The FMC Technologies Code of Business Conduct

Living our core values

FMC Technologies, Inc.

FMC Technologies, Inc. (NYSE: FTI) is the global market leader in subsea systems and a leading provider of technologies and services to the oil and gas industry. We help our customers overcome their most difficult challenges, such as improving shale and subsea infrastructures and operations to reduce cost, maintain uptime, and maximize oil and gas recovery. Named by Forbes® Magazine as one of the World’s Most Innovative Companies in 2013, the company has more than 20,000 employees and operates 24 production facilities in 14 countries.

Visit www.fmctechnologies.com or follow us on Twitter @FMC_Tech for more information.

Message from our Chairman and CEO ................... 4

Be the One ........................................................ 5

Your role ................................................................. 6

Expected behaviors ................................................ 8

Raising concerns .................................................... 9

Responding to concerns ...................................... 10

Integrity inside ..............................................11

Avoiding conflicts of interest – FMC Technologies first ....................................... 12

Valuing our people ................................................ 14

Fair employment practices ................................ 14

Safety ............................................................... 14

• HSE 12 Golden Rules ................................. 15

Privacy .............................................................. 15

Protecting company assets ................................... 16

Transparency in financial information .................. 17

Money laundering prevention ............................ 17

Insider trading and stock tipping ....................... 18

Intellectual property and confidential business information ............................................ 19

Social media .......................................................... 20

Integrity outside ...........................................21

Integrity with our customers and suppliers ..................................... 22

Avoiding improper payments ............................ 22

Giving and receiving gifts and entertainment ..... 24

Competing globally ........................................... 25

Quality – achieving customer success .................. 26

Contracts .......................................................... 26

Integrity with governments ................................. 27

Global trade restrictions ..................................... 27

Political activity .................................................. 28

Global immigration compliance ......................... 28

Integrity with others ............................................. 30

Promoting human rights ................................... 30

Environmental stewardship ............................... 30

Charitable contributions ..................................... 30

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Code of Business Conduct

Contents

FMC Technologies

04

Message from our Chairman and CEO

Our vision is clear – we will be the undisputed leader in our markets, recognized for setting technical and performance standards in all of our businesses and for enabling customer success.To help us achieve this vision, we created our core values to drive our actions and shape our culture. We have all come to FMC Technologies with different experiences and perspectives, and it is our core values that unify us as one company.We believe how we do business is as important as why we do business. We always act ethically, lawfully and in accordance with our values. It is vitally important that each member of our global team accept the responsibility to be the one to live these values. We live

our values through the decisions we make and the behaviors we exhibit.Our Code of Business Conduct will help us recognize situations that can lead to ethical challenges and help us address those issues in a way that is consistent with our core values. The Code describes expected behaviors and the behaviors to be avoided. It also tells how to get additional guidance when a situation just doesn’t feel right.This Code is intended to give you practical guidance so that you can live our core values no matter where you work, no matter what your role.

John T. GrempChairman and CEO

Be the One

05

Be the One

FMC Technologies

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Your role

To Be the One does not mean you are alone. Each of us plays a role in maintaining the company’s values, and together, we create the FMC Technologies culture.Our Code applies to each of us:• All directors, officers, and employees• All employees of our subsidiaries

and affiliates• Anyone who represents us or acts

on our behalf, including contract employees, suppliers, contractors, agents, sales agents, and distributors.

We are all expected to:• Live – Read and understand the

guidance provided in this Code of Business Conduct (our Code), our standards and policies, and to live it every day.

• Lead – Help other team members follow our Code through leading by example and providing training on the issues your business faces most often.

• Support – Create an environment that encourages other team members to raise ethical concerns early.

• Report – Report behaviors that may violate the guidelines set out in our Code, standards or our policies.

• Stop – Intervene, without hesitation, to stop any activity by others that is in conflict with our core values or our Code.

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Be the One

This Code of Business Conduct will help us recognize situations that can lead to ethical challenges and help us to address those issues in a way that is consistent with our core values.

Customer-Centered We create value by building close partnerships with our internal and

external customers to achieve mutual success.

Valuing People We have the best people, invest in their development and provide

opportunities for their growth. Our strength and success comes

from respecting people, embracing diversity, and valuing

different cultures.

