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Transocean

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FY2021 Annual Report · Transocean
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

(Mark one)
☑  ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

FORM 10-K

For the fiscal year ended December 31, 2021
OR

☐  TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from _____ to _____

Commission file number 001-38373

TRANSOCEAN LTD.
(Exact name of registrant as specified in its charter)

Switzerland
(State or other jurisdiction of incorporation or organization)

98-0599916
(I.R.S. Employer Identification No.)

Turmstrasse 30
Steinhausen, Switzerland
(Address of principal executive offices)

6312
(Zip Code)

Registrant’s telephone number, including area code: +41 (41) 749-0500

Securities registered pursuant to Section 12(b) of the Act:

Title of each class
Shares, CHF 0.10 per share
0.50% Exchangeable Senior Bonds due 2023

Trading symbol
RIG
RIG/23

Name of each exchange on which registered
New York Stock Exchange
New York Stock Exchange

Securities registered pursuant to Section 12(g) of the Act: None

Indicate by check mark whether the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.   Yes ☑   No ☐
Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Exchange Act.   Yes ☐   No ☑
Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934
during  the  preceding  12  months  (or  for  such  shorter  period  that  the  registrant  was  required  to  file  such  reports),  and  (2)  has  been  subject  to  such  filing
requirements for the past 90 days.   Yes ☑   No ☐

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of

Regulation S-T during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).   Yes ☑   No ☐

Indicate  by  check  mark  whether  the  registrant  is  a  large  accelerated  filer,  an  accelerated  filer,  a  non-accelerated  filer,  smaller  reporting  company  or  an
emerging growth company.  See the definitions of “large accelerated filer,” “accelerated filer”, “smaller reporting company” and “emerging growth company” in
Rule 12b-2 of the Exchange Act.

Large accelerated filer ☑   Accelerated filer ☐   Non-accelerated filer ☐
Smaller reporting company ☐   Emerging growth company ☐

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new

or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act. ☐

Indicate  by  check  mark  whether  the  registrant  has  filed  a  report  on  and  attestation  to  its  management’s  assessment  of  the  effectiveness  of  its  internal
control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or
issued its audit report. ☐

Indicate by check mark whether the registrant is a shell company (as defined by Rule 12b-2 of the Exchange Act).   Yes ☐   No ☑ 
As of June 30, 2021, 634,629,502 shares were outstanding and the aggregate market value of shares held by non-affiliates was approximately $2.87 billion
(based on the reported closing market price of the shares of Transocean Ltd. on June 30, 2021 of $4.52 per share and assuming that all directors and executive
officers of the Company are “affiliates,” although the Company does not acknowledge that any such person is actually an “affiliate” within the meaning of the
federal securities laws).  As of February 14, 2022, 656,377,507 shares were outstanding.

DOCUMENTS INCORPORATED BY REFERENCE

Portions of the registrant’s definitive Proxy Statement to be filed with the United States Securities and Exchange Commission within 120 days of

December 31, 2021, for its 2022 annual general meeting of shareholders, are incorporated by reference into Part III of this Form 10-K.

Table of Contents

TRANSOCEAN LTD. AND SUBSIDIARIES
INDEX TO ANNUAL REPORT ON FORM 10-K
FOR THE YEAR ENDED DECEMBER 31, 2021

Item

Page

Item 1.
Item 1A.
Item 1B.
Item 2.
Item 3.
Item 4.

Item 5.

Item 6.
Item 7.
Item 7A.
Item 8.
Item 9.
Item 9A.
Item 9B.
Item 9C.

Item 10.
Item 11.
Item 12.

Item 13.
Item 14.

PART I

Business
Risk Factors
Unresolved Staff Comments
Properties
Legal Proceedings
Mine Safety Disclosures

PART II
Market for Registrant’s Common Equity, Related Shareholder Matters and Issuer Purchases of

Equity Securities

Reserved
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Quantitative and Qualitative Disclosures About Market Risk
Financial Statements and Supplementary Data
Changes in and Disagreements with Accountants on Accounting and Financial Disclosure
Controls and Procedures
Other Information
Disclosure Regarding Foreign Jurisdictions that Prevent Inspections

PART III

Directors, Executive Officers and Corporate Governance
Executive Compensation
Security Ownership of Certain Beneficial Owners and Management and Related Shareholder

Matters

Certain Relationships and Related Transactions, and Director Independence
Principal Accountant Fees and Services

Item 15.

Exhibits and Financial Statement Schedules

PART IV

2
9
22
22
22
23

25
26
27
39
41
74
74
74
74

75
75

75
75
75

76

FORWARD-LOOKING INFORMATION

The  statements  included  in  this  annual  report  regarding  future  financial  performance  and  results  of  operations  and  other
statements that are not historical facts are forward-looking statements within the meaning of Section 27A of the United States
(“U.S.”) Securities Act of 1933 and Section 21E of the U.S. Securities Exchange Act of 1934.  Forward-looking statements in
this annual report include, but are not limited to, statements about the following subjects:

◾ the effect, impact, potential duration, the scale of any economic disruptions or other implications of the COVID-19 pandemic, including

virus variants;

◾ the effect of any disputes and actions with respect to production levels by, among or between major oil and gas producing countries and any

expectations we may have with respect thereto;

◾ our results of operations, our cash flow from operations, our revenue efficiency and other performance indicators and optimization of rig-

based spending;

◾ the  offshore  drilling  market,  including  the  effects  of  variations  in  commodity  prices,  supply  and  demand,  utilization  rates,  dayrates,
customer  drilling  programs,  stacking  and  reactivation  of  rigs,  effects  of  new  rigs  on  the  market,  the  impact  of  changes  to  regulations  in
jurisdictions  in  which  we  operate  and  changes  in  the  global  economy  or  market  outlook  for  our  industry,  our  rig  classes  or  the  various
geographies in which we operate;

◾ customer  drilling  contracts,  including  contract  backlog,  force  majeure  provisions,  contract  awards,  commencements,  extensions,
terminations,  renegotiations,  contract  option  exercises,  contract  revenues,  early  termination  payments,  indemnity  provisions  and  rig
mobilizations;

◾ the transition to renewable or other energy alternatives, the commitment, by us or our customers, to reduce greenhouse gas emissions or

intensity thereof;

◾ liquidity, including availability under our bank credit agreement, and adequacy of cash flows for our obligations;
◾ debt  levels,  including  interest  rates,  credit  ratings  and  our  evaluation  or  decisions  with  respect  to  any  potential  liability  management
transactions or strategic alternatives intended to prudently manage our liquidity, debt maturities and other aspects of our capital structure
and any litigation, alleged defaults and discussions with creditors related thereto;

◾ newbuild,  upgrade,  shipyard  and  other  capital  projects,  including  the  level  of  expected  capital  expenditures  and  the  timing  and  cost  of
completing  capital  projects,  delivery  and  operating  commencement  dates,  relinquishment  or  abandonment,  expected  downtime  and  lost
revenues;

◾ the cost and timing of acquisitions and the proceeds and timing of dispositions;
◾ tax matters, including our effective tax rate, changes in tax laws, treaties and regulations, tax assessments and liabilities for tax issues in the

tax jurisdictions in which we operate or have a taxable presence;

◾ legal  and  regulatory  matters,  including  results  and  effects  of  current  or  potential  legal  proceedings  and  governmental  audits  and

assessments, outcomes and effects of internal and governmental investigations, customs and environmental matters;

◾ insurance matters, including adequacy of insurance, renewal of insurance, insurance proceeds and cash investments of our wholly owned

captive insurance company;

◾ effects of accounting changes and adoption of accounting policies; and
◾ investment  in  recruitment,  retention  and  personnel  development  initiatives,  the  timing  of,  and  other  matters  concerning,  severance

payments and benefit payments.

Forward-looking  statements  in  this  annual  report  are  identifiable  by  use  of  the  following  words  and  other  similar

expressions:

◾anticipates ◾budgets ◾estimates ◾forecasts ◾may
◾expects
◾believes ◾could

◾intends

◾might

◾plans
◾predicts ◾scheduled

◾projects

◾should

Such statements are subject to numerous risks, uncertainties and assumptions, including, but not limited to:
◾ those described under “Item 1A. Risk Factors” in this annual report on Form 10-K;
◾ the effects of public health threats, pandemics and epidemics, such as the outbreak of COVID-19, and the adverse impact thereof on our
business,  financial  condition  and  results  of  operations,  including,  but  not  limited  to,  our  growth,  operating  costs,  supply  chain,  labor
availability,  logistical  capabilities,  customer  demand  for  our  services  and  industry  demand  generally,  our  liquidity,  the  price  of  our
securities  and  trading  markets  with  respect  thereto,  our  ability  to  access  capital  markets,  and  the  global  economy  and  financial  markets
generally;

◾ the effects of actions by, or disputes among or between, members of the Organization of Petroleum Exporting Countries and other oil and

natural gas producing countries with respect to production levels or other matters related to the prices of oil and natural gas;

◾ the adequacy of and access to our sources of liquidity;
◾ our inability to renew drilling contracts at comparable, or improved, dayrates and to obtain drilling contracts for our rigs that do not have

contracts;

◾ operational performance;
◾ the cancellation of drilling contracts currently included in our reported contract backlog;
◾ losses on impairment of long-lived assets;
◾ shipyard, construction and other delays;
◾ the results of meetings of our shareholders;
◾ changes in political, social and economic conditions;
◾ the effect and results of litigation, regulatory matters, settlements, audits, assessments and contingencies; and
◾ other factors discussed in this annual report and in our other filings with the U.S. Securities and Exchange Commission (“SEC”), which are

available free of charge on the SEC website at www.sec.gov.

The  foregoing  risks  and  uncertainties  are  beyond  our  ability  to  control,  and  in  many  cases,  we  cannot  predict  the  risks  and
uncertainties that could cause our actual results to differ materially from those indicated by the forward-looking statements.  Should
one  or  more  of  these  risks  or  uncertainties  materialize,  or  should  underlying  assumptions  prove  incorrect,  actual  results  may  vary
materially from those indicated.  All subsequent written and oral forward-looking statements attributable to us or to persons acting on
our behalf are expressly qualified in their entirety by reference to these risks and uncertainties.  You should not place undue reliance on
forward-looking  statements.    Each  forward-looking  statement  speaks  only  as  of  the  date  of  the  particular  statement.    We  expressly
disclaim any obligations or undertaking to release publicly any updates or revisions to any forward-looking statement to reflect any
change in our expectations or beliefs with regard to the statement or any change in events, conditions or circumstances on which any
forward-looking statement is based, except as required by law.

Table of Contents

ITEM 1. BUSINESS

OVERVIEW

PART I

Transocean Ltd. (together with its subsidiaries and predecessors, unless the context requires otherwise, “Transocean,”
the  “Company,”  “we,”  “us”  or  “our”)  is  a  leading  international  provider  of  offshore  contract  drilling  services  for  oil  and  gas
wells.   As  of  February  14,  2022,  we  owned  or  had  partial  ownership  interests  in  and  operated  a  fleet  of  37  mobile  offshore
drilling units, consisting of 27 ultra-deepwater floaters and 10 harsh environment floaters.  As of February 14, 2022, we were
constructing two ultra-deepwater drillships.

We  provide,  as  our  primary  business,  contract  drilling  services  in  a  single  operating  segment,  which  involves
contracting  our  mobile  offshore  drilling  rigs,  related  equipment  and  work  crews  to  drill  oil  and  gas  wells.   We  specialize  in
technically  demanding  regions  of  the  global  offshore  drilling  business  with  a  particular  focus  on  ultra-deepwater  and  harsh
environment  drilling  services.    Our  drilling  fleet  is  one  of  the  most  versatile  fleets  in  the  world,  consisting  of  drillships  and
semisubmersible floaters used in support of offshore drilling activities and offshore support services on a worldwide basis.

Transocean  Ltd.  is  a  Swiss  corporation  with  its  registered  office  in  Steinhausen,  Canton  of  Zug  and  with  principal
executive  offices  located  at  Turmstrasse  30,  6312  Steinhausen,  Switzerland.    Our  telephone  number  at  that  address  is
+41 41 749-0500.  Our shares are listed on the New York Stock Exchange under the ticker symbol “RIG.”  For information
about  the  revenues,  operating  income,  assets  and  other  information  related  to  our  business,  our  segments  and  the  geographic
areas in which we operate, see “Part II. Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations” and “Part II. Item 8. Financial Statements and Supplementary Data—Notes to Consolidated Financial Statements—
Note 1—Business, Note 5—Revenues and Note 7—Long-Lived Assets.”

DRILLING FLEET

Overview—We  provide  contract  drilling  services  using  our  fleet  of  mobile  offshore  drilling  units,  including  both
drillships and semisubmersibles, broadly referred to as floaters.  Floaters are designed to operate in locations away from port for
extended periods of time and have living quarters for the crews, a helicopter landing deck and storage space for drill pipe, riser
and  drilling  supplies.    Our  drilling  units  and  related  equipment  are  suitable  for  both  exploration  and  development,  and  we
engage in both types of activities.

Drillships are floating vessels that are shaped like conventional ships, generally self-propelled and considered to be the
most mobile of the major rig types.  Drillships typically have greater deck load and storage capacity than semisubmersible rigs,
which provides logistical and resupply efficiency benefits for customers.  Drillships are generally better suited to operations in
calmer  sea  conditions  and  typically  do  not  operate  in  areas  considered  to  be  harsh  environments.    Our  high-specification
drillships  are  equipped  with  dynamic  positioning  thruster  systems,  which  allows  them  to  maintain  position  without  anchors
through  the  use  of  onboard  propulsion  and  station-keeping  systems.    We  have  22  ultra-deepwater  drillships  that  are,  and
two  ultra-deepwater  drillships  under  construction  that  will  be,  equipped  with  our  patented  dual-activity  technology.    Dual-
activity  technology  employs  structures,  equipment  and  techniques  using  two  drilling  stations  within  a  dual  derrick  to  allow
these drillships to perform simultaneous drilling tasks in a parallel, rather than a sequential manner, which reduces critical path
activity  and  improves  efficiency  in  both  exploration  and  development  drilling.    In  addition  to  dynamic  positioning  thruster
systems, dual-activity technology and industry-leading hoisting capacity, our contracted newbuild drillships under construction
will be equipped with at least one 20,000 pounds per square inch (“psi”) blowout preventers.

Semisubmersibles are floating vessels that can be partially submerged by means of a water ballast system such that the
lower column sections and pontoons are below the water surface during drilling operations.  Semisubmersibles are known for
stability, making them well suited for operating in rough sea conditions.  Semisubmersible floaters are capable of maintaining
their position over a well either through dynamic positioning or the use of mooring systems.  Although most semisubmersible
rigs are relocated with the assistance of tugs, some units are self-propelled and move between locations under their own power
when afloat on pontoons.  Four of our 13 semisubmersibles are equipped with dual-activity technology and also have mooring
capability.  Two of these four dual-activity units are custom-designed, high-capacity semisubmersible drilling rigs, equipped for
year-round operations in harsh environments, including those of the Norwegian continental shelf and sub-Arctic waters.

Our  floater  fleet  consists  of  ultra-deepwater  floaters  and  harsh  environment  floaters  that  are  designed  with  high-
specification  capabilities  to  operate  in  the  technically  demanding  regions  of  the  global  offshore  drilling  business.    Ultra-
deepwater  floaters  are  equipped  with  high-pressure  mud  pumps  and  are  capable  of  drilling  in  water  depths  of  4,500  feet  or
greater.    Harsh  environment  floaters  are  capable  of  drilling  in  harsh  environments  in  water  depths  between  1,500  and
10,000  feet  and  have  greater  displacement,  which  offers  larger  variable  load  capacity,  more  useable  deck  space  and  better
motion characteristics.

Fleet status—Depending on market conditions, we may idle or stack our non-contracted rigs.  An idle rig is between
drilling  contracts,  readily  available  for  operations,  and  operating  costs  are  typically  at  or  near  normal  operating  levels.    A
stacked  rig  typically  has  reduced  operating  costs,  is  staffed  by  a  reduced  crew  or  has  no  crew  and  is  (a)  preparing  for  an
extended  period  of  inactivity,  (b)  expected  to  continue  to  be  inactive  for  an  extended  period,  or  (c)  completing  a  period  of
extended inactivity.  Stacked rigs will continue to incur operating costs at or above normal operating levels for approximately
30 days following initiation of stacking.  Some idle rigs and all stacked rigs require additional costs to return to service.  The
actual cost to return to service, which in many instances could be significant and could fluctuate

- 2 -

Table of Contents

over  time,  depends  upon  various  factors,  including  the  availability  and  cost  of  shipyard  facilities,  the  cost  of  equipment  and
materials, the extent of repairs and maintenance that may ultimately be required, the length of time a rig has spent in stacking
mode and time and cost of assembling and training crew.  We consider these factors, together with market conditions, length of
contract, dayrate and other contract terms, when deciding whether to return a stacked rig to service.  We may not return some
stacked rigs to work for drilling services.

Drilling units—The following tables, presented as of February 14, 2022, provide certain specifications for our rigs.
 Unless otherwise noted, the stated location of each rig indicates either the current drilling location, if the rig is operating, or the
next operating location, if the rig is in shipyard with a follow-on contract.  The dates provided represent the expected time of
completion, the year placed into service, and, if applicable, the year of the most recent upgrade.  As of February 14, 2022, we
owned all of the drilling rigs in our fleet noted in the tables below, except for the following: (1) the harsh environment floater
Transocean Norge, which is owned through our 33.0 percent ownership interest in Orion Holdings (Cayman) Limited (together
with its subsidiary, “Orion”), and (2) the ultra-deepwater floater Petrobras 10000, which is subject to a finance lease through
August 2029.

