EXHIBIT 14










                            CODE OF BUSINESS CONDUCT



                             NABORS INDUSTRIES LTD.
                              AND ITS SUBSIDIARIES




                                    MAY 2003


                                    FOREWORD

Nabors prides itself in being the industry leader in all aspects of its
business. Leadership includes maintaining high moral, ethical and legal
standards in all relationships and transactions in which the Company engages. To
reaffirm these principles, the Board of Directors has adopted the following Code
of Business Conduct, which applies to all directors, officers and employees of
the Company and its subsidiaries.

The guidelines contained in the Code are of necessity broad. Furthermore, the
laws and regulations applicable to many of the matters addressed in the Code are
complex and subject to change. Questions about the Code's application to
specific circumstances should be directed to an employee's supervisor, Human
Resources Department or the Law Department. When in doubt about an ethics
question, ask before you act.

Whether you are a new employee or one who has been with the Company for some
time, I urge you to familiarize yourself with the Code of Business Conduct.
Employees will be required to certify compliance with the Code on an annual
basis. More importantly, employees are expected to conform to the principles of
honesty and integrity embodied in the Code every day and in every way.

/s/ Eugene M. Isenberg
----------------------
Eugene M. Isenberg
Chairman & Chief Executive Officer

                                TABLE OF CONTENTS

INTRODUCTION                                                            1

FINANCIAL INTEGRITY                                                     1

CONFLICTS OF INTEREST                                                   3

COMPLIANCE WITH LAWS, RULES & REGULATIONS
   Fair Competition                                                     4
   Insider Trading                                                      5
   Health, Safety & Environment                                         5
   Fair Employment Practices                                            5
   Political Activities                                                 6

INTERNATIONAL BUSINESS
   Working with Governments                                             7
   Improper Payments                                                    7
   Export Controls/U.S. Embargos/Trade Sanctions                        8

INTELLECTUAL PROPERTY AND CONFIDENTIAL INFORMATION                      9

COMPLIANCE AND REPORTING
   Employee Responsibilities                                           10
   Management Responsibilities                                         11
   Expressing Your Personal Commitment                                 11


THIS CODE OF BUSINESS CONDUCT AND THE POLICIES DESCRIBED IN IT DO NOT ALTER THE
AT-WILL NATURE OF ANY EMPLOYMENT RELATIONSHIP AND DO NOT CREATE ANY CONTRACTUAL
RIGHTS OR ENLARGE ANY LEGAL RIGHTS OF ANY EMPLOYEE OR THIRD PARTY.

                                  INTRODUCTION

This Code of Business Conduct ("Code") embodies the commitment of Nabors
Industries Ltd. and its subsidiaries ("Nabors" or the "Company") to conduct our
business in accordance with applicable laws and high ethical standards. All
employees and directors of Nabors throughout the world are expected to adhere to
the principles described in this Code. We also expect consultants and agents we
retain generally to abide by this Code.

The Code should be read in conjunction with the safety, human resource,
accounting, legal and other policies (collectively, "Policies") applicable to an
employee, which Policies are not part of this Code.

                               FINANCIAL INTEGRITY

The Company expects candor from employees at all levels and full compliance with
Nabors' accounting Policies and controls. Our Board of Directors and senior
management do care how results are obtained, not just that they are obtained.
The Company will not tolerate employees who achieve results at the cost of
violation of laws or who deal unscrupulously.

Nabors' shareholders, creditors, management, governmental entities, and your
co-workers each rely upon the accuracy and transparency of the Company's
accounting records. It is imperative that the accounting records and reports
produced from them accurately and fairly reflect the assets, liabilities,
expenses and revenues of the Company in accordance with applicable laws and
accounting standards.

Accurate documentation in reasonable detail must support all transactions. False
or misleading accounting records, transactions, books and reports (including
expense reports and time sheets) are strictly prohibited. Misclassification of
transactions as to accounts, business units, or accounting periods is forbidden.
Each employee bears responsibility for ensuring that they are not party to a
false or misleading accounting entry.

All payments by the Company for goods or services should be described accurately
and fairly in the Company's financial records, should be supported by
contemporaneous documentation, and must be made only for the purposes described
in the documents and records supporting the payment.

Maintaining secret or unrecorded Company funds or bank accounts is strictly
prohibited. All cash received by the Company shall be promptly recorded in the
Company's financial records and deposited in an account maintained with a bank
or other financial institution approved by Nabors' Treasurer.