IntegrityWe do what is right and we do what we say. We always act

ethically, lawfully and in accordance with our values.

InnovationWe believe the best is yet to be

invented. We encourage purposeful creativity and thoughtful risk taking to create value for all stakeholders.

Safety & Sustainability We protect the health and safety

of our people and promote the sustainability of the

environment and the communities where we operate.

Collaboration We promote an environment of open and sharing cooperation

within the company and with our suppliers and customers.

QualityWe embrace the Five Absolutes of

Quality™. Through strict conformance to requirements, a prevention mindset

and a zero-defect performance standard, we eliminate the price of nonconformance and create

customer success.

FMC Technologies core values

FMC Technologies

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Safety & Sustainability Expected Behaviors:• Take responsibility for

preventing injuries.• Follow all safe work

practices and policies.• Report and address all injuries

and unsafe working conditions.• Protect the safety and health

of all employees, visitors and communities where we operate.

• Operate efficiently to preserve natural resources.

• Commit to corporate responsibility and support our local communities.

CollaborationExpected Behaviors:• Proactively share

experiences and information within the company.

• Focus on common goals rather than individual achievements.

• Encourage interaction and teamwork guided by clear direction and structured feedback.

• Embrace and share best practices.

• Act as one global company.

InnovationExpected Behaviors:• Constantly look for better

ways of doing things.• Foster an environment

of innovation and seek breakthrough ideas and initiatives.

• Proactively share information, best practices and ideas throughout the company.

• Balance the pursuit of innovation against the value of standardization.

• Pursue creativity without fear of failure.

Valuing PeopleExpected Behaviors:• Provide equal opportunity and

fair treatment to all employees.• Maintain a great

work environment.• Foster a culture of workforce

diversity and value a multicultural approach.

• Take responsibility for improving existing skills and acquiring new skills and knowledge.

• Help others advance by providing tools and opportunities for professional development.

IntegrityExpected Behaviors:• Never compromise our

values for results.• Accept accountability for

your own actions and those of your team.

• Raise concerns without hesitation and address issues with no retaliation.

• Speak the truth and insist on an open and trusting environment.

• Lead consistently by actions, not just words.

Customer-CenteredExpected Behaviors:• Help internal and external

customers succeed by insisting on measurable requirements.

• Deliver only conforming products or services to our customers.

• Build alliances with customers and suppliers who share our values.

• Cultivate long-term relationships with our external customers and suppliers.

• Share performance metrics with customers to achieve mutual success.

• Live our values to build the FMC Technologies brand.

QualityExpected Behaviors:• Insist on clear requirements

and agree on them upfront.• Recognize and celebrate

individuals who demonstrate a prevention mindset.

• Develop, implement and maintain zero-defect capable processes.

• Understand the price of nonconformance and personally strive for zero defects in everything we do.

• Work to requirements and standard operating procedures; avoid waivers and workarounds.

Core values – our expected behaviors

Be the One

09

FMC Technologies’ Ethics Hotline can be reached in several ways:

• 877-488-8343, toll-free in the U.S.• 001-503-748-0519, collect outside the U.S.• www.ethicspoint.com

Our hotline is managed by a third party that can take reports in the following languages: English, French, German, Portuguese, Spanish and Mandarin.

FMC Technologies provides several ways to ask questions about our Code or report concerns or potential violations: • Your direct supervisor • Human Resources • Legal department• Ethics Hotline• Any officer.

We encourage employees and others to raise questions and concerns to ensure that we are living our core values. Retaliation against anyone who makes a good faith report of possible violations of our Code, standards or policies, or cooperates with an investigation, is strictly prohibited.

Raising concerns

Q: If I’m aware of a Code violation but I cannot provide any proof, should I still report it?

A: Yes. It is not your responsibility to investigate a Code violation before reporting it. We will handle the investigation process.

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Responding to concerns

We treat all reports of suspected violations of our Code confidentially and will share the information only with those who “need to know” to investigate and properly resolve the issue.

If you are asked to participate in an investigation, you must assist honestly and openly. When investigating concerns, FMC Technologies may access, review and disclose information processed or stored by the company’s equipment, devices or computers.

We will quickly investigate all reports and take necessary action, including disciplinary action, when appropriate.