Rig category and name
Ultra-deepwater floaters (27)

     Specifications     

Type

Year
entered
service /

Water
depth
capacity
     upgraded      (in feet)      (in feet)     

Drilling
depth
capacity

Drillship
Drillship
Drillship
Drillship
Drillship
Drillship
Drillship
Drillship
Drillship
Drillship
Drillship
Drillship
Drillship
Drillship
Drillship
Drillship
Drillship
Drillship
Drillship
Drillship
Drillship
Semisubmersible
Drillship
Drillship
Drillship
Semisubmersible
Semisubmersible

2018
2017
2016
2016
2016
2015
2014
2014
2014
2013
2013
2011
2011
2011
2011
2011
2010
2010
2010
2010
2009
2009
2009
2009
2009
2005
2000

2019
2016
2016
2015
2015
2010
2009

Semisubmersible
Semisubmersible
Semisubmersible
Semisubmersible
Semisubmersible
Semisubmersible
Semisubmersible
Semisubmersible 1985/2007
Semisubmersible 1987/1997
Semisubmersible

1990

 12,000
 12,000
 12,000
 12,000
 12,000
 12,000
 12,000
 12,000
 12,000
 12,000
 12,000
 12,000
 10,000
 10,000
 10,000
 10,000
 12,000
 7,500
 12,000
 12,000
 12,000
 7,500
 12,000
 12,000
 12,000
 7,500
 8,000

 10,000
 1,640
 1,640
 1,640
 1,640
 10,000
 10,000
 5,000
 4,500
 2,000

Deepwater Poseidon
Deepwater Pontus
Deepwater Conqueror
Deepwater Proteus
Deepwater Thalassa
Ocean Rig Apollo
Deepwater Athena
Deepwater Asgard
Deepwater Invictus
Deepwater Skyros
Deepwater Mylos
Deepwater Champion
Deepwater Corcovado
Deepwater Mykonos
Deepwater Orion
Deepwater Olympia
Discoverer India
Discoverer Luanda
Dhirubhai Deepwater KG2
Discoverer Inspiration
Discoverer Americas
Development Driller III
Petrobras 10000
Discoverer Clear Leader
Dhirubhai Deepwater KG1
GSF Development Driller I
Deepwater Nautilus

Harsh environment floaters (10)

Transocean Norge
Transocean Enabler
Transocean Encourage
Transocean Endurance
Transocean Equinox
Transocean Spitsbergen
Transocean Barents
Henry Goodrich
Transocean Leader
Paul B. Loyd, Jr.

(a) (b) (c) (d)
(a) (b) (c) (d)
(a) (b) (c) (d)
(a) (b) (c) (d)
(a) (b) (c) (d)
(a) (b)
(a) (b)
(a) (b) (c)
(a) (b) (c)
(a) (b)
(a) (b) (c)
(a) (b)
(a) (b)
(a) (b)
(a) (b)
(a) (b)
(a) (b)
(a) (b)
(a)
(a) (b) (c)
(a) (b)
(a) (b) (e)
(a) (b)
(a) (b) (c)
(a)
(a) (b) (e)
(e)

(a) (e) (f)
(a) (e) (f)
(a) (e) (f)
(a) (e) (f)
(a) (e) (f)
(a) (e) (f) (g)
(a) (e) (g)
(e)
(e)
(e)

(a) Dynamically positioned.
(b) Patented dual activity.
(c) Two blowout preventers.
(d) Designed to accommodate a future upgrade to 20,000 psi blowout preventers.
(e) Moored.
(f) Automated drilling control.
(g) Dual activity.

- 3 -

Contracted
location or
standby
status

U.S. Gulf
U.S. Gulf
U.S. Gulf
U.S. Gulf
U.S. Gulf
Stacked
Stacked
U.S. Gulf
U.S. Gulf
Angola
Stacked
Stacked
Brazil
Brazil
Idle
Stacked
Stacked
Stacked
Idle
U.S. Gulf
Stacked
Idle
Brazil
Stacked
India
Stacked
Not Disclosed

 40,000
 40,000
 40,000
 40,000
 40,000
 40,000
 40,000
 40,000
 40,000
 40,000
 40,000
 40,000
 35,000
 35,000
 35,000
 35,000
 40,000
 40,000
 35,000
 40,000
 40,000
 37,500
 37,500
 40,000
 35,000
 37,500
 30,000

 40,000 Norwegian N. Sea
 28,000 Norwegian N. Sea
 28,000 Norwegian N. Sea
 28,000 Norwegian N. Sea
 28,000 Norwegian N. Sea
 30,000 Norwegian N. Sea
 30,000 Norwegian N. Sea
 30,000
 25,000
 25,000

Stacked
Stacked
U.K. N. Sea

 
Table of Contents

Rig category and name
Rigs under construction (2)

Ultra-deepwater floaters
Deepwater Atlas
Deepwater Titan

    Specifications    

Type

Water
depth
capacity
     completion     (in feet)      (in feet)     

Drilling
depth
capacity

Expected

Contracted
location

(a) (b) (c)
(a) (b) (d)

Drillship
Drillship

2H2022
1H2023

 12,000
 12,000

 40,000
 40,000

U.S. Gulf
U.S. Gulf

(a) To be dynamically positioned.
(b) To be equipped with our patented dual activity.
(c) To be equipped with one 20,000 psi blowout preventer and one 15,000 psi blowout preventer.
(d) To be equipped with two 20,000 psi blowout preventers.

DRILLING CONTRACTS

Our offshore drilling services contracts are individually negotiated and vary in their terms and conditions.  We obtain
most of our drilling contracts through bidding processes in competition against other drilling services contractors and through
direct negotiations with operators.  Drilling contracts generally provide for payment on a dayrate basis, typically with higher
rates  for  periods  when  drilling  operations  are  optimized  and  lower  or  zero  rates  for  periods  during  which  the  drilling  unit  is
mobilized or when drilling operations are interrupted, restricted by equipment breakdowns, adverse environmental conditions or
otherwise.  A dayrate drilling contract generally extends over a period of time either covering the drilling of a single well or
group  of  wells  or  covering  a  stated  term.    At  December  31,  2021,  our  contract  backlog  was  approximately  $6.60  billion,
representing a decrease of 18 percent and 37 percent, respectively, compared to the contract backlog at December 31, 2020 and
2019, which was $8.06 billion and $10.42 billion, respectively.  See “Part II. Item 7. Management’s Discussion and Analysis of
Financial Condition and Results of Operations—Performance and Other Key Indicators.”

Certain of our drilling contracts may be cancelable for the convenience of the customer, typically with the payment of
an  early  termination  payment.    Such  payments,  however,  may  not  fully  compensate  us  for  the  loss  of  the  contract.    Drilling
contracts  also  customarily  provide  for  either  automatic  termination  or  termination  at  the  option  of  the  customer,  typically
without  payment  of  any  termination  fee,  under  various  circumstances  such  as  non-performance,  in  the  event  of  extended
downtime  or  impaired  performance  due  to  equipment  or  operational  issues  or  periods  of  extended  downtime  due  to  force
majeure events.  Many of these events are beyond our control.  The contract term in some instances may be extended by the
customer exercising options for the drilling of additional wells or for an additional period of time.  Our contracts also typically
include  a  provision  that  allows  the  customer  to  extend  the  contract  to  finish  drilling  a  well-in-progress.    During  periods  of
depressed  market  conditions,  our  customers  may  seek  to  renegotiate  drilling  contracts  or  options  to  reduce  the  term  of  their
obligations  or  the  average  dayrate  through  term  extensions  or  may  seek  to  early  terminate  or  repudiate  their  contracts.
 Suspension of drilling contracts will result in the reduction in or loss of dayrate for the period of the suspension.  If customers
cancel some of our contracts and we are unable to secure new contracts on a timely basis and on substantially similar or more
favorable  terms,  if  some  of  our  contracts  are  suspended  for  an  extended  period  of  time  or  if  a  number  of  our  contracts  are
renegotiated on less favorable terms, our consolidated financial position, results of operations or cash flows may be adversely
affected.  See “Item 1A. Risk Factors—Risks related to our business—Our drilling contracts may be terminated due to a number
of events, and, during depressed market conditions, our customers may seek to repudiate or renegotiate their contracts.”

Under dayrate drilling contracts, consistent with standard industry practice, our customers, as the operators, generally
assume, and grant indemnity for, subsurface and well control risks, and their consequential damages.  Under all of our current
drilling  contracts,  our  customers  indemnify  us  for  pollution  damages  in  connection  with  reservoir  fluids  stemming  from
operations under the contract, and we indemnify our customers for pollution that originates above the surface of the water from
the  rig  from  substances  in  our  control,  such  as  diesel  used  onboard  the  rig  or  other  fluids  stored  onboard  the  rig.   Also,  our
customers indemnify us for consequential damages they incur, damage to the well or reservoir, loss of subsurface oil and gas
and the cost of bringing the well under control.  However, because our drilling contracts are individually negotiated, the degree
of indemnification we receive from our customers for the risks discussed above may vary from contract to contract based on
market conditions, customer requirements existing when the contract was negotiated or other factors.  In some instances, we
have contractually agreed upon certain limits to our indemnification rights and can be responsible for certain damages up to a
specified maximum dollar amount.  The nature of our liability and the prevailing market conditions, among other factors, can
influence such contractual terms.  Notwithstanding a contractual indemnity from a customer, there can be no assurance that our
customers will be financially able to indemnify us or will otherwise honor their contractual indemnity obligations.

The  interpretation  and  enforceability  of  a  contractual  indemnity  depends  upon  the  specific  facts  and  circumstances
involved, as governed by applicable laws, and may ultimately need to be decided by a court or other proceeding, which would
need  to  consider  the  specific  contract  language,  the  facts  and  applicable  laws.    Applicable  laws  often  consider  contractual
indemnity for criminal fines and penalties to be against public policy.  Many courts also restrict indemnification for criminal
fines  and  penalties.    The  inability  or  other  failure  of  our  customers  to  fulfill  their  indemnification  obligations,  or  the
unenforceability of all of our contractual protections could have a material adverse effect on our consolidated financial position,
results  of  operations  or  cash  flows.    See  “Item  1A.  Risk  Factors—Risks  related  to  our  business—Our  business  involves
numerous  operating  hazards,  and  our  insurance  and  indemnities  from  our  customers  may  not  be  adequate  to  cover  potential
losses from our operations.”

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MARKETS

Overview—Our operations are geographically dispersed in oil and gas exploration and development areas throughout
the  world.    We  operate  in  a  single,  global  offshore  drilling  market,  as  our  drilling  rigs  are  mobile  assets  and  can  be  moved
according  to  prevailing  market  conditions.    We  may  mobilize  our  drilling  rigs  between  regions  for  a  variety  of  reasons,
including  to  respond  to  customer  contracting  requirements  or  to  capture  observed  market  demand.    Consequently,  we  cannot
predict the future percentage of our revenues that will be derived from particular geographic areas.  As of February 14, 2022,
the  drilling  units  in  our  fleet,  including  stacked  and  idle  rigs,  but  excluding  rigs  under  construction,  were  located  in  Greece
(eight  units),  the  U.S.  Gulf  of  Mexico  (eight  units),  the  Norwegian  North  Sea  (seven  units),  Brazil  (three  units),
Malaysia  (three  units),  the  United  Kingdom  (the  “U.K.”)  North  Sea  (two  units),  Trinidad  (one  unit),  Angola  (one  unit),
Canada (one unit), India (one unit), Myanmar (one unit), and Namibia (one unit).

We  categorize  the  sectors  of  the  floater  market  in  which  we  operate  as  follows:  (1)  ultra-deepwater  and  deepwater,
(2) harsh environment and (3) midwater.  We typically employ our ultra-deepwater floaters to service the ultra-deepwater and
deepwater  sector,  and  we  employ  our  harsh  environment  floaters  to  service  all  three  sectors.    We  generally  view  the  ultra-
deepwater and deepwater market sector as water depths beginning at 4,500 feet and extending to the maximum water depths in
which rigs are capable of drilling, which is currently up to 12,000 feet.  The midwater market sector includes water depths from
approximately  300  feet  to  approximately  4,500  feet.    The  harsh  environment  market  sector  includes  regions  that  are  more
challenged by lower temperatures, harsher weather conditions and water currents.

The market for offshore drilling rigs and related services reflects  our  customers’  demand  for  equipment  for  drilling
exploration, appraisal and development wells and for performing maintenance on existing production wells.  Activity levels of
energy  companies,  including  integrated  energy  companies,  independent  energy  companies  and,  to  a  lesser  extent,  national
energy companies are largely driven by the worldwide  demand  for  energy,  including  crude  oil  and  natural  gas.    Worldwide
energy  supply  and  demand  drives  oil  and  natural  gas  prices,  which,  in  turn,  impact  energy  companies’  ability  to  fund
investments in exploration, development and production activities.

Outlook—In 2014, the industry began to experience a severe cyclical downturn that has proven to be of considerably
longer duration than those previously observed.  Multiple years of volatile and generally weak commodity prices, exacerbated
by  the  effects  of  the  COVID-19  pandemic  and  production  disputes  among  major  oil  producing  countries,  resulted  in  our
customers  delaying  offshore  investment  decisions  and  postponing  exploration  and  development  programs.    Some  of  our
customers  have  also  committed  to  invest  or  increase  investment  in  low  carbon  and  renewable  energy  resources,  potentially
affecting their expenditures in the development and production of hydrocarbons over the coming decades.  Even in the context
of some diversion of investment away from traditional energy sources, the structural efficiency gains achieved by the offshore
oil  and  gas  industry  during  the  past  seven  years  materially  improved  the  economics  of  deepwater  and  harsh  environment
offshore development projects.  Our services are central to the exploitation of these competitive sources of new supply.

Our overall outlook for the offshore drilling industry has improved over the past year and remains positive, particularly
for  high-specification  assets,  such  as  those  we  own  and  operate.    During  the  second  half  of  2021,  our  customers’  interest  in
deepwater and harsh environment offshore projects was renewed due to numerous favorable factors, such as sustained higher
commodity prices and comparably lower carbon intensity compared to other sources of fossil fuel.  South America, including
Guyana,  the  U.S.  Gulf  of  Mexico  and,  increasingly,  West Africa  remain  key  ultra-deepwater  market  sectors,  while  Norway
continues to represent the largest harsh environment market.

In addition, in 2021, we observed continued strong tendering activity for Asia and Australia.  Licensing activity also
indicated  an  increased  interest  in  these  areas  as  energy  companies  looked  to  explore  and  develop  new  prospects.    Certain
customers began to increase their exploration, production and reserve replacement activities by restarting delayed projects and
commencing new campaigns.  We have seen an acceleration in this trend in early 2022.  While we expect this to continue in the
near  term,  and  potentially  longer,  it  depends  upon  many  variables,  including  increased  global  demand  for  hydrocarbons,  the
effects of the COVID-19 pandemic on consumer activity, the actions by some governments and regulators intended to curtail
existing and future drilling activities, and other factors.

We expect offshore oil and gas production to be a significant part of the long-term strategy for energy companies as
they strive to meet the global demand for energy sources and hydrocarbons.  These projects are technically demanding due to
various  factors,  such  as  water  depth,  complex  well  designs,  deeper  drilling  depth,  high  pressure  and  temperature,  sub-salt
geological  formations,  harsh  environments,  and  heightened  regulatory  standards  necessitating  the  use  of  high-specification
drilling units.  Generally, high-specification rigs are the most modern, technologically advanced class of the offshore fleet and
have capabilities that are attractive to energy companies operating in deeper water depths, other challenging environments or
with complex well designs.  We have led the industry and made concerted efforts since the beginning of the prolonged downturn
to high-grade our fleet profile by acquiring high-specification assets and disposing of lower-specification assets.  In this regard,
during  the  years  ended  December  31,  2021,  2020  and  2019,  we  sold  for  scrap  value  one,  six  and  eleven  lower-specification
drilling units, respectively.

As the hydrocarbon supply-demand balance further improves, we expect sustained prices to increase demand for our
high-specification  fleet  of  assets  and,  because  there  are  now  fewer  offshore  drilling  rigs  than  in  recent  years,  further
improvement of dayrates.  See “Item 1A. Risk Factors—Risks related to our business.”

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CUSTOMERS

We provide our offshore drilling services to most of the leading integrated energy companies or their affiliates, as well
as for many government-owned or government-controlled energy companies and other independent energy companies.  For the
year  ended  December  31,  2021,  our  most  significant  customers  were  Shell  plc  (together  with  its  affiliates,  “Shell”)  and
Equinor ASA (together with its affiliates, “Equinor”), representing approximately 31 percent and 30 percent, respectively, of our
consolidated operating revenues.  No other customers accounted for 10 percent or more of our consolidated operating revenues
in the year ended December 31, 2021.  Additionally, as of February 14, 2022, the customers with the most significant aggregate
amount of contract backlog associated with our drilling contracts were Shell, Equinor and Chevron Corporation (together with
its affiliates, “Chevron”), representing approximately 54 percent, 16 percent and 15 percent, respectively, of our total contract
backlog.    See  “Item  1A.  Risk  Factors—Risks  related  to  our  business—We  rely  heavily  on  a  relatively  small  number  of
customers and the loss of a significant customer or a dispute that leads to the loss of a customer could have an adverse effect on
our business.”

