Halliburton 2011 Annual Report Download - page 114

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99
In February 2011, the same shareholder who had made the demand on our board of directors in
connection with one of the derivative lawsuits discussed above filed a shareholder derivative lawsuit in
Harris County, Texas naming us as a nominal defendant and certain of our directors and officers as
defendants. This case alleges that these defendants, among other things, breached fiduciary duties of good
faith and loyalty by failing to properly exercise oversight responsibilities and establish adequate internal
controls, including controls and procedures related to cement testing and the communication of test results,
as they relate to the Macondo well incident. Our Board of Directors designated a special committee of
independent and disinterested directors to oversee the investigation of the allegations made in the lawsuit
and shareholder demand. Upon receipt of its special committee’ s findings and recommendations, the
independent and disinterested members of the Board determined that the shareholder claims were without
merit and not otherwise in the best interest of the company to pursue. The Board directed company counsel
to report its determinations to the plaintiffs and demanding shareholder. As of December 31, 2011, we had
not accrued any amounts related to this matter because we do not believe that a loss is probable. Further, an
estimate of possible loss or range of loss related to this matter cannot be made.
Angola Investigations
We are conducting an internal investigation of certain areas of our operations in Angola, focusing
on compliance with certain company policies, including our Code of Business Conduct (COBC), and the
FCPA and other applicable laws. In December 2010, we received an anonymous e-mail alleging that
certain current and former personnel violated our COBC and the FCPA, principally through the use of an
Angolan vendor. The e-mail also alleges conflicts of interest, self-dealing and the failure to act on alleged
violations of our COBC and the FCPA. We contacted the DOJ to advise them that we were initiating an
internal investigation with the assistance of outside counsel and independent forensic accountants.
During the third quarter of 2011, we met with the DOJ and the SEC to brief them on the status of
our investigation and provided them documents. We are currently responding to a subpoena from the SEC
regarding this matter and are producing all relevant documents. We understand that one of our employees
has also received a subpoena from the SEC regarding this matter.
We expect to continue to have discussions with the DOJ and the SEC, and we intend to continue
to cooperate with their inquiries and requests as they investigate this matter. Because these investigations
are at an early stage, we cannot predict their outcome or the consequences thereof.
Environmental
We are subject to numerous environmental, legal, and regulatory requirements related to our
operations worldwide. In the United States, these laws and regulations include, among others:
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the Comprehensive Environmental Response, Compensation, and Liability Act;
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the Resource Conservation and Recovery Act;
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the Clean Air Act;
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the Federal Water Pollution Control Act;
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the Toxic Substances Control Act; and
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the Oil Pollution Act of 1990.