Situations that can lead to disciplinary action include:• Violating the Code, our standards

or policies• Requesting others to violate

our Code, standards or policies• Failing to report a known or

suspected violation of our Code, standards or policies

• Failure to cooperate honestly and openly with an investigation of a possible violation of our Code, standards or policies

• Retaliating against anyone who makes a report of a possible violation of our Code, standards or policies

• Knowingly reporting a false allegation of possible violation of our Code, standards or policies.

Discipline can include loss of pay, change in role or responsibility, suspension, termination or reimbursement to the company for losses resulting from the violation.

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Integrity inside

Integrity inside

FMC Technologies

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When conducting company business, we each have a duty to put FMC Technologies’ interests before our own personal gain. A conflict of interest can arise when personal interests, activities or relationships interfere with our objectivity and loyalty to FMC Technologies.

The appearance of a conflict can be just as damaging to an employee and our company’s reputation as an actual conflict.

Some conflicts of interest are obvious, such as a kickback payment for awarding FMC Technologies business to a vendor. Other conflicts of interest may be less obvious, such as conducting business with a firm owned by a family member, even when that firm appears to be offering the best value.

Avoiding conflicts of interest – FMC Technologies first

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Integrity inside

It is best to avoid circumstances that can give rise to even the appearance of a conflict of interest. The examples below describe situations that could be viewed as a conflict of interest and should be avoided or disclosed.

To avoid conflicts:

• Disclose – to avoid later misunderstanding and to ensure transparency, you must disclose any situation that can be viewed as a potential conflict of interest to your supervisor or Human Resources.

• Seek approval – if you must be directly involved in a transaction for FMC Technologies with a family member or close friend (or other situation giving rise to the appearance of a conflict of interest), it may be necessary for you to seek approval before proceeding. Please contact the legal department which can assist you with obtaining any required approval. Executive officers and directors must seek approval of our Board of Directors (or its designated committee).

Outside employment

Financial interests

Personal relationships

Political relationships

• A close relative works for a supplier or customer.

• You conduct business on the side for your personal benefit (not for the company’s) with your company laptop.

• You are asked to serve on the board of a competitor, supplier or customer’s company.

• A close relative is an owner or investor in a privately- owned customer of FMC Technologies.

• You accept expensive event tickets or gifts from a supplier or customer.

• You learn about a business opportunity at work and decide to pursue it for yourself.

• You supervise or are supervised by a close relative or partner.

• You are considering hiring a close relative or partner as an employee or contractor.

• You have a relationship with a supplier that inappropriately influences your business decisions.

• You have a romantic relationship with a subordinate.

• You work on a political campaign during working hours.

• You express your political views in a setting where your audience may think you are speaking on behalf of FMC Technologies.

FMC Technologies

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We strive to hire the best people and provide opportunities for our employees to excel.

The strength of our company is our people and their diversity. FMC Technologies employs women and men of many nationalities and backgrounds, all working together to achieve common goals and objectives. We strive to hire the best people and provide opportunities for our employees to excel.

Fair employment practicesTo ensure the growth and development of our employees, you must:

• Base all employment decisions on job qualifications and merit

• Never discriminate based on race, color, gender, religion, national origin, age, disability, sexual orientation or veteran status

• Create a harassment-free work environment:

• Don’t threaten or intimidate • Never make unwanted

sexual advances • Don’t post or distribute photos,

jokes or messages that could be offensive or degrading.

SafetyWe accept our responsibility to protect the health and safety of our employees, their families, our contractors, visitors and the public.

Destination Zero is our commitment to safety and a focus on our common goal as a company: zero safety incidents, worldwide, every day. We expect all employees to behave using these three key safety behaviors:

• Prevent safety incidents by refusing to do work perceived to be dangerous to our personal health or safety

• Report situations that have the potential to harm an employee, partner, or someone in our community

• Intervene without hesitation, to stop a job or any unsafe behavior.

Any employee who believes a situation or activity is unsafe or puts anyone at risk has the obligation to intervene and stop the job. A job can resume only when a safe alternative is developed. FMC Technologies is committed to performing work safely or not at all.

As part of our commitment to Destination Zero, we should never perform our work while under the influence of alcohol or illegal drugs.

