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Conflict of Interest

The Company will not permit conflicts of interest on the part of its directors, and employees except under guidelines or procedures approved by the Board of Directors. A “conflict of interest” exists when:


• A Director or employee accepts or gives a gift or extravagant entertainment to / from someone soliciting business with the Company.

• The Company is committed to conducting its business with integrity and in compliance with all applicable laws. We require accountability for any exorbitant or abnormal business gifts, meals and entertainment, whether received or given by Company personnel.

• Receipt of any Payment, Abnormal Gift, Commissions & Loans Presidents, officers or employees are not to accept any payment, significant gift, commission or loan in any form from any competitor of the Company, Vendors, Suppliers, Customers and Buyers or from any person or firm having current or prospective dealings with the Company.

• An employee or consultant serves in a management or director capacity at another company in the contract drilling and energy services industry;

• If any officer, director / President or employee has the intention of working for, or is working for another Enterprise while in the employ of the Company, that has current or prospective dealings with, or competes with, the Company, the facts, including the amount of compensation received, or to be received, must be reported in writing.

• Investments in other Enterprises with which the Company Does Business or Competes

• Any officer, director / President and employee owning an investment in any enterprise that has current or prospective dealings with, or competes with, the Company shall report such interest to the President or Senior Officer of the Company.