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ITEM 16B. CODE OF ETHICS

Our Board has established a code of business conduct and ethics applicable to our Directors, officers and employees, and reviews this code on an annual basis. Any waiver of this code may be made only by our Board and is required to be promptly disclosed pursuant to applicable U.S. federal securities laws and the corporate governance rules of the NYSE.

See “Part III, Item 19. Exhibits—Exhibit 11.2” of this Annual Report on Form 20-F for a copy of our code of business conduct and ethics. Additionally, the code of business conduct and ethics is publicly available on our website at www.borrdrilling.com/about#corporate-responsibility.

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