Valuing our people

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Integrity inside

HSE 12 Golden RulesAround-the-clock safety1. Mechanical lifting – No Touch PolicyAdhere to the ‘No Touch’ policy. Tag lines and/or push/pull sticks will be used to guide loads lifted by cranes, hoists, forklifts or other mechanical lifting equipment. Under no circumstances should a person guide or handle a suspended load with their hands.

2. Lift Truck OperationsOnly a certified and authorized person is allowed to operate a lift truck.

3. Lifting, Carrying and HandlingAlways follow your manual handling training, if in doubt, don’t try to move an object or load. Gloves are required for lifting, carrying and handling parts, tools and equipment. Gloves should not be worn when there is a risk of the glove being caught and pulled into rotating or moving equipment.

4. Working at HeightProtect yourself from a fall when working at height.

5. Working with High Pressure EquipmentOnly authorized and competent persons are allowed to conduct pressure testing. Always check for trapped pressure.

6. Energy IsolationIsolate hazardous energy prior to conducting work on any system. A lock, tag and try system shall be used to isolate energy.

7. Hot WorkAlways complete a hot work permit prior to using an open flame or spark-producing equipment outside the designated area. Remove combustibles and re-check the area frequently after the work is completed.

8. Confined Space EntryAlways complete an entry permit prior to working inside a confined space. Have an escape plan ready.

9. Environmental ConservationAlways dispose of environmental waste in approved containers.

10. Driving Motor VehiclesAlways wear a seatbelt when riding in a motor vehicle and never text or use a cell phone when the vehicle is in motion.

11. Working in High-Risk CountriesBefore travelling to a high-risk country, always assess the risks and be familiar with the FMC Technologies Crisis Plan.

12. Management of ChangeAll changes to equipment, procedures, personnel, systems, process, organization, product materials or substances cannot proceed without a formal HSE Management of Change assessment.

PrivacyAs part of our everyday work, many of us have access to personal information about other employees, customers or vendors. We must protect this information at all times.

• Collect only the information necessary to perform our work

• Save only required personal data• Transfer personal data

internationally in compliance with the privacy laws of the receiving and sending jurisdictions. Check with the legal department to ensure that you know the requirements.

Protecting company assets

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• Don’t store personal information on your company devices and don’t have an expectation that personal files stored on a company device are private

• Do not use the intranet • to access sites that could contain

security threats (malware or other malicious code)

• to view external content that could impact network performance

• to access external content that could be offensive, degrading or in violation of the law.

In our workday we use technology and tools provided to us by the company. It is our responsibility to use those tools and technology properly.

• Secure tools, technology and inventory to prevent loss (including loss of information through cyber-attack)

• Account for tools, technology and inventory regularly

• Use only properly licensed software • Do not use company assets for

personal gain (although incidental personal use of computers and cell phones is permitted as long as the use does not interfere with job duties)

Transparency in financial information

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Integrity inside

Money laundering preventionAs part of ensuring that our financial records are accurate, complete and transparent, it is also necessary for us to exercise appropriate diligence on suppliers and other vendors to prevent money laundering. Money laundering is when someone involved in criminal activities (terrorism, narcotics, bribery or fraud) “launders” the proceeds of their crimes to prevent detection and appear legitimate. Appropriate due diligence also prevents “reverse money laundering” where legitimate funds may be used (knowingly or unknowingly) to finance terrorist activities.

To protect FMC Technologies from these risks, you should:

• Conduct appropriate due diligence on all suppliers, consultants or agents

• Ensure that all payments to suppliers, consultants or agents are made in accordance with our financial standards, including the requirement that payment be made in the country in which the work was performed

• Ask questions if an agent or consultant proposes a transaction structure that seems unusually complex.

We all have a role to play in ensuring the accuracy and completeness of our financial information.

• Ensure all transactions are properly authorized and recorded accurately and in a timely manner

• Make accounting decisions based on FMC Technologies financial standards and recognized accounting standards

• Submit and approve only valid business expenses for reimbursement

• Assist with all reviews, including internal and external audits, to ensure transactions are fairly and accurately recorded, and to detect inappropriate transactions.

Not only is accurate information critical for making responsible business decisions, but inaccurate financial information could mislead investors and damage the company’s reputation.