Employees participating in an accounting function should familiarize themselves
with and follow Nabors' General Accounting Procedures (GAP), as well as all
generally accepted accounting principles (GAAP), standards, laws and regulations
for accounting and financial reporting of transactions, estimates and forecasts.
Accruals shown in the Company's accounting records (e.g., allowance for
uncollectible receivables, prepaid expenses, and accrued expenses) shall be
supported by appropriate documentation and based upon good faith estimates as
required by GAP and GAAP.

                                       1

Employees should give complete and accurate information in response to any
inquiry from Nabors' internal auditors and outside independent auditors, as well
as the Company's legal counsel.

THINGS TO WATCH OUT FOR

o   Failure to obtain appropriate approvals for capital expenditures;

o   Financial results that seem inconsistent with underlying performance;

o   Inaccurate financial records, such as overstated expense reports, or
    erroneous time sheets or invoices;

o   Transactions that are inconsistent with good business economics;

o   Absence of controls to protect assets from risk of loss;

o   Circumventing review and approval procedures;

o   Adequacy of routines and controls at newly acquired businesses and at
    remote, thinly staffed sites;

o   Requests not to disclose information to accounting or management personnel;

o   Unreasonable delays in recording transactions.

                                       2

                              CONFLICTS OF INTEREST

Nabors recognizes and respects that employees may take part in legitimate
financial, business and other activities outside their jobs. However, those
activities must be lawful and free of conflicts with their responsibilities as
Nabors employees. Unless specific other arrangements are made, all employees are
expected to work a full-time schedule. To avoid any actual or perceived conflict
of interest, employees should inform their supervisor of any outside employment,
directorship, or business involvement that might reasonably be perceived as
creating a conflict now or in the future.

Conflicts of interest are prohibited as a matter of policy, unless proper
approvals have been obtained. In particular, employees must not exploit their
position with or relationships developed through Nabors for personal gain.
Accordingly, you should not accept gifts, gratuities or anything else of value
from a third party, except as permitted under Company Policies. Misuse of
Nabors' equipment or resources, intellectual property, confidential information,
time or facilities (including office equipment, e-mail, and computer
applications) can also constitute an impermissible conflict of interest.

THINGS TO WATCH OUT FOR

o   Taking a part-time job where you may be tempted to spend time on that job
    during your normal Nabors working hours or to use Nabors equipment or
    materials;

o   Receiving gifts of greater than nominal value from suppliers, customers or
    competitors while you are in a position to influence Nabors decisions that
    might affect or appear to affect the outside concern;

o   Receiving personal discounts or other benefits from suppliers, service
    providers or customers not available to the general public or similarly
    situated Nabors employees.

o   Directing business to a supplier that is owned or managed by a relative or
    close friend;

o   Misusing Nabors resources, your position or influence to promote or assist
    an outside business;

o   Preferential hiring of, direct supervision of, or making a promotion
    decision about a spouse, relative or close personal friend;

o   A romantic or other personal relationship that may create a conflict of
    interest;

o   Owning a significant interest in a supplier, competitor or customer.

For a related-party transaction involving an officer or director of the Company,
prior written approval of the Audit Committee is required. For a related-party
transaction involving any other employee, prior written approval of the
President or Chief Executive Officer of the Company is required.

                                       3

                  COMPLIANCE WITH LAWS, RULES & REGULATIONS

It is Nabors' policy to comply with all applicable laws, rules and regulations.
It is the personal responsibility of each employee and director to adhere to the
standards and restrictions imposed by those laws, rules, and regulations.
Following is a brief summary of certain topics about which employees should be
aware. More detailed descriptions of these laws and Nabors' compliance
requirements can be found in Nabors' Policies.

FAIR COMPETITION

The United States and many other countries regulate and in certain cases
prohibit certain types of anticompetitive behavior. Representation agreements,
patent, copyright and trademark licenses, territorial restrictions on resellers,
rebates, and discounts to customers are several of the subjects which may be
covered by the competition laws of many countries.

Nabors is dedicated to compliance with laws governing fair competition in all of
its activities. Any activity that undermines this commitment is unacceptable.
Accordingly, all purchases and sales must be predicated strictly on
considerations of efficiency, price, quality, service and suitability.

THINGS TO WATCH OUT FOR

The laws governing this area are complex, and employees should seek counsel
whenever appropriate.