HUMAN CAPITAL RESOURCES

Worldwide workforce—As  of  December  31,  2021,  we  had  a  global  workforce  of  approximately  5,530  individuals,
including  approximately  530  contractors,  representing  58  nationalities.    At  December  31,  2021,  our  global  workforce  is
geographically distributed in 21 countries across five continents as follows: 34 percent in North America, 32 percent in Europe,
17 percent in South America, 12 percent in Asia and 5 percent in Africa.

FIRST Shared Values and corporate culture—Our FIRST Shared Values serve as the foundation for our corporate
culture and guide us to act ethically and responsibly as we strive to deliver value for our stakeholders and to maintain a safe and
respectful work environment for our people.  Our Shared Values are as follows:

◾ Focused.  We will consistently exceed the expectations of customers, shareholders and employees.
◾ Innovative.  We will continuously advance our position as technical leaders, and relentlessly pursue improvement in all

that we do.

◾ Reliable.  We will execute flawlessly by ensuring that our equipment, processes and systems always perform as and when

intended, and that our people are properly trained and motivated.

◾ Safe.  Above all else, we will protect each other, the environment and our assets.  We will conduct our operations in an

incident-free environment, all the time, everywhere.

◾ Trusted.    We  will  always  act  with  integrity  and  professionalism,  honor  our  commitments,  comply  with  laws  and

regulations, respect local cultures, and be fiscally responsible.

Code of Integrity and Human Rights—We maintain a Code of Integrity and Human Rights Policy that applies to all
our board members, executives, employees and business partners, including contractors, suppliers, vendors, investees and joint
venture partners.  We demonstrate our respect of human rights by maintaining a healthy and safe work environment, observing
fair employment practices and providing competitive employment terms.  Practices such as modern slavery, child labor, forced
or indentured servitude, and other human rights abuses are strictly prohibited.

Labor  rights—We  respect  the  labor  rights  of  all  individuals  in  our  workforce,  including  the  right  to  collective
bargaining.    Approximately  42  percent  of  our  total  workforce,  working  primarily  in  Norway,  Brazil  and  the  U.K.,  are
represented by, and some of our contracted labor work is subject to, collective bargaining agreements, substantially all of which
are subject to annual salary negotiation.  Negotiations over annual salary or other labor matters could result in higher personnel
or other costs or increased operational restrictions or disruptions.  The outcome of any such negotiation generally affects the
market for all offshore employees, not only union members.  A failure to reach an agreement on certain key issues could result
in strikes, lockouts or other work stoppages.

Attraction,  development  and  retention—We  aim  to  strategically  cultivate  a  best-in-class  workforce  to  offer  the
innovation, local knowledge and experience required of the world’s premier offshore drilling contractor.  We seek to maintain
our  competitive  advantage  while  benefitting  our  local  communities  by  offering  regionally  competitive  compensation  and
benefits packages, a technically challenging work environment, global opportunities, and rotational development programs.  We
continually assess and adapt our offerings and our policies, based on evolving social and technological practices, to provide a
modern work environment, which is essential to attract and retain top talent, and a respectful and inclusive work environment in
which our global workforce can thrive.  Our focus on the quality of our workforce is designed to maximize the quality of our
work performance and ultimately, the value we deliver to our stakeholders.

Training—We  invest  in  our  workers  by  providing  them  with  the  transferrable  skill  sets  essential  to  advancing  their
professional  development.   To  ensure  our  business  competes  at  the  highest  levels,  we  maintain  a  rigorous  competency-based
training program.  Our internal training board maintains and regularly updates our training matrix to meet or exceed industry
standards,  and  it  oversees  our  competency  assurance  management  system,  which  is  accredited  by  the  Offshore  Petroleum
Industry Training Organization.  We provide various offshore training formats designed to encompass all learning styles through
on-the-job, e-learning, customer-specific training, certifications, and leadership and licensing programs.  Setting us apart from
our competitors, we also offer unique simulation-based education, augmented by digital twin modeling, enabling our workforce
to more accurately visualize equipment performance and target efficiencies.  The certifications, skills and competencies needed
for each role are clearly articulated to our workforce, and workers are required to successfully complete the relevant training
and attain all necessary certifications prior to taking on new roles.

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Wellness and benefits—We offer our workforce regionally competitive medical and financial benefits, tailored to our
workforce  demographics.   We  design  our  wellness  and  benefits  strategy  under  four  pillars  consisting  of  physical  well-being,
financial  well-being,  emotional  well-being  and  social  well-being,  emphasizing  during  the  pandemic,  as  a  key  benefit,  our
globally available employee assistance program.

Safety—Our safety vision is to conduct our operations in an incident-free workplace, all the time, everywhere.  As a
socially responsible company, we prioritize the protection of everyone aboard our rigs and in our facilities, the environment and
our  property  at  all  work  locations  and  during  all  operations.    We  require  compliance  with  all  local  regulations  and  a
comprehensive  set  of  internal  policies  and  procedures  that  govern  our  operations,  including  health  and  safety  protocols  for
COVID-19  mitigation.    With  regular  competency  and  effectiveness  assessments,  our  highly  trained  crews  are  equipped  to
protect our operational integrity with the process-driven management of hazards to prevent and mitigate major hazard accidents.
 We measure our safety performance in terms of widely accepted ratios with the use of industry standards, including (a) the total
recorded  incidence  rate  (“TRIR”),  which  represents  the  number  of  recordable  work-related  injuries  or  illnesses  for  every
200,000 hours worked, and (b) the lost time incidence rate (“LTIR”), which measures the number of incidents that result in lost
time due to work-related injuries or illnesses for every 200,000 hours worked.  In the year ended December 31, 2021, our TRIR
was 0.26, and our LTIR was 0.02.

ENVIRONMENTAL RESPONSIBILITY

We understand our business has an impact on the environment.  Our objective is to deliver our services in a manner
that minimizes the impact to the environment and supports the interests of our stakeholders.  We constantly seek new ways to
advance our commitment to safely performing our operations while simultaneously safeguarding the environment in which we
operate.  We maintain a global Environmental Management System (“EMS”) standard that is applied to our rigs, offices and
facilities.  The EMS is aligned to ISO 14001 and provides a framework to ensure that our worldwide operations are managed
consistently and continuously in an environmentally responsible manner.

We  regularly  assess  the  environmental  impacts  of  our  operations,  focusing  on  the  reduction  of  greenhouse  gas
emissions, operational discharges and water use, through increasing energy efficiency and waste minimization.  Our actions are
designed  to  reduce  risk  in  our  current  and  future  operations,  to  promote  sound  environmental  management  practices  and  to
continue to be proactive in managing and reducing our environmental footprint.  Our investments and deployment of capital and
technology reflect our commitment to improve the energy and emission efficiency of our operations.

Another way we seek to enhance our operational performance is by setting emissions targets.  We intend to reduce our
operating Scope 1 and Scope 2 greenhouse gas emissions intensity by 40 percent from 2019 levels by 2030.  Achieving these
targets will require investments over time that result in the development and implementation of new technologies, reduced fuel
consumption and other initiatives that enable us to optimize our power management capabilities.

When we have decommissioned older and less capable assets, we have demonstrated our commitment to recycle them
according  to  established  environmental  regulations  and  guidelines.   All  the  rigs  that  we  have  sold  for  scrap  value  have  been
safely and responsibly recycled following protocols established under the Basel Convention and by the International Maritime
Organization at the Hong Kong International Convention.

TECHNOLOGICAL INNOVATION

We have a long history of technological innovation, including the first dynamically positioned drillship, the first rig to
drill year-round in the North Sea, the first semisubmersible rig for year-round sub-Arctic operations, the first 10,000-ft. water
depth  rated  ultra-deepwater  drillship  and  numerous  water  depth  world  records  over  the  past  several  decades.    Twenty-
two  drillships  and  two  semisubmersibles  in  our  existing  fleet  are,  and  our  two  drillships  that  are  under  construction  will  be,
equipped with our patented dual-activity technology, which allows our rigs to perform simultaneous drilling tasks in a parallel
rather  than  sequential  manner,  reducing  well  construction  critical  path  activities  and,  thereby,  improving  efficiency  in  both
exploration and development drilling.

We continue to develop and deploy industry-leading technology in the pursuit of delivering safer, more efficient and
environmentally responsible drilling services.  In addition to our patented dual-activity drilling technology, our two drillships
under construction will include industry-leading 3.5 million-pound hoisting load capability, hybrid energy storage systems for
enhanced drill floor equipment reliability, fuel and emissions savings as well as advanced generator protection for power plant
reliability.  Ten drillships in our existing fleet are, and our two drillships that are under construction will be, outfitted with dual
blowout  preventers  and  triple  liquid  mud  systems.    Our  two  drillships  under  construction  will  be  equipped  with  20,000  psi
blowout  preventers  and  related  equipment.    Five  drillships  in  our  existing  fleet  are  designed  to  accept  20,000  psi  blowout
preventers  in  the  future.    We  also  continue  to  develop  and  invest  in  technologies  designed  to  optimize  our  performance  and
deliver ever better operational integrity through innovations, such as our proprietary fault-resistant and fault-tolerant blowout
preventer control system.

Seven of our harsh environment semisubmersibles are designed and constructed specifically to provide highly efficient
performance  in  the  Norwegian  North  Sea  and  in  the  Barents  Sea.    We  have  installed  automated  drilling  control  systems  on
six harsh environment floaters, which materially improves our ability to safely and efficiently deliver wells to our customers.

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We  employ  a  data-driven  approach  by  deploying  technology,  augmented  by  the  size  of  our  fleet,  to  expand  our
knowledge framework for sustainable process optimization.  In 2020, we deployed our smart equipment analytics tool, which
delivers real-time data feeds from equipment to monitor equipment health, inferred emissions and energy consumption while
identifying  performance  trends  that  allow  us  to  systematically  optimize  equipment  maintenance  and  achieve  higher  levels  of
reliability, operational efficiency and sustainability.

Driven by our continued focus on safety, we developed and deployed our patented HaloGuard℠ system, which alarms,
notifies and, if required, halts equipment to avoid injury to personnel who move into danger zones.  We recently deployed the
first unit of Enhanced Drilling’s EC-Monitor system to an offshore installation, enabling highly accurate understanding of well
fluid  dynamics  and  improving  the  efficiency  and  accuracy  of  flow-checking  and  detecting  flow  anomalies.   Additionally,  in
2021,  we  deployed  on  one  of  our  ultra-deepwater  drillships  the  first  kinetic  blowout  stopper,  a  step-changing  technology
operations integrity and enterprise risk reduction through unrivaled shearing capability.  In the first half of 2022, we expect to
be  the  first  to  deploy  offshore  a  robotic  riser  bolting  tool  on  two  of  our  ultra-deepwater  drillships,  improving  our  ability  to
deliver safe, efficient and operations to our customers.

We  believe  our  efforts  to  continuously  improve,  and  effectively  use,  innovative  technologies  to  meet  or  exceed  our
customers’  requirements  is  critical  to  maintaining  our  competitive  position  within  the  contract  drilling  services  industry  by
drilling more efficient wells, building greater resilience into our critical operating systems, ensuring the safety of our crews, and
reducing fuel consumption and emissions.

GOVERNMENTAL REGULATIONS

Our  operations  are  subject  to  a  variety  of  international,  regional,  national,  state  and  local  government  regulations,
including  environmental  regulations.    We  monitor  our  compliance  with  such  government  regulations  in  each  country  of
operation  and,  while  we  see  an  increase  in  many  government  regulations,  particularly  general  environmental  regulation,  we
have made and will continue to make the required expenditures to comply with current and future government requirements.  To
date,  we  have  not  incurred  material  costs  in  order  to  comply  with  such  government  regulations,  including  environmental
regulations, and do not expect to make any material capital expenditures in order to comply with such regulations in the year
ending December 31, 2022, or any other period contemplated at this time.  We do not believe that our compliance with such
requirements will have a material adverse effect on our competitive position, consolidated results of operations or cash flows.
  We  incorporate  by  reference  into  this  subsection  “—Government  Relations”  the  disclosures  on  government  regulations,
including environmental regulations, contained in the following sections of this annual report on Form 10-K:
◾“Item 1A. Risk Factors—Risks related to our laws, regulations and governmental compliance;”
◾“Item 3. Legal Proceedings;”
◾“Part II. Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations—Other Matters;”
◾“Part II. Item 8. Financial Statements and Supplementary Data—Notes to Consolidated Financial Statements—Note 11—Income

Taxes;” and

◾“Part  II.  Item  8.  Financial  Statements  and  Supplementary  Data—Notes  to  Consolidated  Financial  Statements—Note  13—

Commitments and Contingencies.”

JOINT VENTURE, AGENCY AND SPONSORSHIP RELATIONSHIPS AND OTHER INVESTMENTS

In some areas of the world, local customs and practice or governmental requirements necessitate the formation of joint
ventures  with  local  participation  since  local  laws  or  customs  in  those  areas  effectively  mandate  the  establishment  of  a
relationship  with  a  local  agent  or  sponsor.    When  appropriate  in  these  areas,  we  may  enter  into  agency  or  sponsorship
agreements.    We  also  invest  in  certain  companies  for  operational  and  strategic  purposes.    Some  of  these  joint  ventures  or
companies in which we are an investor are involved in researching and developing technology to improve efficiency, reliability,
sustainability and safety for our drilling and other activities or are involved in businesses developed to support the transition to
renewable or other energy alternatives.  We may or may not control these partially owned companies.  At December 31, 2021,
we  held  partial  ownership  interests  in  companies  organized  in  the  Cayman  Islands,  the  U.S.,  Norway,  Canada  and  other
countries, the most significant of which was our 33.0 percent ownership interest in Orion, an unconsolidated Cayman Islands
exempted company formed to construct and own the harsh environment semisubmersible Transocean Norge.  Certain affiliates
of Hayfin Capital Management LLP, own the remaining 67.0 percent ownership interest in Orion not owned by us.

AVAILABLE INFORMATION

Our  website  address  is  www.deepwater.com.    Information  contained  on  or  accessible  from  our  website  is  not
incorporated by reference into this annual report on Form 10-K and should not be considered a part of this report or any other
filing that we make with the SEC.  Furthermore, references to our website URLs are intended to be inactive textual references
only.   We  make  available  on  this  website  free  of  charge,  our  annual  reports  on  Form  10-K,  quarterly  reports  on  Form  10-Q,
current reports on Form 8-K and amendments to those reports as soon as reasonably practicable after we electronically file those
materials with, or furnish those materials to, the SEC.  You may also find on our website information related to our corporate
governance,  board  committees  and  company  code  of  business  conduct  and  ethics.    The  SEC  also  maintains  a  website,
www.sec.gov,  which  contains  reports,  proxy  statements  and  other  information  regarding  SEC  registrants,  including  us.    We
intend to satisfy the requirement under Item 5.05 of Form 8-K to disclose any amendments to our Code of Integrity and any
waiver  from  any  provision  of  our  Code  of  Integrity  by  posting  such  information  in  the  Governance  page  on  our  website  at
www.deepwater.com.

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ITEM 1A.RISK FACTORS

RISKS RELATED TO OUR BUSINESS

OUR  BUSINESS  DEPENDS  ON  THE  LEVEL  OF  ACTIVITY  IN  THE  OFFSHORE  OIL  AND  GAS  INDUSTRY,
WHICH IS SIGNIFICANTLY AFFECTED BY VOLATILE OIL AND GAS PRICES AND OTHER FACTORS.

Our business depends on oil and gas exploration, development and production in offshore areas where we are capable
of operating.  Demand for our services depends on these activities and related expenditure levels that are directly affected by
trends in oil and, to a lesser extent, natural gas prices.  Oil and gas prices are extremely volatile and are affected by numerous
factors, including the following:

◾ worldwide  demand  for  oil  and  gas,  including  economic  activity  in  the  U.S.,  other  large  energy-consuming  markets  and  in
developing and emerging markets, which has been significantly impacted by the COVID-19 pandemic and the governmental,
company and individual reactions thereto;

◾ the  ability  of  the  Organization  of  the  Petroleum  Exporting  Countries  (“OPEC”)  to  set  and  maintain  production  levels,

productive spare capacity and pricing among its members;

◾ the level of production in non-OPEC countries;
◾ inventory levels, and the cost and availability of storage and transportation of oil, gas and their related products;
◾ the policies, laws and regulations of various governments regarding exploration and development of their oil and gas reserves
and environmental matters, including those addressing alternative energy sources and the risks of global climate change;

◾ international sanctions on oil-producing countries, or the lifting of such sanctions;
◾ advances in exploration, development and production technology;
◾ the development, exploitation and market acceptance of alternative energy sources;
◾ the further development of shale technology to exploit oil and gas reserves;
◾ the discovery rate of new oil and gas reserves and the rate of decline of existing oil and gas reserves;
◾ accidents, adverse weather conditions, natural disasters and other similar incidents relating to the oil and gas industry; and
◾ the worldwide security and political environment, including uncertainty or instability resulting from an escalation or outbreak

of armed hostilities, civil unrest, acts of terrorism, public health threats or other crises.