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• Keep all material, non-public information about FMC Technologies confidential

• Treat all material, non-public information about our customers and suppliers with the same degree of confidentiality you would give FMC Technologies’ information

• Do not conduct stock transactions based on material, non-public information

• Do not pass along material, non-public information to others

• Respect all “blackout notices.” To reduce the risk of insider trading, you may receive a notice that you cannot buy or sell FMC Technologies stock during certain blackout periods. If you are provided a notice, do not make any FMC Technologies’ stock transactions until you have been advised that the blackout period has been lifted

• Do not write options on FMC Technologies’ securities.

Insider trading and stock tipping

Sometimes, in the course of our work, we will learn information about FMC Technologies, our customers or our suppliers that has not yet been made public. If we were to make stock transactions based on this information before it is disclosed to all investors, we would have an unfair advantage.

Using material, non-public information for your personal benefit (including stock market transactions) is called “insider trading.” Passing material, non-public information along to others, even family members, so that they may use the information for personal gain is called “stock tipping.” These practices erode investor confidence and are violations of our core values, this Code and the law.

This can be a very difficult area to navigate, so please contact the legal department with any questions.

Tip: Information is considered “material” if a reasonable investor would consider that information important in making a decision to buy, hold or sell stocks. Examples of material information are projections of future earnings, loss of a significant project, or other sensitive business plans or strategies. Any information that could be expected to affect FMC Technologies’ stock price, whether it is positive or negative, should be considered “material,” and not be shared with anyone.

Intellectual property and confidential business information

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Integrity inside

Tip: Trade secrets can include customer lists, marketing and sales plans, engineering designs and technical information.

• Execute timely all patent disclosures, applications and assignment documents required to protect our intellectual property

• Not disclose an innovation that we have decided to protect as a trade secret

• Collaborate with caution. Our core values encourage us to collaborate within our company. However, sharing information about our technology developments and innovations with others, even our customers, can erode our ability to protect those innovations. This can be true, even if we have entered into a non-disclosure agreement. Before embarking on any detailed discussions with other parties about joint technology developments or other collaborations, make sure you have the approval of your manager or supervisor and you have discussed the project with the legal department

• Remember your confidentiality obligations continue after you leave FMC Technologies.

Our history of innovation is one of our biggest competitive advantages. This innovation is the result of our technology, our ideas, our techniques and our processes – these are called FMC Technologies’ intellectual property or confidential information. Every employee must protect this information and be very careful not to unintentionally or improperly share our intellectual property. We all must take the same care with our customers’ and suppliers’ intellectual property as we would with our own.

To ensure the protection of our intellectual property, you should:

• Respect the patent rights of other parties when designing our products and services

• Protect confidential information entrusted to us by our customers or suppliers with the same care as FMC Technologies’ confidential information

• Follow our processes for identifying, capturing and publishing information about our technical innovations. Disclosing new ideas too soon could jeopardize our ability to obtain patent protection for our innovations

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Social media

Social media has changed the way we communicate, work and live. FMC Technologies respects the right of employees to use social media as a medium of self-expression; however, what we as individuals publish to online sites should remain our personal views.

Our personal views should never be attributed to FMC Technologies and should not appear to come from or be supported by the company. Only certain employees are authorized to use social media to speak on behalf of FMC Technologies.

In addition, only certain employees are authorized to access social media while using FMC Technologies’ assets. For those who have access to social media while at work, we must ensure that the purpose and the time spent on social media is in the best interest of the company.

We should also be careful about our social networking participation during our personal time because our conduct, even while off-duty, can reflect on and impact the company’s reputation. We all must make sure that our use of social media or social networking does not disclose the company’s confidential information or discuss internal information.

The FMC Technologies way The wrong way

• Make it clear that any opinions expressed via social media are your own, unless specifically authorized by FMC Technologies• Communicate in a professional, respectful manner.

• Using social media in a way that is harmful to FMC Technologies, its employees, customers, business partners, suppliers, competitors or other stakeholders• Using social media to discuss FMC Technologies’ business without prior authorization.

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Integrity outside

Integrity outside

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We have earned the trust of our customers, business partners and suppliers by building close partnerships that achieve mutual success. By living our core values and working under the Code, we protect and grow that trust and further strengthen our relationships.