Following are some guidelines for certain sensitive areas:

    o   Do not discuss, communicate (including at industry meetings or in
        surveys), propose or enter into any agreements or understandings --
        express or implied, formal or informal, written or oral -- with any
        competitor regarding:

        o   prices;

        o   terms or conditions of sale;

        o   wages, compensation or benefits information;

        o   costs, profits or profit margins;

        o   product or service offerings;

        o   production or sales capacity or volume;

        o   market share;

        o   coordination of bidding activities;

        o   dividing sales territories or allocation of customers or product
            lines;

    o   Consult with the Law Department early in the process of evaluating any
        proposed merger, acquisition, or joint venture;

    o   Consult with the Law Department in connection with business arrangements
        that could raise antitrust issues, including exclusive arrangements for
        the purchase or sale of products or services and bundling of goods and
        services;

                                       4

INSIDER TRADING

Generally, it is both illegal and against Nabors' policy for any employee or
director who is aware of material nonpublic information relating to the Company
to buy or sell any securities of the Company or recommend that another person
buy, sell, or hold the securities of the Company.

More detailed rules governing the trading of Company securities by employees is
contained in the Policies. Any employee who is uncertain about the legal rules
governing his or her purchase or sale of Company securities (including the
exercise of employee stock options) should consult with Nabors' Corporate
Secretary or Nabors' Law Department before making any such purchase or sale.

HEALTH, SAFETY & ENVIRONMENT

Nabors is committed to health, safety and environmental (HSE) excellence.
Compliance with all applicable laws, rules and regulations governing health,
safety and the environment is a responsibility of management and employees in
all functions.

Continuous improvement in its HSE programs is a core business strategy of
Nabors. No deviations from Company safety practices and procedures are permitted
without the approval of appropriate Company personnel or governmental regulatory
agency. Disposal of waste in violation of applicable laws, regulations, or
Company Policies, as well as the concealment, destruction, or falsification of
records, is strictly forbidden.

Each business unit has issued its own HSE Policies. Employees are expected to
strictly comply with these Policies, and supervisors are expected to strictly
enforce these Policies.

THINGS TO WATCH OUT FOR

o   Unsafe activities and conditions, such as failure to use prescribed personal
    protective equipment or unjustified departures from applicable HSE policies;

o   Failure to comply with health, safety or environmental regulations and
    procedures;

o   HSE complaints from employees, customers or others;

o   Deficiencies noted by government inspectors;

o   Unreported health, safety or environmental hazards or accidents;

o   Concerns about possible product safety issues;

o   Possession, use, purchase, or sale of alcohol or illegal drugs, or persons
    under the influence of alcohol or illegal drugs on Company premises or while
    performing work for the Company outside Company premises.

FAIR EMPLOYMENT PRACTICES

Nabors is committed to provide equal employment opportunity and to follow
applicable labor and employment laws wherever it operates, including the
prohibition against all forms of illegal discrimination. This includes observing
those laws that pertain to freedom of association, privacy, recognition of the
right to engage in collective bargaining, and those laws that pertain to the
elimination of any improper employment discrimination or harassment. By
providing equal access and fair treatment to all employees on the basis of
merit, we improve Nabors' success

                                       5

while enhancing the progress of individuals and the communities where our
businesses are located.

THINGS TO WATCH OUT FOR

o   Harassment of an individual or group of individuals in the workplace (for
    example, telling offensive jokes or displaying materials that ridicule or
    offend a member of a particular race, gender, or ethnic group);

o   Allowing race, color, religion, national origin, gender, age, disability,
    veteran status or other characteristic protected by applicable law to be a
    factor in hiring, firing, promotion, compensation, or other
    employment-related decisions;

o   Making unwelcome sexual advances;

o   Violating a labor law in the country of operation;

o   Refusing to work, or otherwise cooperate with, certain individuals because
    of their race, religion, sex, or other protected status;

o   Terminating an employee without following appropriate procedures;

o   Disclosing employment, personal or medical data to a person who does not
    have the business need, authority or the subject's consent;

o   Intimidating or discriminating against employees for engaging in collective
    bargaining activities.

POLITICAL ACTIVITIES

Nabors does not make contributions to political candidates or political parties
except as permitted by applicable law.

Employees engaging in political activity will do so as private citizens and not
as representatives of Nabors. An employee's personal lawful political
contribution, or decision not to make contributions, will not influence the
employee's compensation, job security, or opportunities for advancement.

                                       6

                             INTERNATIONAL BUSINESS

WORKING WITH GOVERNMENTS

Nabors conducts business with many national governments (including
government-owned enterprises). Nabors also interacts with many government
agencies, ministries, officials, and public international agencies. Nabors is
committed to conducting its business with all governmental representatives with
high ethical standards and in compliance with applicable laws and regulations,
including U.S. laws that have application outside of U.S. territories, and
special requirements associated with government transactions.