Demand for our services is particularly sensitive to the level of exploration, development and production activity of,
and the corresponding capital spending by, energy companies, including national energy companies.  Prolonged reductions in oil
and natural gas prices could depress the immediate levels of exploration, development and production activity.  Perceptions of
longer-term  lower  oil  and  natural  gas  prices  by  energy  companies,  or  a  perception  that  the  demand  for  hydrocarbons  will
significantly  decrease  in  the  medium  to  long  term,  could  similarly  reduce  or  defer  major  expenditures  given  the  long-term
nature  of  many  large-scale  development  projects  and  capital  reinvestment  policies.    Lower  levels  of  activity  result  in  a
corresponding  decline  in  the  demand  for  our  services,  which  could  have  a  material  adverse  effect  on  our  revenue  and
profitability.  Oil and gas prices and market expectations of potential changes in these prices significantly affect this level of
activity.  However, increases in near-term commodity prices do not necessarily translate into increased offshore drilling activity
since  customers’  expectations  of  longer-term  future  commodity  prices  and  expectations  regarding  future  demand  for
hydrocarbons typically have a greater impact on demand for our rigs.  Consistent with this dynamic, customers may delay or
cancel many exploration and development programs, resulting in reduced demand for our services.  Also, increased competition
for customers’ drilling budgets could come from, among other areas, land-based energy markets worldwide.  The availability of
quality drilling prospects, exploration success, relative production costs, the stage of reservoir development and political and
regulatory  environments  also  affect  customers’  drilling  campaigns.    Worldwide  military,  political  and  economic  events  have
often contributed to oil and gas price volatility and are likely to do so in the future.

THE OFFSHORE DRILLING INDUSTRY IS HIGHLY COMPETITIVE AND CYCLICAL, WITH INTENSE PRICE
COMPETITION.

The offshore contract drilling industry is highly competitive with numerous industry participants, none of which has a
dominant  market  share.    Drilling  contracts  are  traditionally  awarded  on  a  competitive  bid  basis.    Although  rig  availability,
service quality and technical capability are drivers of customer contract awards, bid pricing and intense price competition are
often key determinants for which a qualified contractor is awarded a job.

The  offshore  drilling  industry  is  highly  cyclical  and  is  impacted  by  oil  and  natural  gas  price  levels  and  volatility.
  Periods  of  high  customer  demand,  limited  rig  supply  and  high  dayrates  have  been  followed  by  periods  of  low  customer
demand,  excess  rig  supply  and  low  dayrates.    Changes  in  commodity  prices  can  have  a  dramatic  effect  on  rig  demand,  and
periods of excess rig supply may intensify competition in the industry and result in the idling of older and less technologically
advanced equipment.  We have idled and stacked rigs, and may in the future idle or stack additional rigs or enter into lower
dayrate drilling contracts in response to market conditions.  Idled or stacked rigs may remain out of service for extended periods
of  time.    During  prior  periods  of  high  dayrates  and  rig  utilization  rates,  we  and  other  industry  participants  responded  to
increased customer demand by increasing the supply of rigs through ordering the construction of new units.  The number of new
units  delivered  without  contracts,  combined  with  an  increased  number  of  rigs  in  the  global  market  completing  contracts  and
becoming idle, has increased and may continue to intensify price competition.  During periods of low oil and natural gas price
levels, new construction has resulted in an oversupply of rigs and has caused a subsequent decline in dayrates and rig utilization
rates, sometimes for extended periods of time.  In an oversupplied market, we may have limited bargaining power to negotiate
on more favorable terms.  Additionally, lower market dayrates and intense price competition may drive customers to seek to
renegotiate existing contracts to reduce dayrates in exchange for longer contract terms.  Lower dayrates and rig utilization rates
could adversely affect our revenues and profitability.

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As  of  February  14,  2022,  we  have  15  uncontracted  rigs,  of  which  five  have  been  out  of  service  for  greater  than
five years, and these rigs may remain out of service for extended periods of time.  If we are unable to obtain drilling contracts
for our uncontracted rigs, whether due to a prolonged offshore drilling market downturn, a delayed or muted recovery of such
market or otherwise, it may have an adverse effect on our results of operations and cash flows.

WE  MAY  NOT  BE  ABLE  TO  RENEW  OR  OBTAIN  NEW  DRILLING  CONTRACTS  FOR  RIGS  WHOSE
CONTRACTS ARE EXPIRING OR OBTAIN DRILLING CONTRACTS FOR OUR STACKED AND IDLE RIGS.

The offshore drilling markets in which we compete experience fluctuations in the demand for drilling services.  Our
ability  to  renew  expiring  drilling  contracts  or  obtain  new  drilling  contracts  depends  on  the  prevailing  or  expected  market
conditions at the time of expiration.  As of February 14, 2022, we have 15 stacked or idle rigs.  We also have 11 existing drilling
contracts for our rigs that are currently operating, which are scheduled to expire before December 31, 2022.  We may be unable
to  obtain  drilling  contracts  for  our  rigs  that  are  currently  operating  upon  the  expiration  or  termination  of  such  contracts,  and
there may be a gap in the operation of the rigs between the current contracts and subsequent contracts.  When oil and natural gas
prices  are  low  or  it  is  expected  that  such  prices  will  decrease  in  the  future,  we  may  be  unable  to  obtain  drilling  contracts  at
attractive dayrates or at all.  We may not be able to obtain new drilling contracts in direct continuation with existing contracts,
or depending on prevailing market conditions, we may enter into drilling contracts at dayrates substantially below the existing
dayrates or on terms otherwise less favorable compared to existing contract terms, which may have an adverse effect on our
financial position, results of operations or cash flows.

OUR CURRENT BACKLOG OF CONTRACT DRILLING REVENUES MAY NOT BE FULLY REALIZED.

At February 14, 2022, our contract backlog was approximately $6.47 billion.  This amount represents the maximum
contractual operating dayrate multiplied by the number of days remaining in the firm contract period, excluding revenues for
mobilization,  demobilization,  contract  preparation,  other  incentive  provisions  or  reimbursement  revenues,  which  are  not
expected  to  be  significant  to  our  contract  drilling  revenues.    Our  contract  backlog  includes  amounts  associated  with  our
two contracted newbuild units that are currently under construction.  The contractual operating dayrate may be higher than the
actual dayrate we ultimately receive or an alternative contractual dayrate, such as waiting on weather rate, repair rate, standby
rate or force majeure rate, may apply under certain circumstances.  The contractual operating dayrate may also be higher than
the  actual  dayrate  we  ultimately  receive  due  to  a  number  of  factors,  including  rig  downtime  or  suspension  of  operations.
  Several  factors  could  cause  rig  downtime  or  a  suspension  of  operations,  including:  equipment  breakdowns  and  other
unforeseen engineering problems, labor strikes and other work stoppages, shortages of material and skilled labor, surveys by
government and maritime authorities, periodic classification surveys, severe weather or harsh operating conditions, and force
majeure events.

In certain drilling contracts, the dayrate may be reduced to zero if, for example, repairs extend beyond a stated period
of time.  Our contract backlog includes only firm commitments, which are represented by signed drilling contracts or, in some
cases, other definitive agreements awaiting contract execution.  We may not be able to realize the full amount of our contract
backlog  due  to  events  beyond  our  control.    In  addition,  some  of  our  customers  have  experienced  liquidity  issues  in  the  past,
including  some  recently,  and  these  liquidity  issues  could  be  experienced  again  if  commodity  prices  decline  for  an  extended
period of time.  Liquidity issues and other market pressures could lead our customers to seek bankruptcy protection or to seek to
repudiate, cancel or renegotiate these agreements for various reasons (see “—Our drilling contracts may be terminated due to a
number  of  events,  and,  during  depressed  market  conditions,  our  customers  may  seek  to  repudiate  or  renegotiate  their
contracts”).    Our  inability  to  realize  the  full  amount  of  our  contract  backlog  may  have  an  adverse  effect  on  our  financial
position, results of operations or cash flows.

OUR  DRILLING  CONTRACTS  MAY  BE  TERMINATED  DUE  TO  A  NUMBER  OF  EVENTS,  AND,  DURING
DEPRESSED  MARKET  CONDITIONS,  OUR  CUSTOMERS  MAY  SEEK  TO  REPUDIATE  OR  RENEGOTIATE
THEIR CONTRACTS.

Certain of our drilling contracts with customers may be cancelable at the option of the customer upon payment of an
early  termination  payment.    Such  payments  may  not,  however,  fully  compensate  us  for  the  loss  of  the  contract.    Drilling
contracts  also  customarily  provide  for  either  automatic  termination  or  termination  at  the  option  of  the  customer,  typically
without  the  payment  of  any  termination  fee,  under  various  circumstances  such  as  non-performance,  as  a  result  of  significant
downtime or impaired performance caused by equipment or operational issues, or sustained periods of downtime due to force
majeure events, many of which are beyond our control.  Certain customers who seek to terminate our drilling contracts may
attempt to defeat or circumvent our protections against certain liabilities.  Our customers’ ability to perform their obligations
under their drilling contracts, including their ability to fulfill their indemnity obligations to us, may also be negatively impacted
by  an  economic  downturn.    Our  customers,  which  include  national  energy  companies,  often  have  significant  bargaining
leverage over us.  If our customers cancel some of our contracts, and we are unable to secure new contracts on a timely basis
and on substantially similar terms, or if contracts are suspended for an extended period of time or if a number of our contracts
are renegotiated on terms that are not as favorable as current terms, it could adversely affect our financial position, results of
operations or cash flows.

During periods of depressed market conditions, such as we have recently experienced, we are subject to an increased
counterparty risk, as our customers may seek to repudiate their contracts, including through claims of non-performance in order
to reduce their capital expenditures.  Our customers may no longer need a drilling rig that is currently under contract or may be
able to obtain a comparable drilling rig at a lower dayrate.  We have experienced, and are at continued risk of experiencing,
early contract terminations when there is a weak commodity price environment.  The ability of each of our counterparties to
perform its obligations under a contract with us, including indemnity obligations, will depend on a number of factors that are
beyond our control and may include, among other things, general economic conditions, the condition of the offshore drilling
industry, prevailing prices for oil and natural gas, the overall financial condition of the

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counterparty, the dayrates received and the level of expenditures necessary to maintain drilling activities.  Should a counterparty
fail to honor its obligations under an agreement with us, we could sustain losses, which could have an adverse effect on our
business and on our financial position, results of operations or cash flows.

WE  MUST  MAKE  SUBSTANTIAL  CAPITAL  AND  OPERATING  EXPENDITURES  TO  REACTIVATE  OUR
STACKED  OR  IDLE  FLEET  AND  TO  MAINTAIN  OUR  ACTIVE  FLEET,  AND  WE  MAY  BE  REQUIRED  TO
MAKE SIGNIFICANT CAPITAL EXPENDITURES TO MAINTAIN OUR COMPETITIVENESS AND TO COMPLY
WITH  LAWS  AND  APPLICABLE  REGULATIONS  AND  STANDARDS  OF  GOVERNMENTAL  AUTHORITIES
AND ORGANIZATIONS.

We must make substantial capital and operating expenditures to maintain our active fleet or to reactivate our stacked or
idle  fleet.    These  expenditures  could  increase  as  a  result  of  changes  in  the  cost  of  labor  and  materials,  requirements  of
customers, the size of our fleet, the cost of replacement parts for existing rigs, the geographic location of the rigs and the length
of  drilling  contracts.    Changes  in  offshore  drilling  technology,  customer  requirements  for  new  or  upgraded  equipment  and
competition  within  our  industry  may  require  us  to  make  significant  capital  expenditures  in  order  to  maintain  our
competitiveness  and  to  achieve  our  commitment  to  reduce  our  greenhouse  gas  emission  intensity.    Changes  in  governmental
regulations, including environmental requirements, and changes in safety or other equipment standards, as well as compliance
with standards imposed by maritime self-regulatory organizations, may cause our capital expenditures to increase or require us
to  make  additional  unforeseen  capital  expenditures.   As  a  result  of  these  factors,  we  may  be  required  to  take  our  rigs  out  of
service for extended periods of time, with corresponding losses of revenues, in order to make such alterations or to add such
equipment.  In the future, market conditions may not justify these expenditures or enable us to operate our older rigs profitably
during the remainder of their economic lives.

If  we  are  unable  to  fund  capital  expenditures  with  our  cash  flows  from  operations  or  proceeds  from  sales  of  non-
strategic  assets,  we  may  be  required  to  either  incur  additional  borrowings  or  raise  capital  through  the  sale  of  debt  or  equity
securities, or additional financing arrangements with banks or other capital providers.  Our ability to access the capital markets
may be limited by our financial condition at the time, perceptions of us or our industry, by changes in laws and regulations or
interpretation thereof and by adverse market conditions resulting from, among other things, general economic conditions and
contingencies and uncertainties that are beyond our control.  If we raise funds by issuing equity securities or other securities that
are  convertible  into  equity  securities,  existing  shareholders  may  experience  dilution.    Our  failure  to  obtain  the  funds  for
necessary future capital expenditures could have a material adverse effect on our business and on our financial position, results
of operations and cash flows.

PUBLIC  HEALTH  THREATS  HAVE  HAD,  AND  MAY  CONTINUE  TO  HAVE,  SIGNIFICANT  ADVERSE
CONSEQUENCES FOR GENERAL ECONOMIC, FINANCIAL AND BUSINESS CONDITIONS, AS WELL AS FOR
OUR BUSINESS AND OPERATIONS.

Public  health  threats,  pandemics  and  epidemics,  such  as  the  outbreak  of  COVID-19,  including  new  variants  therof,
severe influenza, other coronaviruses and other highly communicable viruses or diseases, have impacted and may continue to
impact  our  operations  directly  or  indirectly,  including  by  disrupting  the  operations  of  our  business  partners,  suppliers  and
customers in ways that adversely impact our operations.  For instance, the outbreak of COVID-19 and its development into a
pandemic in March 2020 resulted in various actions by governmental authorities around the world designed to prevent or reduce
the  spread  of  COVID-19,  such  as  imposing  mandatory  closures  of  all  non-essential  business  facilities,  seeking  voluntary
closures  of  such  facilities  and  imposing  restrictions  on,  or  advisories  with  respect  to,  travel,  business  operations  and  public
gatherings or interactions.  In addition, companies and individuals seeking to curtail the spread of COVID-19 have taken certain
cautionary  measures,  such  as  certain  companies  requiring  employees  to  work  remotely,  suspending  or  curtailing  all  non-
essential travel for employees, and discouraging employee attendance at in-person work-related meetings, as well as individuals
voluntarily social distancing and self-quarantining.  While many of the restrictions and measures initially implemented during
2020  have  since  been  softened  or  lifted  in  varying  degrees  in  different  locations  around  the  world,  and  the  manufacture  and
distribution  of  COVID-19  vaccines  during  2021  aided  to  initiate  an  economic  recovery  from  the  pandemic,  the  uncertainty
regarding new potential virus variants and the success of any these vaccines may in the future adversely affect global economic
activity  or  prompt  the  re-imposition  of  certain  restrictions  and  measures.    Increases  in  COVID-19  cases,  such  as  recently
developed as new variants emerged, may result in significantly reduced economic activity, even if not required by governmental
authorities, particularly in affected areas, which could result in a sharp reduction in the demand for oil and a decline in oil prices
as occurred during 2020.

We continue to experience increased costs and inefficiencies as a result of the comprehensive precautionary measures
we continue to take to help minimize the risk of COVID-19 impacts to our business, employees, customers, suppliers and the
communities  in  which  we  operate,  including  testing  employees  for  COVID-19  prior  to  transport  offshore  to  a  rig  and
quarantining any operational employee, where appropriate, who have shown signs of COVID-19, regardless of whether such
employee has been confirmed to be infected, and we also have experienced increased costs as a result of increasing our pools of
employees  that  are  available  to  substitute  for  employees  who  are  not  able  to  travel  to  a  rig.    We  cannot  guarantee  that  any
precautionary  measures  will  be  effective  in  preventing  either  an  outbreak  of  COVID-19  on  one  or  more  of  our  rigs  or  other
adverse effects related to COVID-19.  To the extent an outbreak of COVID-19 develops on one or more of our rigs, we may
have to temporarily shut down operations of such rig or rigs, which could result in significant downtime or contract termination
and have substantial adverse consequences for our business and results of operations.  In addition, most of our non-operational
employees  continue  to  work  remotely  a  substantial  majority  of  their  time,  which  increases  various  operational  risks.    For
instance, working remotely may increase the risk of security breaches or other cyber incidents or attacks, loss of data, fraud and
other disruptions as a consequence of more employees accessing sensitive and critical information from remote locations.

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Many governmental authorities across the globe implemented at various times during the COVID-19 pandemic travel
restrictions  and  mandatory  quarantine  measures  to  prevent  or  reduce  the  spread  of  COVID-19,  and  in  complying  with  such
governmental  actions,  we  have  experienced,  and  expect  to  continue  to  experience,  increased  difficulties,  delays  and  costs  in
moving our personnel in and out of, and to work in, the various jurisdictions in which we operate.  We may be unable to pass
along  these  increased  costs  to  our  customers.    Additionally,  disruptions  to  or  restrictions  on  the  ability  of  our  suppliers,
manufacturers  and  service  providers  to  supply  parts,  equipment  or  services  in  the  jurisdictions  in  which  we  operate  or  to
progress the construction of our newbuild projects, whether as a result of government actions, labor shortages, the inability to
source  parts  or  equipment  from  affected  locations,  or  other  effects  related  to  the  COVID-19  outbreak,  may  have  significant
adverse consequences on our ability to meet our commitments to customers, including by increasing our operating costs and
increasing the risk of rig downtime and could result in contract terminations.

