occurred, or, if you are asked to violate the
same, you should not remain silent. You are responsible for reporting the violation or
suspected violation, or any instances of significant employee misconduct, directly to your
supervisor, manager, Human Resources, Corporate Counsel, or other appropriate functional
organization. If your supervisor or manager is personally involved, report the violation to a
Human Resources Business Partner or Corporate Counsel. Depending on the circumstances,
failure to report a violation or a suspected violation may be a violation of the code.