Avoiding improper payments

FMC Technologies competes fairly on the strength of its technology, service and execution excellence. The company does not make or accept improper payments to obtain or retain business with those in government or the private sector or as a reward for awarding supplier contracts.

Certain reasonable and limited expenditures for gifts, business entertainment and customer travel may be appropriate to build and maintain customer and supplier relationships and, in some instances, to fulfill our contractual obligations. Care should be taken to ensure that expenditures are reasonable and cannot be confused with improper payments, which can include bribes and kickbacks.

Ask your supervisor, controller or the legal department if you are ever unsure about an expenditure.

Tip: Providing anything of “value” can create the appearance of impropriety.

This can include money, goods or services provided to an individual or any of their family members.

Examples of value can include:

• A summer job for the daughter of someone who works for a supplier

• A scholarship to a family member of someone who works for a customer

• A donation to a charity run by the spouse of someone who works for a customer.

Integrity with customers and suppliers

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Integrity outside

Q: Who is a “government official?”

A: A government official can be someone in any branch of government (or anyone exercising governmental powers), political candidates or parties, officers or employees of any corporation owned or controlled by the government including state-owned oil companies. For FMC Technologies, this means that the employees of our national oil company customers are considered government officials.

The following “do’s and don’ts” will help you navigate between appropriate business expenditures and improper payments.

Do ensure records of expenditures properly reflect the nature of the transaction.

Do select business entertainment venues and activities that reflect our core values.

Do conduct appropriate due diligence on any consultant, supplier, business partner or agent that will interact on our behalf with government officials to ensure:

• There is no family or personal relationship between the business partner and the official that could create the appearance of a conflict of interest

• The party has a reputation for integrity • The party understands our core

values and our Code and agrees to abide by them

• The party is not affiliated with a state sponsor of terrorism or other specially-designated national (see Global Trade Restrictions on page 27)

• The fee is reasonable and customary.

Do pay all consultants, agents, suppliers, and business partners in the country where they performed work or sold goods.

Don’t give (or receive) anything of value:

• That violates local law or the customer’s own rules and business guidelines

• That creates the appearance of impropriety

• To gain or retain an improper advantage

• Above a nominal value ($150 USD)without prior approval

• With such frequency that, although of minimal value individually, can create the appearance of impropriety when aggregated

• For gifts, entertainment and customer travel for government officials without prior approval

• As a facilitation payment (a payment to expedite routine and administrative government action) except in extraordinary circumstances where the safety or security of an employee is in immediate threat

• In cash.

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Giving and receiving gifts and entertainment

*if multiple gifts, use the aggregate annual value

You may not give or accept

the gift or entertainment

Unless prohibited by law, you may give or accept

the gift or entertainment

You must obtain approval of VP,

GC, COO/President and CFO prior to giving the gift or entertainment

You must obtain VP and one additional

officer approval prior

to giving or accepting the gift or

entertainment

Could the giving or receiving of the

gift or entertainment appear to create

an actual or perceived conflict of interest?

Yes No

NoYesIs the gift or

entertainment worth less

than $150 USD?*

Yes NoIs it more than $5,000 USD?*

You must obtain VP

approval prior to giving or accepting the gift or

entertainment

Is the gift or entertainment

for a government official?

Yes No

• This chart provides appropriate guidance on giving and receiving gifts and entertainment.

VP: Vice President

GC: General Counsel

COO: Chief Operating Officer

CFO: Chief Financial Officer

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Integrity outside

Competing globallyWe are committed to competing fairly and in compliance with all applicable competition laws. Competition and anti-trust laws seek to protect markets by fostering fair and robust competition. Specifically, these laws seek to prevent collusion among competitors and to prevent companies with dominant market position from abusing their market power.

It is necessary to have meetings with our competitors from time to time. However, extreme care should be taken to define the purpose and scope of these discussions upfront.

To protect FMC Technologies from any competition law risk, you should never enter into any written or oral agreement with a competitor to:

• Allocate territories, customers, projects or market segments

• Share information on: • Prices • Capacity • Bids • Product or services • Features offered • Margins • Discounts• Prohibit work with specific

suppliers or customers.