Concerns over the prolonged negative effects of the COVID-19 outbreak on economic and business prospects across
the  world,  including  as  a  result  of  new  variants  of  the  virus,  have  also  contributed  to  oil  price  volatility  and  uncertainty
regarding the outlook for the global economy.  Such conditions have resulted in, and may continue to result in, reductions to our
customers’  drilling  and  production  expenditures  and  delays  or  cancellations  of  projects,  thus  decreasing  demand  for  our
services, and an increased risk that our customers may seek price reductions or more favorable economic terms for our services,
terminate our contracts or that we may be required to idle, stack or retire more of our rigs.  Additionally, any early termination
payment  made  in  connection  with  an  early  contract  termination  may  not  fully  compensate  us  for  the  loss  of  the  contract.
 Accordingly, the actual amount of revenues earned may be substantially lower than the reported contract backlog.  To the extent
our suppliers experience a deterioration in financial condition or operational capability as a result of such depressed market and
industry  conditions  or  we  or  other  suppliers  incur  delays  in  moving  personnel  to  and  from  drilling  rigs,  we  may  experience
disruptions in supply, which could increase our operating costs and increase rig downtime.  The occurrence of any such events
with  respect  to  our  customers,  contracts  or  suppliers  in  certain  cases  has  had,  and  may  continue  to  have,  significant  adverse
consequences for our business and financial position.

The magnitude and duration of potential social, economic and labor instability resulting from the COVID-19 outbreak,
including the speed at which national economies can recover, or whether any recovery will ultimately experience a reversal or
other setbacks, are uncertain and cannot be estimated as such effects depend on future events that are largely out of our control.
 The ultimate extent of the impact of COVID-19 and its variants on our business and financial position depend largely on future
developments, including the duration, spread or containment of the outbreak, particularly within the geographic locations where
we operate, and the related impact on overall economic activity, all of which are highly uncertain.  We are unable to predict the
timing or impact of any such restructurings, if completed, on the capital structure and competitive dynamics among offshore
drilling companies.

PUBLIC  AND  INVESTOR  SENTIMENT  TOWARDS  CLIMATE  CHANGE,  FOSSIL  FUELS  AND  OTHER  ESG
MATTERS  COULD  ADVERSELY  AFFECT  OUR  BUSINESS,  COST  OF  CAPITAL  AND  THE  PRICE  OF  OUR
STOCK AND OTHER SECURITIES.

Changing public sentiment concerning fossil fuels, aimed at the investment community, including investment advisors,
sovereign wealth funds, public pension funds, universities and other groups, has prompted efforts to promote the divestment of
shares of energy companies, as well as to pressure lenders and other financial services companies to limit or curtail activities
with energy companies.  These efforts have recently intensified, as demonstrated by the State of New York’s December 2020
announcement  that  it  will  be  divesting  the  state’s  Common  Retirement  Fund  from  fossil  fuels.    If  this  or  similar  divestment
efforts are successful, our stock price and our ability to access capital markets may be negatively impacted.

Members  of  the  investment  community  are  also  increasing  their  focus  on  environmental,  social  and  governance
(“ESG”) practices and disclosures, including practices and disclosures related to greenhouse gases and climate change, in the
energy industry in particular, and diversity and inclusion initiatives and governance standards among public companies more
generally.  As a result, we may face increasing pressure regarding our ESG disclosures and practices.  Additionally, members of
the  investment  community  may  screen  companies  such  as  ours  for  ESG  sustainability  performance  before  investing  in  our
stock.    Over  the  past  few  years  there  has  also  been  an  acceleration  in  investor  demand  for  ESG  investing  opportunities,  and
many large institutional investors have committed to increasing the percentage of their portfolios that are allocated towards ESG
investments.   As  a  result,  there  has  been  a  proliferation  of  ESG  focused  investment  funds  seeking  ESG  oriented  investment
products.  If we or our securities are unable to meet the sustainability ESG standards or investment criteria set by these investors
and  funds,  we  may  lose  investors  or  investors  may  allocate  a  portion  of  their  capital  away  from  us,  our  cost  of  capital  may
increase, our stock price and the price of our publicly traded debt securities may be negatively impacted and our reputation may
also be negatively affected.

WE  RELY  HEAVILY  ON  A  RELATIVELY  SMALL  NUMBER  OF  CUSTOMERS  AND  THE  LOSS  OF  A
SIGNIFICANT CUSTOMER OR A DISPUTE THAT LEADS TO THE LOSS OF A CUSTOMER COULD HAVE AN
ADVERSE EFFECT ON OUR BUSINESS.

We engage in offshore drilling services for most of the leading integrated energy companies or their affiliates, as well
as for many government-owned or government-controlled energy companies and other independent energy companies.  For the
year ended December 31, 2021, our most significant customers were Shell and Equinor, representing approximately 31 percent
and  30  percent,  respectively,  of  our  consolidated  operating  revenues.   As  of  February  14,  2022,  the  customers  with  the  most
significant  aggregate  amount  of  contract  backlog  associated  with  our  drilling  contracts  were  Shell,  Equinor  and  Chevron,
representing approximately 54 percent, 16 percent and 15 percent, respectively, of our total contract backlog.  The loss of any of
these customers or another significant customer, or a decline in payments under any of our drilling contracts, could, at least in
the short term, have an adverse effect on our business.

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OUR OPERATING AND MAINTENANCE COSTS WILL NOT NECESSARILY FLUCTUATE IN PROPORTION TO
CHANGES IN OUR OPERATING REVENUES.

Our operating and maintenance costs will not necessarily fluctuate in proportion to changes in our operating revenues
and  are  affected  by  many  factors,  including  inflation.    Costs  for  operating  a  rig  are  generally  fixed  or  only  semi-variable
regardless of the dayrate being earned.  In addition, should our rigs incur unplanned downtime while on contract or idle time
between drilling contracts, we will not always reduce the staff on those rigs because we could use the crew to prepare the rig for
its next contract.  During times of reduced activity, reductions in costs may not be immediate because portions of the crew may
be required to prepare rigs for stacking, after which time the crew members may be reassigned to active rigs or released.  As our
rigs  are  mobilized  from  one  geographic  location  to  another,  the  labor  and  other  operating  and  maintenance  costs  can  vary
significantly.  In general, labor costs increase primarily due to higher salary levels and inflation.  Equipment maintenance costs
fluctuate depending upon the type of activity the unit is performing and the age and condition of the equipment, and these costs
could increase for short or extended periods as a result of regulatory or customer requirements that raise maintenance standards
above historical levels.  The amount of contract preparation and reactivation costs vary based on the scope and length of the
contract  preparation  or  reactivation  project,  and  the  recognition  of  such  costs  varies  depending  on  the  duration  of  the  firm
contractual period and other contract terms.

Certain of our drilling contracts are partially payable in local currency.  The amounts, if any, of local currency received
under these drilling contracts may exceed our local currency needs to pay local operating and maintenance costs, leading to an
accumulation  of  excess  local  currency  balances,  which,  in  certain  instances,  may  be  subject  to  either  restrictions  or  other
difficulties  in  converting  to  U.S.  dollars,  our  functional  currency,  or  to  other  currencies  of  the  locations  where  we  operate.
 Excess amounts of local currency may also be exposed to the risk of currency exchange losses.

OUR BUSINESS INVOLVES NUMEROUS OPERATING HAZARDS, AND OUR INSURANCE AND INDEMNITIES
FROM  OUR  CUSTOMERS  MAY  NOT  BE  ADEQUATE  TO  COVER  POTENTIAL  LOSSES  FROM  OUR
OPERATIONS.

Our operations are subject to the usual hazards inherent in the drilling of oil and gas wells, such as, blowouts, reservoir
damage, loss of production, loss of well control, lost or stuck drill strings, equipment defects, craterings, fires, explosions and
pollution.  Contract drilling requires the use of heavy equipment and exposure to hazardous conditions, which may subject us to
liability  claims  by  employees,  customers  and  other  parties.    These  hazards  can  cause  personal  injury  or  loss  of  life,  severe
damage  to  or  destruction  of  property  and  equipment,  pollution  or  environmental  or  natural  resource  damage,  claims  by  third
parties or customers and suspension of operations.  Our offshore fleet is also subject to hazards inherent in marine operations,
either while on site or during mobilization, such as capsizing, sinking, grounding, collision, piracy, damage from severe weather
and marine life infestations.

The  South  China  Sea,  the  Northwest  Coast  of  Australia  and  the  U.S.  Gulf  of  Mexico  are  areas  subject  to  typhoons,
hurricanes  or  other  extreme  weather  conditions  on  a  relatively  frequent  basis,  and  our  drilling  rigs  in  these  regions  may  be
exposed to damage or total loss by these storms, some of which may not be covered by insurance.  The occurrence of these
events could result in the suspension of drilling operations, damage to or destruction of the equipment involved and injury to or
death of rig personnel.  Some experts believe global climate change could increase the frequency and severity of these extreme
weather conditions.  Operations may also be suspended because of machinery breakdowns, abnormal drilling conditions, failure
of subcontractors to perform or supply goods or services, or personnel shortages.  We customarily provide contract indemnity to
our customers for certain claims that could be asserted by us relating to damage to or loss of our equipment, including rigs, and
claims that could be asserted by us or our employees relating to personal injury or loss of life.

Damage to the environment or natural resources could also result from our operations, particularly through spillage of
hydrocarbons, fuel, lubricants or other chemicals and substances used in drilling operations, or extensive uncontrolled fires.  We
may also be subject to property damage, environmental indemnity and other claims by energy companies or other third parties.
 Drilling involves certain risks associated with the loss of control of a well, such as blowout, cratering, the cost to regain control
of  or  redrill  the  well  and  remediation  of  associated  pollution.    Our  customers  may  be  unable  or  unwilling  to  indemnify  us
against such risks.  In addition, a court may decide that certain indemnities in our current or future drilling contracts are not
enforceable.  The law generally considers contractual indemnity for criminal fines and penalties to be against public policy, and
the enforceability of an indemnity as to other matters may be limited.

Our insurance policies and drilling contracts contain rights to indemnity that may not adequately cover our losses, and
we do not have insurance coverage or rights to indemnity for all risks.  We have two main types of insurance coverage: (1) hull
and machinery coverage for physical damage to our property and equipment and (2) excess liability coverage, which generally
covers  offshore  risks,  such  as  personal  injury,  third-party  property  claims,  and  third-party  non-crew  claims,  including  wreck
removal and pollution.  We generally have no hull and machinery insurance coverage for damages caused by named storms in
the U.S. Gulf of Mexico.  We maintain per occurrence deductibles that generally range up to $10 million for various third-party
liabilities,  and  we  self-insure  $50  million  of  the  $750  million  excess  liability  coverage  through  our  wholly  owned  captive
insurance company.  We also retain the risk for any liability that exceeds our excess liability coverage.  However, pollution and
environmental risks generally are not completely insurable.

If  a  significant  accident  or  other  event  occurs  that  is  not  fully  covered  by  our  insurance  or  by  an  enforceable  or
recoverable  indemnity,  the  occurrence  could  adversely  affect  our  financial  position,  results  of  operations  or  cash  flows.   The
amount of our insurance may also be less than the related impact on enterprise value after a loss.  Our insurance coverage will
not in all situations provide sufficient funds to protect us from all liabilities that could result from our drilling operations.  Our
coverage  includes  annual  aggregate  policy  limits.   As  a  result,  we  generally  retain  the  risk  for  any  losses  in  excess  of  these
limits.  We generally do not carry insurance for loss of revenue, and

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certain other claims may also not be reimbursed by insurance carriers.  Any such lack of reimbursement may cause us to incur
substantial costs.  In addition, we could decide to retain more risk in the future, resulting in higher risk of losses, which could be
material.  Moreover, we may not be able to maintain adequate insurance in the future at rates that we consider reasonable or be
able to obtain insurance against certain risks.

FAILURE TO RECRUIT AND RETAIN KEY PERSONNEL COULD HURT OUR OPERATIONS.

We depend on the continuing efforts of key members of our management, as well as other highly skilled personnel, to
operate  and  provide  technical  services  and  support  for  our  business  worldwide.    Historically,  competition  for  the  personnel
required for drilling operations has intensified as the number of rigs activated, added to worldwide fleets or under construction
increased,  leading  to  shortages  of  qualified  personnel  in  the  industry  and  creating  upward  pressure  on  wages  and  higher
turnover.   We  may  experience  a  reduction  in  the  experience  level  of  our  personnel  as  a  result  of  any  increased  turnover  and
ongoing  staff  reduction  initiatives,  which  could  lead  to  higher  downtime  and  more  operating  incidents,  which  in  turn  could
decrease revenues and increase costs.  If increased competition for qualified personnel were to intensify in the future we may
experience increases in costs or limits on operations.

OUR  LABOR  COSTS  AND  THE  OPERATING  RESTRICTIONS  UNDER  WHICH  WE  OPERATE  COULD
INCREASE  AS  A  RESULT  OF  COLLECTIVE  BARGAINING  NEGOTIATIONS  AND  ADDITIONAL
UNIONIZATION EFFORTS.

Approximately 42 percent of our total workforce, working primarily in Norway, Brazil and the U.K., are represented
by, and some of our contracted labor work is subject to, collective bargaining agreements, substantially all of which are subject
to annual salary negotiation.  Negotiations over annual salary or other labor matters could result in higher personnel or other
costs or increased operational restrictions or disruptions.  The outcome of any such negotiation generally affects the market for
all  offshore  employees,  not  only  the  union  members.   A  failure  to  reach  an  agreement  on  certain  key  issues  could  result  in
strikes,  lockouts,  or  other  work  stoppages.    Legislation  has  been  introduced  in  the  U.S.  Congress  that  could  encourage
additional unionization efforts in the U.S., as well as increase the chances that such efforts succeed.  Additional unionization
efforts,  if  successful,  new  collective  bargaining  agreements  or  work  stoppages  could  materially  increase  our  labor  costs  and
operating restrictions.

OUR SHIPYARD PROJECTS AND OPERATIONS ARE SUBJECT TO DELAYS AND COST OVERRUNS.

As of February 14 2022, we had under construction two ultra-deepwater drillships.  We also have a variety of other
more  limited  shipyard  projects  at  any  given  time.   These  shipyard  projects  are  subject  to  the  risks  of  delay  or  cost  overruns
inherent in any such construction project resulting from numerous factors, including the following:

◾ complications  arising  from  pandemics  and  epidemics,  such  as  COVID-19,  severe  influenza,  other  coronaviruses  and  other
highly  communicable  viruses  or  diseases,  and  associated  government  orders  in  the  country  where  the  rigs  are  being
constructed or serviced and elsewhere;
◾ shipyard availability, failures and difficulties;
◾ shortages of equipment, materials or skilled labor;
◾ failure  or  delayed  deliveries  of  significant  materials  or  equipment  for  various  reasons,  including  due  to  supplier  shortages,

constraints, disruption or quality issues;

◾ design and engineering problems, including those relating to the commissioning of newly designed equipment;
◾ latent damages or deterioration to hull, equipment and machinery in excess of engineering estimates and assumptions;
◾ unanticipated actual or purported change orders;
◾ disputes with shipyards and suppliers;
◾ availability of suppliers to recertify equipment for enhanced regulations;
◾ strikes, labor disputes and work stoppages;
◾ customer acceptance delays or delays in providing customer-supplied engineering, approvals or equipment;
◾ adverse weather conditions, including damage caused by such conditions;
◾ terrorist acts, war, piracy and civil unrest;
◾ unanticipated cost increases; and
◾ difficulty in obtaining necessary permits or approvals.

These  factors  may  contribute  to  cost  variations  and  delays  in  the  delivery  of  our  newbuild  units  and  other  rigs
undergoing shipyard projects.  Cost variations may result in, among other things, disputes with the shipyards that construct or
service our drilling units.  In addition, delayed delivery of our newbuild units or other rigs undergoing shipyard projects would
impact contract commencement, resulting in a loss of revenues we could earn, and may also cause customers to terminate or
shorten the term of the drilling contract for the rig pursuant to applicable late delivery clauses.  In the event of termination of
any of these drilling contracts, we may not be able to secure a replacement contract on as favorable terms, if at all.

Our operations also rely on a significant supply of capital and consumable spare parts and equipment to maintain and
repair our fleet.  We also rely on the supply of ancillary services, including supply boats and helicopters.  Our reliance on our
suppliers, manufacturers and service providers to secure equipment, parts, components and sub-systems used in our operations
exposes  us  to  volatility  in  the  quality,  prices  and  availability  of  such  items.    Certain  parts  and  equipment  that  we  use  in  our
operations may be available only from a small number of suppliers, manufacturers or service providers, or in some cases must
be  sourced  through  a  single  supplier,  manufacturer  or  service  provider.    A  disruption  in  the  deliveries  from  our  suppliers,
manufacturers or service providers, capacity constraints, production disruptions, price increases, quality control issues, recalls
or other decreased availability of parts and equipment or ancillary services could adversely

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affect  our  ability  to  meet  our  commitments  to  customers,  adversely  impact  our  operations,  increase  our  operating  costs  and
result in increases in rig downtime and delays in the repair and maintenance of our fleet.

AS  PART  OF  OUR  BUSINESS  STRATEGIES,  WE  MAY  PURSUE  OPPORTUNITIES  TO  STRENGTHEN  AND
BROADEN OUR BUSINESS THAT INCLUDE ACQUISITIONS OF BUSINESSES OR DRILLING RIGS, MERGERS
OR JOINT VENTURES OR OTHER INVESTMENTS, AND SUCH TRANSACTIONS WOULD PRESENT VARIOUS
RISKS AND UNCERTAINTIES.