THINGS TO WATCH OUT FOR

o   Violating applicable laws or regulations that establish gratuity
    restrictions, entertainment rules, recruiting prohibitions or certification
    procedures;

o   Acceptance of information related to the government's competitive selection
    of a supplier, or a competitor's bid, unless the appropriate representative
    has specifically and lawfully authorized release of such information.

IMPROPER PAYMENTS

Bribery of public and private officials in the conduct of Nabors' business in
the United States and abroad is strictly prohibited. Employees should not,
directly or indirectly, offer anything of value to a government official,
government employee or customer for the purpose of influencing any act or
decision of the official or employee in their official capacity or inducing such
person to do or omit to do any act in violation of their lawful or ethical duty.
Nabors policy in this regard extends to payments to consultants, agents or other
intermediaries when a Nabors employee knows or has reason to believe that some
part of a payment will be used to bribe or otherwise influence a public official
or customer.

Violations of this policy can result in severe civil and criminal penalties. If
you are confronted with a demand for a bribe from anyone, you should report it
to your supervisor and the Law Department. More detailed rules governing
improper payments can be found in the Policies.

THINGS TO WATCH OUT FOR

o   Anyone representing or being considered to represent Nabors who has been
    accused of improper business practices; has influence on the buying decision
    and a reputation for bribes; has a family or other relationship that could
    improperly influence the decision of a customer or government official;
    approaches you near an award decision and explains that he or she has a
    "special arrangement" with a government official or the customer; or insists
    on receiving a commission payment before the announcement of the award
    decision;

o   Any request that a commission or other payment be made in a third country or
    to another name;

o   A commission that seems large in relation to the services provided.

                                       7

EXPORT CONTROLS/U.S. EMBARGOS/TRADE SANCTIONS

Many countries regulate international trade transactions, such as imports,
exports and international financial transactions, for a variety of reasons,
including national security and foreign policy. In addition, the United States
prohibits any cooperation with trade boycotts against countries friendly to the
United States or against firms which may be "blacklisted" by certain groups or
countries.

You should follow relevant international trade control regulations, including
licensing, shipping documentation, import documentation, reporting and records
retention requirements of all countries in which you conduct business. In some
cases, these restrictions will apply to international trade in goods,
technology, software, and services as well as to financial transactions.

All information furnished in connection with exports must be accurate and
truthful, including information relating to the value of the exports and the
ultimate destination or use of the exported items. This applies regardless of
whether the information is given to a governmental authority, a co-worker, or a
third party assisting the Company in facilitating the export.

From time to time, the United States prohibits or restricts trade and other
commercial dealings between U.S. citizens and certain countries, persons or
groups. It is imperative that employees seek advice from appropriate personnel
if they have any questions about whether a particular transaction is permissible
under applicable law. Violations of these laws can result in substantial fines
and/or imprisonment for violators.

THINGS TO WATCH OUT FOR

o   Unfamiliar customers or vendors without convincing references;

o   Evasive, reluctant or otherwise unsatisfactory answers by a customer to
    questions about end use, end user, delivery dates or delivery locations;

o   Freight forwarder listed as ultimate consignee;

o   Transactions involving an embargoed country, a citizen or representative of
    an embargoed country or an individual or entity subject to government
    sanction;

o   Any payment to the exporter or benefiting the exporter that is not included
    in the invoice price or otherwise reported to customs authorities;

o   Any payments or transactions with entities listed on the Specially
    Designated Nationals and Blocked Persons List promulgated by the U.S.
    Treasury's Office of Foreign Assets Control.

                                       8

               INTELLECTUAL PROPERTY AND CONFIDENTIAL INFORMATION

Among Nabors' most valuable assets is its intellectual property - patents, trade
secrets, trademarks, copyrights and other proprietary information. It is Nabors'
policy to establish, protect, maintain and defend its rights in all commercially
significant intellectual property and to use those rights in responsible ways.
All employees must take steps to safeguard these assets. In addition to
protecting Nabors' intellectual property rights, Nabors respects the valid
intellectual property rights of others. Unauthorized use of the intellectual
property rights of others may expose Nabors to civil lawsuits and damages and is
prohibited.

THINGS TO WATCH OUT FOR

o   Receiving from an employee proprietary information about his or her prior
    employer;

o   Accepting proprietary information from an outsider, without first consulting
    company legal counsel, under circumstances where a confidential relationship
    exists or may be implied;

o   Discussing Nabors' proprietary information with customers or suppliers;

o   Using trademarks and copyrighted information without proper identifying
    marks.