Q: A customer contact has just sent me a competitor’s bid packet by mistake. What do I do?

A: Do not use the information and immediately turn it over to the legal department. The legal department will return it to our competitor and provide assurance that all copies, including electronic copies on email servers, have been destroyed.

Tip: Take extra care when attending trade shows or trade association meetings where you are likely to interact with competitors.

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Our priority is to provide products and services of outstanding quality at all times.

Our priority is to provide products and services of outstanding quality at all times. The FMC Technologies approach to quality demands the clear and agreed definition of all requirements before undertaking every task. We evaluate our process against the performance standard of zero defects. Our ultimate goal is our customers’ success.

Contracts To thoroughly define our customers’ requirements, FMC Technologies will only perform services or provide products or systems with an executed, written agreement or contract. All contracts must be reviewed and approved as provided in our financial standards.

Quality – achieving customer success

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Integrity outside

Global trade restrictionsFMC Technologies provides products and services to companies around the world. Most of these countries have customs laws and foreign policy-based trade controls, including economic sanctions and embargoes, governing the import or export of the products or services we offer. Some countries have laws requiring the boycott of other countries, while others have laws prohibiting the participation in boycotts.

Trade regulations can target countries, business sectors within countries, or individuals or organizations who are sometimes referred to as state-sponsors of terrorism or specially-designated nationals.

We must strictly comply with all customs laws and trade controls that apply to us, wherever we do business.

To give FMC Technologies greater ability to manage the movement of goods and provision of services in a compliant manner, you should:

• Use only approved customs agents and freight forwarders

• Provide complete and accurate information about final destination, end user and end use for all shipments.

• Provide a complete and accurate listing for all items included in a shipment.

• Check with the legal department before transferring technology (engineering drawings, source code, etc.) from one country to another.

• Ensure that temporary imports are properly managed in accordance with import license or customs documents.

• Remember that carrying equipment or spare parts in your luggage (known as “hand carry”) is subject to the same trade restrictions and customs clearance obligations as any other shipment to that country.

• Notify the legal department of any requests to participate in boycotts.

Tip: Because of the diversity of our workforce, we must be aware of “deemed exports” and treat them in the same manner as a physical export.

A “deemed export” is when a discussion about technology with a citizen of a country subject to trade restrictions is viewed as an export of the technology to that restricted country.

Integrity with governments

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Political activityFMC Technologies encourages employees to participate in the political process. We must make it clear, however, that any political activity reflects our individual beliefs and not those of FMC Technologies. No political contributions should be made on behalf of the company without the prior approval of your manager and the legal department.

Global immigration complianceWe do not hire or recruit anyone not legally authorized to work in the country in which employment is sought. We are committed to making sure the employment, travel, transfer, and residence of employees conforms to applicable immigration and employment laws. Each of us is accountable for maintaining our immigration status in compliance with the laws of the countries in which we work.

Each of us is accountable for maintaining our immigration status in compliance with the laws of the countries in which we work.

Integrity outside

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Integrity with others

Promoting human rights We are committed to recognizing human rights on a global basis. We do not tolerate the use of child, forced, indentured or involuntary labor, regardless of where we conduct business. We will not work with suppliers who source minerals from conflict zones. We will only do business with others that adhere to human rights and uphold labor laws.

Environmental stewardshipWe are committed to operating our business in a way that protects the environment and promotes the sustainable use of natural resources.

Charitable contributionsWe are required to carefully evaluate and document all charitable donations or other contributions made on behalf of the company. We must take special care with donations to charities made at the request of government officials or to charities in which a government official may serve in an executive or board capacity.

HeadquartersFMC Technologies, Inc.5875 N. Sam Houston Pkwy. W. Houston, TX 77086, United States

J +1 281 591 4000 +1 281 591 4102 www.fmctechnologies.com

All images property of FMC Technologies unless otherwise stated.

The paper used to print the Code of Business Conduct is FSC® (Forest Stewardship Council™) certified and is Lacey Act Compliant.

© 2015 FMC Technologies, Inc. All rights reserved.

FMC Technologies’ Ethics Hotline J 877 488 8343, toll-free in the U.S. 001 503 748 0519, collect outside the U.S. www.ethicspoint.com