Contingent Liability

Update on legacy

The Deferred Prosecution Agreement SBM Offshore signed with the United States Department of Justice on November 29, 2017 includes, among other things, an obligation to report on the status of the Company’s compliance program. The Company confirms that this three-year period has now ended, without extension or other conditions.

In Switzerland, three of the Company’s subsidiaries received a notification from the Bundesanwaltschaft (federal prosecutor’s office) in Bern. It concerns a suspicion that from 2005 till 2012 these subsidiaries failed to take the necessary measures to prevent the execution of corrupt payments during said period. The notification refers to the legacy settlements the Company concluded in the Netherlands (2014) and Brazil (2018) as well as the Deferred Prosecution Agreement with the United States. The suspicion regarding the compliance controls shortcoming relate to payments covered by these agreements.

There are no provisions or accrued liabilities accounted for as of December 31, 2020 related to the notification received from the Bundesanwaltschaft (federal prosecutor’s office) in Bern.