                                       9

                            COMPLIANCE AND REPORTING

Through leadership at all levels, we want to sustain a culture where ethical
conduct is recognized, valued and exemplified by all employees, officers and
directors. Employees and directors should identify and raise potential issues
before they lead to problems and should ask about application of this Code
whenever in doubt. Any employee or director who becomes aware of any existing or
potential violation of this Code should promptly notify an appropriate person in
management. The Company will take such action as it deems appropriate to address
any existing or potential violations of the Code.

EMPLOYEE RESPONSIBILITIES

You should have a basic understanding of issues covered by each Nabors Policy,
and you should have a detailed understanding of Policies that apply to your job.
Check the Nabors Intranet at www.naborsnet.nabors.com for the complete and
latest text of every Nabors policy that relates to your work.

You should seek assistance from your immediate supervisor, another senior
officer, the President of your organization or the Nabors Law Department when
you have questions about application of the Policies.

You should promptly raise any concern, that you or others may have about
possible violations of this Code or any Nabors Policy. In some circumstances, a
waiver of a policy may be warranted. It is important to identify issues, though,
to avoid misunderstandings and inadvertent violations of law or policy.
Sometimes it may seem difficult to raise a concern. Not raising a concern,
however, can cause tremendous harm, such as:

o   Serious damage to the health, safety and well-being of yourself, your fellow
    employees, the Company as a whole, our customers and the communities in
    which we operate;

o   The loss of confidence in Nabors - by customers, shareholders, governments
    and the public;

o   Fines, damage awards and other financial penalties against the Company;
    fines and/or prison sentences for individual employees.

Those are the reasons the company requires that employees not sit silently when
they have a policy concern. The point of raising a concern is not to get a
friend in trouble, but to protect oneself or others from potential harm.

You should understand the many options you have for raising policy concerns. You
may raise them with a Nabors manager or, if you prefer, with company human
resource personnel, the Law Department, or an internal or independent auditor.
Alternatively, you may provide information in confidence by calling the Nabors
Hotline, established specifically for reporting policy concerns, at
1-877-NABORS7. Your communication may be written or oral, and it may be
anonymous.

If you raise a policy concern and the issue is not resolved, raise it again with
one of the other contacts listed above.

NABORS STRICTLY PROHIBITS ANY EMPLOYEE FROM RETALIATING OR TAKING ADVERSE
ACTION AGAINST ANYONE FOR RAISING OR HELPING TO RESOLVE A POLICY CONCERN.

                                       10

MANAGEMENT RESPONSIBILITIES

The obligations of Nabors managers go beyond those required of all employees.
Managers in our company are expected to:

o   BUILD AND MAINTAIN A CULTURE OF COMPLIANCE by exemplifying ethical conduct
    in business transactions, communicating that business results are never more
    important than compliance, and encouraging employees to raise their
    integrity questions and concerns.

o   PREVENT COMPLIANCE PROBLEMS by ensuring that policies and procedures,
    tailored to the particular risk areas faced by a business, are issued and
    well-communicated, to ensure that employees understand the requirements of
    this Code, Nabors Policies and applicable law.

o   DETECT COMPLIANCE PROBLEMS by implementing appropriate control measures in
    business processes to detect compliance risks and/or violations and by
    ensuring that periodic compliance reviews are conducted, with the assistance
    of the Corporate Audit Staff, to assess the effectiveness of compliance
    measures and to identify ways of improving them.

o   RESPOND TO COMPLIANCE PROBLEMS by taking prompt corrective action to fix any
    identified weaknesses in compliance measures, taking appropriate
    disciplinary action and consulting with Nabors' legal counsel and making
    appropriate disclosures to regulators and law enforcement authorities.

EXPRESSING YOUR PERSONAL COMMITMENT

Periodically, Nabors asks employees to acknowledge their commitment to and
certify their compliance with this Code and Nabors Policies. Newly hired
employees must also acknowledge and commit to these policies. Each business unit
has a procedure for distributing and collecting these acknowledgments. The
Company expects employees to take these certifications seriously and to make
full disclosure of any issues raised by the certification forms.

Violation of a Nabors policy can also mean breaking the law, subjecting you or
the company to criminal penalties (fines or jail sentences) or civil sanctions
(damage awards or fines).

One final note. Covering up mistakes, whether your own or someone else's,
generally only makes a situation worse. Instead, errors or problems should
immediately be fully disclosed and corrected.

                                       11