We  may  pursue  transactions  that  involve  the  acquisition  of  businesses  or  assets,  mergers  or  joint  ventures  or  other
investments  that  we  believe  will  enable  us  to  further  strengthen  or  broaden  our  business.    Any  such  transaction  would  be
evaluated  on  a  case-by-case  basis,  and  the  consummation  thereof  would  be  dependent  upon  several  factors,  including
identifying  suitable  companies,  businesses  or  assets  that  align  with  our  business  strategies,  reaching  agreement  with  the
potential counterparties on acceptable terms, the receipt of any applicable regulatory and other approvals, and other conditions.
 These transactions involve various risks, including among others, (i) difficulties related to integrating or managing applicable
parts  of  an  acquired  business  or  joint  venture  and  unanticipated  changes  in  customer  and  other  third-party  relationships
subsequent  to  closing,  (ii)  diversion  of  management's  attention  from  day-to-day  operations,  (iii)  failure  to  realize  anticipated
benefits, such as cost savings, revenue enhancements or strengthening or broadening our business, (iv) potentially substantial
transaction costs associated with acquisitions, joint ventures or investments if we or a transaction counterparty seeks to exit or
terminate an interest in the joint venture or investment, and (v) potential accounting impairment or actual diminution or loss of
value of our investment if future market, business or other conditions ultimately differ from our assumptions at the time of such
transaction is consummated.

FAILURE  TO  EFFECTIVELY  AND  TIMELY  ADDRESS  THE  TRANSITION  TO  RENEWABLE  OR  OTHER
ALTERNATIVE  ENERGY  SOURCES  COULD  ADVERSELY  AFFECT  OUR  BUSINESS,  RESULTS  OF
OPERATIONS AND CASH FLOWS.

Our long-term success depends on our ability to effectively address the transition to renewable and other alternative
energy sources, which may require adapting certain parts or our operations to potentially changing government requirements,
customer preferences and to a potentially changing and broader customer base, as well as engaging with existing and potential
customers  and  suppliers  to  develop  or  implement  solutions  designed  to  reduce  or  decarbonize  oil  and  gas  operations,  or  to
advance renewable and other alternative energy sources.  If the energy transition landscape changes faster than anticipated or in
a  manner  that  we  do  not  anticipate,  demand  for  our  services  could  be  adversely  affected.    Furthermore,  if  we  fail  or  are
perceived to not effectively implement an energy transition strategy, or if investors or financial institutions shift funding away
from  companies  in  fossil  fuel-related  industries,  our  access  to  capital  or  the  market  for  our  securities  could  be  negatively
impacted.

OUR ASPIRATIONS, GOALS, COMMITMENT TARGETS AND INITIATIVES RELATED TO SUSTAINABILITY,
INCLUDING  EMISSIONS  REDUCTION,  AND  OUR  PUBLIC  STATEMENTS  AND  DISCLOSURES  REGARDING
THEM, EXPOSE US TO NUMEROUS RISKS.

We have developed, and will continue to develop and set, goals, targets, and other objectives related to sustainability
matters,  including  our  commitment  target  to  reduce  our  greenhouse  gas  emissions.    Statements  related  to  these  goals,
commitment targets and objectives reflect our current intentions and do not constitute a guarantee that they will be achieved.
 Our efforts to research, establish, accomplish, and accurately report on these goals, commitment targets, and other objectives
expose  us  to  numerous  operational,  reputational,  financial,  legal,  and  other  risks.    Our  ability  to  achieve  any  stated  goal,
commitment  target,  or  objective,  including  with  respect  to  emissions  intensity  reduction,  is  subject  to  numerous  factors  and
conditions, some of which are outside of our control.

Our business may face increased scrutiny from investors and other stakeholders related to our sustainability activities,
including  the  goals,  commitment  targets,  and  other  objectives  that  we  announce,  and  our  methodologies  and  timelines  for
pursuing  them.    If  our  sustainability  assumptions  or  practices  do  not  meet  investor  or  other  stakeholder  expectations  and
standards,  which  continue  to  evolve,  our  reputation,  our  ability  to  attract  or  retain  employees,  and  our  attractiveness  as  an
investment or business partner could be negatively affected.  Similarly, our failure or perceived failure to pursue or fulfill our
sustainability-focused goals, targets, and objectives, to comply with ethical, environmental, or other standards, regulations, or
expectations, or to satisfy various reporting standards with respect to these matters, within the timelines we announce, or at all,
could adversely affect our business or reputation, as well as expose us to government enforcement actions and private litigation.

RISKS RELATED TO OUR INDEBTEDNESS

WE  HAVE  A  SUBSTANTIAL  AMOUNT  OF  DEBT,  INCLUDING  SECURED  DEBT,  AND  WE  MAY  LOSE  THE
ABILITY TO OBTAIN FUTURE FINANCING AND SUFFER COMPETITIVE DISADVANTAGES.

At December 31, 2021 and 2020, our total debt was $7.17 billion and $7.81 billion, respectively, of which $2.30 billion
and  $2.77  billion,  respectively,  was  secured.   We  have  a  bank  credit  agreement,  as  amended,  that  established  a  $1.33  billion
secured revolving credit facility (the “Secured Credit Facility”), which is currently undrawn, the borrowings under which would
be secured.  This substantial level of debt and other obligations could have significant adverse consequences on our business
and future prospects, including the following:

◾ we may be unable to obtain financing in the future to refinance our existing debt or for working capital, capital expenditures,

acquisitions, debt service requirements, distributions, share repurchases, or other purposes;

◾ we may be unable to use operating cash flow in other areas of our business because we must dedicate a substantial portion of

these funds to service the debt;

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◾ we could become more vulnerable to general adverse economic and industry conditions, including increases in interest rates,

particularly given our substantial indebtedness, some of which bears interest at variable rates;

◾ we may be unable to meet financial ratios in the agreements governing certain of our debt and finance lease or satisfy certain
other covenants and conditions included in our debt agreements, which could result in our inability to meet requirements for
borrowings under our credit agreement or a default under these agreements, impose restrictions with respect to our access to
certain of our capital, and trigger cross default provisions in our other debt instruments;

◾ if  we  default  under  the  terms  of  our  secured  financing  arrangements,  the  secured  debtholders  may,  among  other  things,

foreclose on the collateral securing the debt, including the applicable drilling units;

◾ we may be unable to obtain new investment or financing given recent environmental, social and governance influenced trends
among many financial intermediaries, investors and other capital markets participants in reducing, or ceasing, lending to, or
investing in, companies that operate in industries with higher perceived environmental exposure; and

◾ we  may  be  less  able  to  take  advantage  of  significant  business  opportunities  and  to  react  to  changes  in  market  or  industry

conditions than our less levered competitors.

See “Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations—Liquidity and

Capital Resources—Sources and uses of liquidity.”

CREDIT  RATING  AGENCIES  HAVE  RATED  OUR  DEBT  BELOW  INVESTMENT  GRADE,  WHICH  COULD
LIMIT OUR ACCESS TO CAPITAL AND HAVE AN ADVERSE EFFECT ON OUR BUSINESS AND FINANCIAL
CONDITION.

The ratings assigned to our debt securities by certain credit rating agencies (our “Debt Ratings”) are below investment
grade.  Our Debt Ratings could have adverse consequences for our business and future prospects and could cause the following:
◾ limitations on our ability to access debt markets, including for the purpose of refinancing our existing debt and replacing or

extending our Secured Credit Facility;

◾ less favorable terms and conditions on any refinancing arrangements, debt issuances or bank credit agreements, some of which

could require collateral and restrict, among other things, our ability to pay distributions or repurchase shares;

◾ increases to certain fees under our Secured Credit Facility and interest rates under indentures governing certain of our senior
notes, which in the case of the 3.80% senior notes due October 2022 and the 7.35% senior notes due December 2041, have
reached  the  maximum  rate  increase  of  2  percent  pursuant  to  the  related  indentures  due  to  the  downgrades  of  certain  credit
rating agencies;

◾ reduced willingness of current and prospective customers, suppliers and creditors to transact business with us;
◾ requirements from creditors, suppliers or customers for additional insurance, guarantees and collateral;
◾ limitations on our access to bank and third-party guarantees, surety bonds and letters of credit; and
◾ reductions to or eliminations of the level of credit suppliers and financial institutions may provide through payment terms or
intraday funding when dealing with us thereby increasing the need for higher levels of cash on hand, which would decrease
our ability to repay debt balances.

Our Debt Ratings have caused some of the effects listed above, and any further downgrades may cause or exacerbate,

any of the effects listed above and could have an adverse effect on our business and financial condition.

WORLDWIDE  FINANCIAL,  ECONOMIC  AND  POLITICAL  CONDITIONS  COULD  RESTRICT  OUR  ABILITY
TO ACCESS THE CAPITAL MARKETS, REDUCE OUR FLEXIBILITY TO REACT TO CHANGING ECONOMIC
AND BUSINESS CONDITIONS AND REDUCE DEMAND FOR OUR SERVICES.

Worldwide financial and economic conditions could restrict our ability to access the capital markets at a time when we
would like, or need, to access such markets, which could have an impact on our flexibility to react to changing economic and
business  conditions.   Worldwide  economic  conditions  have  in  the  past  impacted,  and  could  in  the  future  impact,  the  lenders
participating  in  our  credit  facilities  and  our  customers,  causing  them  to  fail  to  meet  their  obligations  to  us.    If  economic
conditions  preclude  or  limit  financing  from  banking  institutions  participating  in  our  credit  facilities,  we  may  not  be  able  to
obtain similar financing from other institutions.  A slowdown in economic activity could further reduce worldwide demand for
energy  and  extend  or  worsen  the  recovery  from  low  oil  and  natural  gas  prices.    These  potential  developments,  or  market
perceptions  concerning  these  and  related  issues,  could  adversely  affect  our  financial  position,  results  of  operations  or  cash
flows.  In addition, turmoil and hostilities in the Middle East, North Africa and other geographic areas and countries present
incremental risk.  An extended period of negative outlook for the world economy could further reduce the overall demand for
oil and natural gas and for our services.  A further decline in oil and natural gas prices or an extension of the current low oil and
natural gas prices could reduce demand for our drilling services and have an adverse effect on our financial position, results of
operations or cash flows.

RISKS RELATED TO LAWS, REGULATIONS AND GOVERNMENTAL COMPLIANCE

IMPACT OF INCREASINGLY STRINGENT ENVIRONMENTAL AND SAFETY LAWS AND OUR COMPLIANCE
WITH OR BREACH OF SUCH LAWS CAN BE COSTLY, EXPOSE US TO LIABILITY AND COULD LIMIT OUR
OPERATIONS.

Our  business  is  affected  by  laws  and  regulations  relating  to  the  energy  industry  and  the  environment  and  safety,
including international conventions and treaties, and regional, national, state, and local laws and regulations.  Our business also
depends  on  demand  for  services  from  the  oil  and  gas  exploration  and  production  industry,  and,  accordingly,  we  are  directly
affected  by  the  adoption  of  laws  and  regulations  that,  for  economic,  environmental  or  other  policy  reasons,  curtail,  delay  or
impose  additional  compliance  costs  and  obligations  related  to  the  exploration  and  development  drilling  for  oil  and  gas.
  Offshore  drilling  in  certain  areas  has  been  curtailed  and,  in  certain  cases,  prohibited  because  of  environmental  or  safety
concerns.    In  addition,  compliance  with  environmental  and  safety  laws,  regulations  and  standards,  where  applicable,  may
require us to make significant capital expenditures, such as the installation of costly equipment or

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implementation  of  operational  changes,  and  may  affect  the  resale  values  or  useful  lives  of  our  rigs.    We  may  also  incur
additional costs in order to comply with other existing and future regulatory obligations or industry standards, including, but not
limited  to,  costs  relating  to  air  emissions,  including  greenhouse  gases,  the  management  of  ballast  waters,  maintenance  and
inspection,  development  and  implementation  of  emergency  procedures  and  maintenance  of  insurance  coverage  or  other
financial  assurance  of  our  ability  to  address  pollution  incidents.    In  the  last  decade,  enhanced  governmental  safety  and
environmental requirements applicable to our operations were adopted by U.S. federal agencies for drilling in the U.S. Gulf of
Mexico that have caused, and may in the future cause, operators to have difficulties obtaining drilling permits in the U.S. Gulf
of  Mexico.    In  addition,  the  oil  and  gas  industry  has  adopted  equipment  and  operating  standards,  such  as  the  American
Petroleum  Institute  Standard  53,  related  to  the  installation  and  testing  of  well  control  equipment.   A  failure  to  comply  with
applicable  laws  and  regulations  may  result  in  administrative  and  civil  penalties,  criminal  sanctions  or  the  suspension  or
termination  of  our  operations.   Additionally,  our  customers  may  elect  to  voluntarily  comply  with  any  non-mandatory  laws,
regulations  or  other  standards.    Any  such  safety,  environmental  and  other  regulatory  restrictions  or  standards,  including
voluntary customer compliance with respect thereto, could decrease, disrupt or delay operations, decrease demand for offshore
drilling services, increase operating costs and compliance costs or penalties, increase out-of-service time, decrease dayrates, or
reduce the area of operations for drilling rigs in the U.S. and non-U.S. offshore areas.  Any such effects could have an adverse
effect on our financial position, results of operations or cash flows.

To the extent new laws are enacted, existing laws are changed or other governmental actions are taken that prohibit or
restrict offshore drilling or impose additional environmental protection and safety requirements that result in increased costs to
the oil and gas industry, in general, or the offshore drilling industry, in particular, our business or prospects could be materially
adversely affected.  The operation of our drilling rigs will require certain governmental approvals, some of which may involve
public hearings and costly undertakings on our part.  We may not obtain such approvals or such approvals may not be obtained
in a timely manner.  If we fail to timely secure the necessary governmental approvals or permits, our customers may have the
right to terminate or seek to renegotiate their drilling contracts to our detriment.  The amendment or modification of existing
laws and regulations or the adoption of new laws and regulations curtailing or further regulating exploratory or development
drilling or production of oil and gas and compliance with any such new or amended legislation or regulations could have an
adverse effect on our business or on our financial position, results of operations or cash flows.

As  a  contract  driller  with  operations  in  certain  offshore  areas,  we  may  be  liable  for  damages  and  costs  incurred  in
connection with oil spills or disposal of wastes related to those operations, and we may also be subject to significant fines and
other liabilities in connection with spills.  For example, an oil spill could result in significant liability, including fines, penalties
and criminal liability and remediation, restoration or compensation costs for environmental or natural resource damages, as well
as third-party damages, to the extent that the contractual indemnification provisions in our drilling contracts are not enforceable
or  otherwise  sufficient,  or  if  our  customers  are  unwilling  or  unable  to  contractually  indemnify  us  against  these  risks.
 Additionally, we may not be able to obtain such indemnities in our future drilling contracts, and our customers may not have
the financial capability to fulfill their contractual obligations to us.  Also, these indemnities may be held to be unenforceable in
certain jurisdictions, as a result of public policy or for other reasons.  Environmental and safety laws and regulations protecting
the environment have become increasingly stringent and may in some cases impose strict liability on facility or vessel owners or
operators, rendering a person liable for environmental damage without regard to negligence.  These laws and regulations may
expose us to liability for the conduct of, or conditions caused by, others or for acts that were in compliance with all applicable
laws at the time they were performed.  The application of these requirements or the adoption of new requirements or measures
could have an adverse effect on our financial position, results of operations or cash flows.

REGULATORY AND VARIOUS OTHER RISKS, INCLUDING LITIGATION, ASSOCIATED WITH GREENHOUSE
GASES  AND  CLIMATE  CHANGE  COULD  HAVE  AN  ADVERSE  IMPACT  ON  OUR  BUSINESS  AND  DEMAND
FOR OUR SERVICES.

Scientific studies have suggested that emissions of certain gases, including greenhouse gases, such as carbon dioxide
and methane, contribute to warming of the earth’s atmosphere and other climatic changes.  In response to such studies, the issue
of climate change and the effect of greenhouse gas emissions, in particular emissions from the fossil fuel industry, has attracted
considerable attention worldwide.  The attention to climate change has led, and we expect it to continue to lead, to additional
regulations designed to reduce greenhouse gas emissions domestically and internationally.  Such attention could also result in
other  adverse  impacts  for  the  oil  and  gas  industry,  including  further  restrictions  or  bans  imposed  by  lawmakers,  lawsuits  by
governments  or  third-parties  seeking  recoveries  for  damages  resulting  from  the  combustion  of  fuels  that  may  contribute  to
climate change effects, or reduced interest from investors if they elect in the future to shift some or all of their investments to
non-fossil fuel related sectors.  To the extent financial markets view climate change and greenhouse emissions as a financial
risk, this could negatively impact our cost of or access to capital.  Because our business depends on the level of activity in the
oil and gas industry, existing or future laws, regulations, treaties or international agreements related to greenhouse gases and
climate change, or related political, litigation or financial risks, including incentives to conserve energy or use alternative energy
sources, could have a negative impact on our business if such laws, regulations, treaties or international agreements reduce the
worldwide demand for oil and gas or limit drilling opportunities.  In addition, such laws, regulations, treaties or international
agreements or related risks could result in increased compliance costs or additional operating restrictions, which may have an
adverse effect on our business.  Further, some experts believe global climate change could increase the frequency and severity
of extreme weather conditions, the impacts of which could interfere with our operations, cause damage to our equipment as well
as cause other financial and operational impacts, including those that could result from any impact of such conditions on our
customers.

We could also face increased climate-related litigation with respect to our operations both in the U.S. and around the
world.  Governmental and other entities in various U.S. states, such as California and New York, have filed lawsuits against
coal, gas oil and

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petroleum  companies.    These  suits  allege  damages  as  a  result  of  climate  change,  and  the  plaintiffs  are  seeking  unspecified
damages and abatement under various tort theories.  Similar lawsuits may be filed in other jurisdictions both in the U.S. and
globally.  Though we are not currently a party to any such lawsuit, these suits present a high degree of uncertainty regarding the
extent to which energy companies, including offshore drillers, face an increased risk of liability stemming from climate change,
which risk would also adversely impact the oil and gas industry and impact demand for our services.

