Ethics and Compliance

Oceaneering is committed to its Core Values of Safety and the Environment, Customer Focus, Teamwork and People, Excellence, Ethics and Accountability.

Through these values, we have built our reputation as an organization that requires ethical business practices and high levels of integrity in all of our business transactions. Oceaneering’s Core Values underlie our Code of Business Conduct and Ethics and related policies and procedures (collectively, our   “Code of Conduct”), which guide our employees and business associates on a daily basis.

In addition, Oceaneering recognizes that the strength of its reputation is based not only on our own conduct, but also on the behavior of those with whom we do business. As such, it is our goal to ensure that our relationship with suppliers reflects and supports the same high ethical standards. We are committed to work with our partners to promote responsible practices in general and throughout our supply chain around the world. Our intent is to ensure that all our partners acknowledge our values and share our commitment to conduct business in an ethical, legal, and socially responsible manner.

We Want to Hear From You

If you have any compliance or ethics concerns regarding our Code of Business Conduct, accounting controls, auditing matters, or any other concerns, we want to hear from you. All concerns and complaints will be reported and assigned to appropriate parties for review. Ultimately, adherence to our Core Values and compliance with our Code of Business Conduct are overseen by Oceaneering’s Board of Directors and its committees.

Ways to Contact Us
  • U.S. toll free: +1 844.381.9324  
  • Local numbers and translation services are available in most countries via oceaneering.ethicspoint.com

Code of Conduct

Our Code of Business Conduct and Ethics, Anti-Corruption Compliance Policy, and Code of Ethics for the Chief Executive Officer and Senior Financial Officers reiterate Oceaneering’s commitment to integrity and ethical standards and clearly convey to all employees and related third parties how our Code of Conduct pertains to business relationships with us.
We are committed to work with our partners to promote responsible practices in general and throughout our supply chain around the world. Our intent is to ensure that all our employees and partners acknowledge our values and share our commitment to conduct business in an ethical, legal and socially responsible manner. We strive to continually improve within the areas of human rights, labor standards, and the environment and to work against any form of corruption.

Programs

Compliance Program

The Oceaneering Compliance Program has been designed in accordance with world-class best practices including:
  • the OECD’s 13 Good Practices on Internal Controls, Ethics, and Compliance;
  • the United States Sentencing Guidelines’ 7 Elements of an Effective Compliance Program;
  • the Department of Justice’s Resource Guide to the U.S. Foreign Corrupt Practices Act;
  • the United Kingdom Bribery Act 2010; and the
  • the Ministry of Justice’s Guidance on the United Kingdom Bribery Act.

Anti-Corruption Compliance Policy

Oceaneering has zero tolerance of corruption or bribery in any form. Oceaneering policy and laws such as the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, and similar anti-corruption laws around the world prohibit our employees or our agents from giving or offering to give money or anything of value, directly or indirectly, to anyone to induce that person to affect any governmental act or decision, or to assist Oceaneering in obtaining or retaining business or securing any improper advantage. This prohibition applies to all customers, whether government-owned or controlled or privately held, and to all government officials regardless of rank and duty.
Oceaneering suppliers may not act in any way, in their business relationship with Oceaneering or otherwise, that violates this principle. Additionally, Oceaneering suppliers must only themselves use suppliers that do not violate ethical standards through bribes, kickbacks, or other similar improper or unlawful payments. Suppliers must maintain awareness and comply with all applicable bribery and corruption laws and regulations of the countries of their operation.

Anti-Human Trafficking Program

Slavery and human trafficking is a serious concern. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Code of Conduct reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Conflicts Minerals Program

Oceaneering has adopted a policy of supporting industry efforts toward conflict-free supply chains and complying with related reporting requirements imposed on the company by applicable law. We expect our suppliers to support us in these endeavors.
Oceaneering suppliers should responsibly source materials used in their products and services. Suppliers must implement supply chain due diligence policies and take affirmative measures to determine if proceeds from the mining, trading, transportation, smelting or refining of any ores, minerals or derivatives are used to benefit or fund individuals or groups engaged in violence or human rights abuses. When suppliers become aware that these materials are in their supply chain, they must find alternative sources.

Tax Policy

Oceaneering responsibly complies with tax laws and aims at full transparency towards tax authorities. All taxes and charges are paid in accordance with relevant domestic laws and regulations in the countries where we operate. As a good corporate citizen, we believe that tax policy is an important part of building a strong global economy and infrastructure system that can benefit all stakeholders and the communities we share.

Gender Pay Gap Reporting

The Gender Pay Gap Reporting regulations cover UK companies with 250 or more employees as of 5 April 2017. As one such organisation, we are required to publicly report gender pay gap metrics, with the aim of eliminating the gender pay gap. In the Oceaneering group, Oceaneering International Services Limited (“OISL”) is required to publish its gender pay gap metrics. Pay gap calculations are based on the OISL workforce as of 5 April 2017.

Contact Us | Ethics and Compliance
Company page Since our founding in the early 1960s, Oceaneering has expanded and grown globally to service several industries such as the offshore energy industry, defense, entertainment, material handling, aerospace, science, and renewable energy industries. In 1964, Mike Hughes and Johnny Johnson formed a Gulf of Mexico diving company called World Wide Divers. The company grew in response to increasing demand for their services and in 1969 merged with two other diving companies to form Oceaneering International, Inc. To solve the toughest challenges, we do things differently, creatively, and smarter. As your trusted partner, our unmatched experience and truly innovative portfolio of technologies and solutions give us the flexibility to adapt and evolve, regardless of market conditions. Our mission is to solve the unsolvable. We thrive by creating industry-changing technically creative solutions for the most complex operational challenges under water, on land, and in space. Our five core values establish a common culture and demonstrate what is most important for us as a company. Since the beginning, the company has transformed from a small regional diving company into a global provider of engineered products and services. Today, we develop products and services for use throughout the lifecycle of an offshore oilfield, from drilling to decommissioning. We operate the world's premier fleet of work class ROVs. Additionally, we are a leader in offshore oilfield maintenance services, umbilicals, subsea hardware, and tooling. We also serve the aerospace, defense, and theme park industries. Underpinning everything we do, safety is not only the foundation of our core values, but it is vital to our unmatched performance record and company culture. The industries we serve are as diverse as they are complex. Whether we are engineering deepwater umbilicals or developing robotics for aerospace applications, the safety and health of our employees, vendors, and customers is an integral part of our day-to-day business. If we are working, then our responsibility is to be working safely. Since our inception in 1964, we have placed a high value on employee safety—from diving services and subsea inspection to vessel-based installation operations. We have and will continue to evolve not only our health, safety, and environmental (HSE) processes, but those of the industries in which we work. Although we have been fatality-free since 1999, our HSE journey goes beyond statistics. As our portfolio of services has grown, we have continued to prioritize and advance our approach to HSE.