Responsible Business

The Noble Code: Our foundation of ethics and integrity

Noble adheres to high standards for ethics and integrity, health and safety, environmental stewardship and respect around the world.

At Noble, being a responsible business means always doing what is right. We believe doing the right thing is good for our stakeholders and our business and enhances our ability to be the first choice offshore driller. In practice, Noble adheres to high standards for ethics and integrity, health and safety, environmental stewardship and respect around the world. 

We have a deep commitment to ethics and compliance founded on a duty to our employees, customers, vendors, stakeholders, society and the environment in all aspects of our business. The Noble Code explains our duty and our commitments to our people, our community and our world, why they matter and how we do what is right. Our Code is a living, active reference with instructions that guide us as individuals and as a company, providing a model for ethical decision-making to help us choose the right path.

The Code covers a wide variety of issues related to sustainability, health and safety, environmental responsibility and our relationships. Working in tandem with the Noble Code, our management system provides detailed guidance, through policies and procedures, for following our mission, vision and values.

Noble’s Chief Compliance Officer, who has direct access to the chairperson of the Audit Committee and reports to the full Audit Committee quarterly on our Code and ethics and compliance program.

“Noble carries our understanding of ethical business everywhere we go. We communicate our standards and provide training for employees, rig workers and intermediaries, and require 
them to meet our standards. 

Our customers have the same expectations of Noble and we meet their high ethical standards.”

— Emily Buchanan
Chief Compliance Officer

Expanding in-person training

The Noble Code applies to all employees, executives, officers and members of our Board of Directors, and is available online in ten languages. All third parties doing work for Noble must have their own code that encompasses our principles, or must adopt our Noble Code.

Employees take online training on the Code upon hiring and an online Code refresher at least once a year, while employees in onshore offices take in-person refreshers every other year. 

In 2024, our ethics and compliance team conducted in-person training at the majority of our offices and initiated in-person training on rigs. We are committed to 100% completion of online training and to providing in-person training at all offices and most rigs every two years.

Ethics and compliance training in 2024

93%

completion of online training

92%

completion of in-person training by target audience at shorebases and major offices globally

Conducted in-person training in 5 offices and on 3 rigs worldwide

Training in 2024 raised awareness of our process for reporting concerns and potential Code violations or illegal or unethical business conduct. Employees are obligated to report concerns and we provide multiple channels to fulfill this obligation. In addition to using our anonymous, confidential NobleLine resource, employees can contact the designated person ashore or a representative of human resources, ethics and compliance, legal, finance, internal audit or HSE. The Company pledges to receive reports anonymously, investigate reports and enforce the company’s non-retaliation policy for reports made in good faith.

We are committed to engaging employees on ethics and compliance through training, an app, a dedicated internal website and ongoing executive advocacy on our strong culture of ethics. We believe that following laws, complying with regulations and adhering to high global standards will help Noble be a sustainable enterprise.

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