THE GLOBAL NATURE OF OUR OPERATIONS INVOLVES ADDITIONAL RISKS.

We  operate  in  various  regions  throughout  the  world,  which  may  expose  us  to  political  and  other  uncertainties,

including risks of:

◾ terrorist acts, war, piracy and civil unrest;
◾ seizure, expropriation or nationalization of our equipment;
◾ expropriation or nationalization of our customers’ property;
◾ repudiation or nationalization of contracts;
◾ imposition of trade or immigration barriers;
◾ import-export quotas;
◾ wage and price controls;
◾ changes in law and regulatory requirements, including changes in interpretation and enforcement;
◾ involvement in judicial proceedings in unfavorable jurisdictions;
◾ damage to our equipment or violence directed at our employees, including kidnappings;
◾ complications associated with supplying, repairing and replacing equipment in remote locations;
◾ the inability to move income or capital; and
◾ currency exchange fluctuations and currency exchange restrictions, including exchange or similar controls that may limit our

ability to convert local currency into U.S. dollars and transfer funds out of a local jurisdiction.

Our non-U.S. contract drilling operations are subject to various laws and regulations in certain countries in which we
operate, including laws and regulations relating to the import and export, equipment and operation of drilling units, currency
conversions and repatriation, oil and gas exploration and development, taxation and social contributions of offshore earnings
and earnings of expatriate personnel.  We are also subject to the U.S. Treasury Department’s Office of Foreign Assets Control
(“OFAC”) and other U.S. and non-U.S. laws and regulations governing our international operations.  In addition, various state
and  municipal  governments,  universities  and  other  investors  have  proposed  or  adopted  divestment  and  other  initiatives
regarding investments including, with respect to state governments, by state retirement systems in companies that do business
with countries that have been designated as state sponsors of terrorism by the U.S. State Department.  Failure to comply with
applicable  laws  and  regulations,  including  those  relating  to  sanctions  and  export  restrictions,  may  subject  us  to  criminal
sanctions or civil remedies, including fines, denial of export privileges, injunctions or seizures of assets.  Investors could view
any  potential  violations  of  OFAC  regulations  negatively,  which  could  adversely  affect  our  reputation  and  the  market  for  our
shares.

Governments  in  some  countries  have  become  increasingly  active  in  regulating  and  controlling  the  ownership  of
concessions and companies holding concessions, the exploration for oil and gas and other aspects of the oil and gas industries in
their  countries,  including  local  content  requirements  for  participating  in  tenders  for  certain  drilling  contracts.    Many
governments favor or effectively require the awarding of drilling contracts to local contractors or require nonlocal contractors to
employ citizens of, or purchase supplies from, a particular jurisdiction or require use of a local agent.  In addition, government
action,  including  initiatives  by  OPEC,  may  continue  to  cause  oil  or  gas  price  volatility.    In  some  areas  of  the  world,  this
governmental activity has adversely affected the amount of exploration and development work by major energy companies and
may continue to do so.

The shipment of goods, services and technology across international borders subjects us to extensive trade laws and
regulations.    Our  import  and  export  activities  are  governed  by  unique  customs  laws  and  regulations  in  each  of  the  countries
where we operate.  Moreover, many countries, including the U.S., control the import and export of certain goods, services and
technology  and  impose  related  import  and  export  recordkeeping  and  reporting  obligations.    Governments  also  may  impose
economic sanctions against certain countries, persons and other entities that may restrict or prohibit transactions involving such
countries, persons and entities, and we are also subject to the U.S. anti-boycott law.

The  laws  and  regulations  concerning  import  and  export  activity,  recordkeeping  and  reporting,  import  and  export
control and economic sanctions are complex and constantly changing.  These laws and regulations may be enacted, amended,
enforced  or  interpreted  in  a  manner  materially  impacting  our  operations.    Ongoing  economic  challenges  may  increase  some
governments’ efforts to enact, enforce, amend or interpret laws and regulations as a method to increase revenue.  Shipments can
be delayed and denied import or export for a variety of reasons, some of which are outside our control and some of which may
result from failure to comply with existing legal and regulatory regimes.  Shipping delays or denials could cause unscheduled
operational downtime.

Our  ability  to  operate  worldwide  depends  on  our  ability  to  obtain  the  necessary  visas  and  work  permits  for  our
personnel to travel in and out of, and to work in, the jurisdictions in which we operate.  Governmental actions in some of the
jurisdictions  in  which  we  operate  may  make  it  difficult  for  us  to  move  our  personnel  in  and  out  of  these  jurisdictions  by
delaying or withholding the approval of these permits.  If we are not able to obtain visas and work permits for the employees we
need to conduct our operations on a timely basis, we might not be able to perform our obligations under our drilling contracts,
which could allow our customers to cancel the contracts.  If our customers cancel some of our drilling contracts, and we are
unable to secure new drilling contracts on a timely basis and on substantially similar terms, it could have a material adverse
effect on our business and on our financial position, results of operations or cash flows.

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FAILURE  TO  COMPLY  WITH  ANTI-BRIBERY  STATUTES,  SUCH  AS  THE  U.S.  FOREIGN  CORRUPT
PRACTICES  ACT  AND  THE  U.K.  BRIBERY  ACT  2010,  COULD  RESULT  IN  FINES,  CRIMINAL  PENALTIES,
DRILLING CONTRACT TERMINATIONS AND AN ADVERSE EFFECT ON OUR BUSINESS.

The U.S. Foreign Corrupt Practices Act (“FCPA”), the U.K. Bribery Act 2010 (“Bribery Act”) and similar anti-bribery
laws  in  other  jurisdictions,  generally  prohibit  companies  and  their  intermediaries  from  making  improper  payments  for  the
purpose of obtaining or retaining business.  We operate in many parts of the world that have experienced corruption to some
degree and, in certain circumstances, strict compliance with anti-bribery laws may conflict with local customs and practices.  If
we  are  found  to  be  liable  for  violations  under  the  FCPA,  the  Bribery  Act  or  other  similar  laws,  either  due  to  our  acts  or
omissions or due to the acts or omissions of others, including our partners in our various joint ventures and of the current or
former officers, directors or employees of any companies we have acquired, we could suffer from civil and criminal penalties or
other sanctions, which could have a material adverse effect on our business or our financial position, results of operations or
cash flows.  In addition, investors could negatively view potential violations, inquiries or allegations of misconduct under the
FCPA, the Bribery Act or similar laws, which could adversely affect our reputation and the market for our shares.

We could also face fines, sanctions and other penalties from authorities in relevant jurisdictions, including prohibition
of  our  participating  in  or  curtailment  of  business  operations  in  those  jurisdictions  and  the  seizure  of  rigs  or  other  assets.
 Additionally,  our  business  and  results  of  operations  could  be  adversely  affected  as  a  result  of  claims  by  customers,  agents,
shareholders,  debt  holders,  other  interest  holders,  current  or  former  employees  or  other  constituents  of  our  company  who,  in
connection  with  alleged  or  actual  noncompliance  with  antibribery  and  related  laws,  may  seek  to  impose  penalties,  seek
remedies, terminate drilling contracts or take other actions adverse to our interests.  Our business and results of operations may
be  adversely  affected  if  we  are  required  to  dedicate  significant  time  and  resources  to  investigate  and  resolve  allegations  of
misconduct,  regardless  of  the  merit  of  such  allegations.    Further,  disclosure  of  the  subject  matter  of  any  investigation  could
adversely affect our reputation and our ability to obtain new business with potential customers, to retain existing business with
our current customers, to attract and retain employees and to access the capital markets.

WE ARE SUBJECT TO INVESTIGATIONS AND LITIGATION THAT, IF NOT RESOLVED IN OUR FAVOR AND
NOT SUFFICIENTLY INSURED AGAINST, COULD HAVE A MATERIAL ADVERSE EFFECT ON US.

We are subject to a variety of disputes, investigations and litigation.  Certain of our subsidiaries are subject to and have
been  involved  in  litigation  with  certain  of  our  customers  and  other  constituents.    Certain  of  our  subsidiaries  are  named  as
defendants in numerous lawsuits alleging personal grievances or injury, including as a result of exposure to asbestos or toxic
fumes  or  resulting  from  other  occupational  diseases,  such  as  silicosis,  and  various  other  medical  issues  that  can  remain
undiscovered for a considerable amount of time.  Some of these subsidiaries that have been put on notice of potential liabilities
have  no  assets.    Certain  subsidiaries  are  subject  to  litigation  relating  to  environmental  damage.    Our  patent  for  dual-activity
technology has been successfully challenged in certain jurisdictions.  We are also subject to a number of significant tax disputes.
 We cannot predict the outcome of these investigations and cases or the potential costs to resolve them.  Insurance may not be
applicable or sufficient in all cases, insurers may not remain solvent and policies may not be located.  Suits against non-asset-
owning subsidiaries have and may in the future give rise to alter ego or successor-in-interest claims against us and our asset-
owning subsidiaries to the extent a subsidiary is unable to pay a claim or insurance is not available or sufficient to cover the
claims.  To the extent that one or more pending or future investigations or litigation matters is not resolved in our favor and is
not  covered  by  insurance,  which  could  have  a  material  adverse  effect  on  our  financial  position,  results  of  operations  or  cash
flows.

WE  ARE  SUBJECT  TO  CYBERSECURITY  RISKS  AND  THREATS  AS  WELL  AS  INCREASING  REGULATION
OF DATA PRIVACY AND SECURITY.

We depend on data and digital technologies to conduct our offshore and onshore operations, to collect payments from
customers and to pay vendors and employees.  Our data protection measures and measures taken by our customers and vendors
may not prevent unauthorized access of information technology systems, and when such unauthorized access occurs, we, our
customers or vendors may not detect the incident in time to prevent harm or damage.  Threats to our information technology
systems,  and  the  systems  of  our  customers  and  vendors,  associated  with  cybersecurity  risks  and  cyber-incidents  or  attacks
continue to grow.  Such threats may derive from human error, fraud or malice, social engineering on the part of employees or
third  parties,  or  may  result  from  accidental  technological  failure.    In  addition,  breaches  to  our  systems  and  systems  of  our
customers and vendors could go unnoticed for some period of time.  Risks associated with these threats include disruptions of
certain systems on our rigs; other impairments of our ability to conduct our operations; loss or ransom of intellectual property,
proprietary  information,  personal  identifiable  information  or  customer  and  vendor  data;  disruption  of  our  customers’  and
vendors’  operations;  misappropriation  of  assets;  loss  or  damage  to  our  customer  and  vendor  data  delivery  systems;  and
increased costs to prevent, respond to or mitigate cybersecurity events.  A breach could also originate from, or compromise, our
customers’  and  vendors’  or  other  third-party  networks  outside  of  our  control.   A  breach  may  also  result  in  legal  claims  or
proceedings against us by our shareholders, employees, customers, vendors and governmental authorities, both U.S. and non-
U.S.  If such a cyber-incident were to occur, it could have a material adverse effect on our business or on our financial position,
results of operations or cash flows.

In  addition,  laws  and  regulations  governing  data  privacy  and  the  unauthorized  disclosure  of  personal  data  and
confidential  information,  including  the  European  Union  General  Data  Protection  Regulation,  the  Data  Protection  Law,  as
revised,  of  the  Cayman  Islands,  the  General  Data  Protection  Law  of  Brazil  and  the  California  Consumer  Privacy  Act,  pose
increasingly complex compliance challenges and potential to elevate our costs.  Any failure by us to comply with these laws and
regulations, including as a result of a security or privacy

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breach,  could  result  in  significant  penalties,  litigation  and  liabilities  for  us.   Additionally,  if  we  acquire  a  company  that  has
violated  or  is  not  in  compliance  with  applicable  data  protection  laws,  we  may  incur  significant  liabilities  and  penalties  as  a
result.

ACTS  OF  TERRORISM,  PIRACY  AND  POLITICAL  AND  SOCIAL  UNREST  COULD  AFFECT  THE  MARKETS
FOR DRILLING SERVICES.

Acts of terrorism and social unrest, brought about by world political events or otherwise, have caused instability in the
world’s financial and insurance markets in the past and may occur in the future.  Such acts could be directed against companies
such as ours.  In addition, acts of terrorism, piracy and social unrest could lead to increased volatility in prices for crude oil and
natural  gas  and  could  affect  the  markets  for  drilling  services.    Insurance  premiums  could  increase  and  coverage  may  be
unavailable in the future.  Government regulations may effectively preclude us from engaging in business activities in certain
countries.  These regulations could be amended to cover countries where we currently operate or where we may wish to operate
in the future.  Our drilling contracts do not generally provide indemnification against loss of capital assets or loss of revenues
resulting from acts of terrorism, piracy or political or social unrest.  We have limited insurance for our assets providing coverage
for  physical  damage  losses  resulting  from  certain  risks,  such  as  terrorist  acts,  piracy,  vandalism,  sabotage,  civil  unrest,
expropriation and acts of war, and we do not carry insurance for loss of revenues resulting from such risks.

RISKS RELATED TO TAXES

A CHANGE IN TAX LAWS, TREATIES OR REGULATIONS, OR THEIR INTERPRETATION, OF ANY COUNTRY
IN  WHICH  WE  HAVE  OPERATIONS,  ARE  INCORPORATED  OR  ARE  RESIDENT  COULD  RESULT  IN  A
HIGHER  EFFECTIVE  TAX  RATE  ON  OUR  CONSOLIDATED  EARNINGS  AND  INCREASE  OUR  CASH  TAX
PAYMENTS.

We are subject to changes in applicable tax laws, treaties or regulations in the jurisdictions in which we operate and
earn income, and such changes could include laws or policies directed toward companies organized in jurisdictions with low tax
rates with the intent to increase the tax burden.  The Organization for Economic Co-operation and Development, for example,
issued  its  action  plan  of  tax  reform  measures  that  called  for  member  states  to  take  action  to  prevent  base  erosion  and  profit
shifting.  Some of these measures impact transfer pricing, requirements to qualify for tax treaty benefits, and the definition of
permanent establishments depending on each jurisdiction’s adoption and interpretation of such proposals.  Respective countries,
including  Switzerland,  have  adopted  various  measures  into  their  own  tax  laws.    In  addition,  the  EU  has  issued  Anti-Tax
Avoidance  Directives  and  proposed  directives  that  required  or  require  member  states  to  adopt  specific  tax  reform  measures,
some of which relate to a 15 percent minimum tax.  Other tax jurisdictions in which we operate may consider implementing
similar measures.  Any material change to tax laws, treaties, regulations or policies, their interpretation or application, or the
adoption of new interpretations of existing laws and rulings, in any of the jurisdictions in which we operate, are incorporated or
resident, could result in a higher effective tax rate on our worldwide earnings and such change could have a significant adverse
effect on our financial position, results of operations or cash flows.

A  LOSS  OF  A  MAJOR  TAX  DISPUTE  OR  A  SUCCESSFUL  TAX  CHALLENGE  TO  OUR  OPERATING
STRUCTURE,  INTERCOMPANY  PRICING  POLICIES  OR  THE  TAXABLE  PRESENCE  OF  OUR  KEY
SUBSIDIARIES  IN  CERTAIN  COUNTRIES  COULD  RESULT  IN  A  HIGHER  EFFECTIVE  TAX  RATE  ON  OUR
CONSOLIDATED EARNINGS AND INCREASE OUR CASH TAX PAYMENTS.

We are subject to tax laws, treaties and regulations in the countries in which we operate and earn income.  Our income
taxes are based on the applicable tax laws and tax rates in effect in the countries in which we operate and earn income as well as
upon  our  operating  structures  in  these  countries.    Our  income  tax  returns  are  subject  to  review  and  examination  in  these
jurisdictions, and we do not recognize the benefit of income tax positions we believe are more likely than not to be disallowed
upon challenge by a tax authority.  If any tax authority successfully challenges our operational structure, intercompany pricing
policies or the taxable presence of our key subsidiaries in certain countries; or if the terms of certain income tax treaties are
interpreted in a manner that is adverse to our structure; or if we lose a material tax dispute in any country, our effective tax rate
on our worldwide earnings could increase substantially and our earnings and cash flows from operations could be materially
adversely affected.  For example, we believe that neither we nor our non-U.S. subsidiaries, other than those that report a U.S.
trade or business or a U.S. permanent establishment, were or are engaged in a trade or business in the U.S. or, if applicable,
maintained or maintain a permanent establishment in the U.S.  The determination of the aforementioned, among other things,
involves considerable uncertainty.  If the U.S. Internal Revenue Service (the “IRS”) were to disagree, then we could be subject
to additional U.S. corporate income and branch profits taxes on the portion of our earnings effectively connected to such U.S.
business or, if applicable, attributable to such U.S. permanent establishment during the period in which this was considered to
have occurred.  If this occurs, our effective tax rate on worldwide earnings for that period could increase substantially, we could
be subject to assessments in previously filed returns that remain open to audit and our earnings and cash flows from operations
for that period could be adversely affected.

U.S.  TAX  AUTHORITIES  COULD  TREAT  US  AS  A  PASSIVE  FOREIGN  INVESTMENT  COMPANY,  WHICH
WOULD HAVE ADVERSE U.S. FEDERAL INCOME TAX CONSEQUENCES TO U.S. SHAREHOLDERS.

A foreign corporation will be treated as a passive foreign investment company (“PFIC”) for U.S. federal income tax
purposes if either (1) at least 75 percent of its gross income for any taxable year consists of certain types of passive income or
(2) at least 50 percent of the average value of the corporation's assets produce or are held for the production of those types of
passive income.  For purposes of these tests, passive income includes dividends, interest and gains from the sale or exchange of
investment property and certain rents and royalties, but does not include income derived from performing services.  We believe
that  we  have  not  been  and  will  not  be  a  PFIC  with  respect  to  any  taxable  year.    Our  income  from  offshore  contract  drilling
services should be treated as services income for purposes of determining whether

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we  are  a  PFIC.   Accordingly,  we  believe  that  our  income  from  our  offshore  contract  drilling  services  should  not  constitute
passive income, and the assets that we own and operate in connection with the production of that income should not constitute
passive assets.  There is significant legal authority supporting this position, including statutory provisions, legislative history,
case  law  and  IRS  pronouncements  concerning  the  characterization,  for  other  tax  purposes,  of  income  derived  from  services
where a substantial component of such income is attributable to the value of the property or equipment used in connection with
providing such services.  However, a prior case and an IRS pronouncement that relies on such case characterize income from
time  chartering  of  vessels  as  rental  income  rather  than  services  income  for  other  tax  purposes.    The  IRS  has  subsequently
formally  announced  that  it  does  not  agree  with  the  decision  in  that  case.    Moreover,  we  believe  that  the  terms  of  the  time
charters  in  the  prior  case  differ  in  material  respects  from  the  terms  of  our  drilling  contracts  with  customers.    However,  no
assurance can be given that the IRS or a court will accept our position, and there is a risk that the IRS or a court could determine
that we are a PFIC.

If we were treated as a PFIC for any taxable year, our U.S. shareholders would face adverse U.S. tax consequences.
  Under  the  PFIC  rules,  unless  a  shareholder  makes  certain  elections  available  under  the  Internal  Revenue  Code  of  1986,  as
amended, which elections could themselves have adverse consequences for the shareholder, the shareholder could be required to
pay  U.S.  federal  income  tax  at  the  highest  applicable  income  tax  rates  on  ordinary  income  upon  the  receipt  of  excess
distributions,  as  defined  for  U.S.  tax  purposes,  and  upon  any  gain  from  the  disposition  of  our  shares,  plus  interest  on  such
amounts, as if such excess distribution or gain had been recognized ratably over the shareholder’s holding period of our shares.
 Additionally,  under  applicable  statutory  provisions,  the  preferential  tax  rate  on  qualified  dividend  income,  which  applies  to
dividends  paid  to  non-corporate  shareholders,  does  not  apply  to  dividends  paid  by  a  foreign  corporation  if  the  foreign
corporation is a PFIC for the taxable year in which the dividend is paid or the preceding taxable year.

RISKS RELATED TO OUR JURISDICTION OF ORGANIZATION AND GOVERNING DOCUMENTS

AS A SWISS CORPORATION, OUR FLEXIBILITY MAY BE LIMITED WITH RESPECT TO CERTAIN ASPECTS
OF CAPITAL MANAGEMENT AND SWIFT IMPLEMENTATION OF CERTAIN INITIATIVES OR STRATEGIES.

Under Swiss law, our shareholders may approve an authorized share capital that allows the board of directors to issue
new shares without additional shareholder approval within a period of up to two years and for up to a maximum of 50 percent of
a company’s issued share capital.  The authorized share capital approved by our shareholders at the May 2021 annual general
meeting will expire on May 27, 2023.  Our currently available authorized share capital is limited to approximately 22 percent of
our issued share capital as of February 14, 2022.  Accordingly, shareholders at our annual general meeting in May 2022 may be
requested to approve a renewal and an increase in authorized share capital.  Subject to certain exceptions, Swiss law also grants
preemptive  rights  to  existing  shareholders  to  subscribe  for  new  issuances  of  shares.    Further,  Swiss  law  does  not  provide  as
much flexibility in the various terms that can attach to different classes of shares as the laws of some other jurisdictions.  Swiss
law  also  reserves  for  shareholder  approval  certain  corporate  actions,  such  as  approval  of  dividends,  over  which  a  board  of
directors would have authority in some other jurisdictions.  These Swiss law requirements relating to our capital management
may limit our flexibility to swiftly implement certain initiatives or strategies, and situations may arise where greater flexibility
would have provided substantial benefits to our shareholders.

We are required, from time to time, to evaluate the carrying amount of our investments in affiliates, as presented on our
Swiss standalone balance sheet.  If we determine that the carrying amount of any such investment exceeds its fair value, we may
conclude that such investment is impaired.  Any recognized loss associated with such a non-cash impairment could result in our
net assets no longer covering our statutory share capital and statutory capital reserves.  Under Swiss law, if our net assets cover
less than 50 percent of our statutory share capital and statutory capital reserves, the board of directors must convene a general
meeting  of  shareholders  and  propose  measures  to  remedy  such  a  capital  loss.   Appropriate  measures  depend  on  the  relevant
circumstances  and  the  magnitude  of  the  recognized  loss  and  may  include  seeking  shareholder  approval  for  offsetting  the
aggregate loss, or a portion thereof, with our statutory capital reserves, including qualifying additional paid-in capital otherwise
available for distributions to shareholders, or raising new equity.  Depending on the circumstances, we may also need to use
qualifying additional paid-in capital available for distributions in order to reduce our accumulated net loss and such use might
reduce our ability to make distributions without subjecting our shareholders to Swiss withholding tax.

Distributions  to  shareholders  in  the  form  of  a  par  value  reduction  and  dividend  distributions  out  of  qualifying
additional  paid-in  capital  are  currently  not  subject  to  the  35  percent  Swiss  federal  withholding  tax.    However,  the  Swiss
withholding  tax  rules  could  be  changed  in  the  future,  and  any  such  change  may  adversely  affect  us  or  our  shareholders.    In
addition, over the long term, the amount of par value available for us to use for par value reductions or the amount of qualifying
additional paid-in capital available for us to pay out as distributions is limited.  If we are unable to make a distribution through a
reduction in par value, or out of qualifying additional paid-in capital as shown on Transocean Ltd.’s standalone Swiss statutory
financial statements, we may not be able to make distributions without subjecting our shareholders to Swiss withholding taxes.

Under  Swiss  tax  law,  repurchases  of  shares  for  the  purposes  of  capital  reduction  are  treated  as  a  partial  liquidation
subject to a 35 percent Swiss withholding tax based on the difference between the repurchase price and the related amount of
par  value  and  the  related  amount  of  qualifying  additional  paid-in  capital,  if  any.   At  our  2009  annual  general  meeting,  our
shareholders  approved  the  repurchase  of  up  to  CHF  3.5  billion  of  our  shares  for  cancellation  under  the  share  repurchase
program.    If  we  repurchase  shares,  we  expect  to  use  an  alternative  procedure  pursuant  to  which  we  repurchase  shares  via  a
“virtual second trading line” from market players, such as banks and institutional investors, who are generally entitled to receive
a  full  refund  of  the  Swiss  withholding  tax.    The  use  of  such  “virtual  second  trading  line”  with  respect  to  share  repurchase
programs is subject to the approval of the competent Swiss tax and other authorities.  We may not be

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able  to  repurchase  as  many  shares  as  we  would  like  to  repurchase  for  purposes  of  capital  reduction  on  the  “virtual
second trading line” without subjecting the selling shareholders to Swiss withholding taxes.

WE ARE SUBJECT TO ANTI-TAKEOVER PROVISIONS.

Our articles of association and Swiss law contain provisions that could prevent or delay an acquisition of the company
by means of a tender offer, a proxy contest or otherwise.  Actions taken under such provisions may adversely affect prevailing
market prices for our shares, and could, among other things:

◾ provide that the board of directors is authorized, subject to obtaining shareholder approval every two years, at any time during
a  maximum  two-year  period,  which  under  our  current  authorized  share  capital  will  expire  on  May  27,  2023,  to  issue  a
specified number of shares, which under our current authorized share capital is approximately 22 percent of the share capital
registered  in  the  commercial  register  as  of  February  14,  2022,  and  to  limit  or  withdraw  the  preemptive  rights  of  existing
shareholders in various circumstances;

◾ provide  for  a  conditional  share  capital  that  authorizes  the  issuance  of  additional  shares  up  to  a  maximum  amount  of
approximately 20 percent of the share capital registered in the commercial register as of February 14, 2022, without obtaining
additional  shareholder  approval  through:  (1)  the  exercise  of  conversion,  exchange,  option,  warrant  or  similar  rights  for  the
subscription  of  shares  granted  in  connection  with  bonds,  options,  warrants  or  other  securities  newly  or  already  issued  in
national or international capital markets or new or already existing contractual obligations by or of any of our subsidiaries; or
(2) in connection with the issuance of shares, options or other share-based awards;

◾ provide that any shareholder who wishes to propose any business or to nominate a person or persons for election as director at

any annual meeting may only do so if we are given advance notice;

◾ provide that directors can be removed from office only by the affirmative vote of the holders of at least 66 2/3 percent of the

shares entitled to vote;

◾ provide  that  a  merger  or  demerger  transaction  requires  the  affirmative  vote  of  the  holders  of  at  least  66  2/3  percent  of  the
shares represented at the meeting and provide for the possibility of a so-called cash-out or squeeze-out merger if the acquirer
controls 90 percent of the outstanding shares entitled to vote at the meeting;

◾ provide  that  any  action  required  or  permitted  to  be  taken  by  the  holders  of  shares  must  be  taken  at  a  duly  called  annual  or

extraordinary general meeting of shareholders;

◾ limit the ability of our shareholders to amend or repeal some provisions of our articles of association; and
◾ limit transactions between us and an “interested shareholder,” which is generally defined as a shareholder that, together with its
affiliates and associates, beneficially, directly or indirectly, owns 15 percent or more of our shares entitled to vote at a general
meeting.

ITEM 1B.UNRESOLVED STAFF COMMENTS

None.

ITEM 2. PROPERTIES

The description of our property included under “Item 1. Business” is incorporated by reference herein.  We maintain
offices, land bases and other facilities worldwide, most of which we lease, including principal executive offices in Steinhausen,
Switzerland, and corporate offices in Houston, Texas, and the Cayman Islands.  Our remaining offices and bases are located in
various countries in North America, Europe, South America, Asia and Africa.

ITEM 3. LEGAL PROCEEDINGS

We  have  certain  actions,  claims  and  other  matters  pending  as  discussed  and  reported  in  “Part  II.  Item  8.  Financial
Statements  and  Supplementary  Data—Notes 
to  Consolidated  Financial  Statements—Note  13—Commitments  and
Contingencies” and “Part II. Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
—Other  Matters—Regulatory  Matters”  in  this  annual  report  on  Form  10-K.    We  are  also  involved  in  various  tax  matters  as
described  in  “Part  II.  Item  8.  Financial  Statements  and  Supplementary  Data—Notes  to  Consolidated  Financial  Statements—
Note 11—Income Taxes” and in “Part II. Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations—Other Matters—Tax matters” in this annual report on Form 10-K.  All such actions, claims, tax and other matters
disclosed therein are incorporated herein by reference.

As of December 31, 2021, we were involved in a number of other lawsuits, regulatory matters, disputes and claims,
asserted  and  unasserted,  all  of  which  have  arisen  in  the  ordinary  course  of  our  business  and  for  which  we  do  not  expect  the
liability, if any, to have a material adverse effect on our consolidated financial position, results of operations or cash flows.  We
cannot  predict  with  certainty  the  outcome  or  effect  of  any  of  the  matters  referred  to  above  or  of  any  such  other  pending  or
threatened litigation or legal proceedings.  We can provide no assurance that our beliefs or expectations as to the outcome or
effect of any lawsuit or claim or dispute will prove correct and the eventual outcome of these matters could materially differ
from management’s current estimates.

On December 17, 2021, Transocean Offshore Deepwater Drilling Inc., our wholly owned subsidiary, received a letter
from the U.S. Department of Justice (the “DOJ”) related to alleged violations by our subsidiary of its Clean Water Act (“CWA”)
National Pollutant Discharge Elimination System permit (“Permit”).  The alleged violations, involving seven of our drillships,
were identified by the U.S. Environmental Protection Agency (“EPA”) following an initial inspection in 2018 of our compliance
with the Permit and the CWA and relate to deficiencies with respect to records retention, reporting requirements, discharges,
permit limits, inspections and maintenance, and the submission of

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monitoring  reports.    In  connection  with  the  initial  EPA  inspection,  we  initiated  modifications  to  our  Permit  and  CWA
compliance  processes  and  maintained  a  dialogue  with  the  EPA  regarding  the  design  and  implementation  of  enhancements  to
these processes.  At the DOJ’s invitation, in an effort to resolve the matter, we have initiated settlement discussions with the
DOJ, and the enforcement action will likely result in our agreeing to take or continue to take certain corrective actions to ensure
current  and  future  Permit  and  CWA  compliance  and  to  pay  a  monetary  penalty,  which  we  believe  at  this  time  would  be
immaterial.  We do not believe that the enforcement action would have a material adverse effect on our consolidated financial
position,  results  of  operations  or  cash  flow.    If  our  current  expectations  relating  to  these  costs  prove  to  be  inaccurate,  future
expenditures may exceed our accrued amounts.

In addition to the legal proceedings described above, we may from time to time identify other matters that we monitor
through our compliance program or in response to events arising generally within our industry and in the markets where we do
business.  We evaluate matters on a case by case basis, investigate allegations in accordance with our policies and cooperate
with applicable governmental authorities.  Through the process of monitoring and proactive investigation, we strive to ensure no
violation of our policies, Code of Integrity or law has occurred, or will occur; however, we can provide no assurance as to the
outcome of these matters.

ITEM 4. MINE SAFETY DISCLOSURES

Not applicable.

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INFORMATION ABOUT OUR EXECUTIVE OFFICERS

We have included the following information, presented as of February 14, 2022, on our executive officers for purposes of
U.S. securities laws in Part I of this report in reliance on General Instruction G(3) to Form 10-K.  The board of directors elects the
officers of the Company, generally on an annual basis.  There is no family relationship between any of our executive officers.

Officer
Jeremy D. Thigpen
Keelan Adamson
Howard E. Davis
Brady K. Long
Mark L. Mey
David Tonnel

(a)
(a)

(a)

  Chief Executive Officer

Office

President and Chief Operating Officer
Executive Vice President, Chief Administrative Officer and Chief Information Officer

  Executive Vice President and General Counsel
  Executive Vice President and Chief Financial Officer
  Senior Vice President and Chief Accounting Officer

Age as of
     February 14, 2022  
47
52
63
49
58
52

(a) Member of our executive management team for purposes of Swiss law.

Jeremy  D.  Thigpen  is  Chief  Executive  Officer  and  a  member  of  the  Company’s  board  of  directors.    Before  joining  the
Company  in  this  position  in  April  2015,  Mr.  Thigpen  served  as  Senior  Vice  President  and  Chief  Financial  Officer  at
National  Oilwell  Varco,  Inc.  from  December  2012  to  April  2015.    At  National  Oilwell  Varco,  Inc.,  Mr.  Thigpen  also  served  as
President, Downhole and Pumping Solutions from August 2007 to December 2012, as President of the Downhole Tools Group from
May  2003  to  August  2007  and  as  manager  of  the  Downhole  Tools  Group  from  April  2002  to  May  2003.    From  2000  to  2002,
Mr. Thigpen served as the Director of Business Development and Special Assistant to the Chairman for National Oilwell Varco, Inc.
 Mr. Thigpen earned a Bachelor of Arts degree in Economics and Managerial Studies from Rice University in 1997, and he completed
the Program for Management Development at Harvard Business School in 2001.

Keelan Adamson is President and Chief Operating Officer of the Company.  Before being named to his current position in
February 2022, Mr. Adamson served as Executive Vice President and Chief Operations Officer from August 2018 to February 2022, as
Senior Vice President, Operations from October 2017 to July 2018 and as Senior Vice President, Operations Integrity and HSE, from
June  2015  to  October  2017.    Since  2010,  Mr.  Adamson  served  in  multiple  executive  positions  with  responsibilities  spanning
Engineering and Technical Services, Major Capital Projects, Human Resources, and more recently, Operations Integrity and HSE.  Mr.
Adamson  started  his  career  as  a  drilling  engineer  with  BP  Exploration  in  1991  and  joined  Transocean  in  July  1995.    In  addition  to
several  management  assignments  in  the  U.K.,  Asia,  and  Africa,  he  also  held  leadership  roles  in  Sales  and  Marketing,  Well
Construction and Technology, and as Managing Director for operations in North America, Canada and Trinidad.  Mr. Adamson earned
a  bachelor's  degree  in  Aeronautical  Engineering  from  The  Queens  University  of  Belfast  and  completed  the  Advanced  Management
program  at  Harvard  Business  School  in  2016.    Mr. Adamson  also  currently  serves  on  the  board  of  the  National  Ocean  Industries
Association.

Howard E. Davis is Executive Vice President, Chief Administrative Officer and Chief Information Officer of the Company.
 Before joining the Company in this position in August 2015, Mr. Davis served as Senior Vice President, Chief Administrative Officer
and  Chief  Information  Officer  of  National  Oilwell  Varco,  Inc.  from  March  2005  to  April  2015  and  as  Vice  President,  Chief
Administrative Officer and Chief Information Officer from August 2002 to March 2005.  Mr. Davis earned a bachelor’s degree from
University of Kentucky in 1980, and he completed the Advanced Management Program at Harvard Business School in 2005.

Brady  K.  Long  is  Executive  Vice  President  and  General  Counsel  of  the  Company.    Before  being  named  to  his  current
position in March 2018, Mr. Long served as Senior Vice President and General Counsel from November 2015 to March 2018.  From
2011  to  November  2015,  when  Mr.  Long  joined  the  Company,  he  served  as  Vice  President—General  Counsel  and  Secretary  of
Ensco  plc,  which  acquired  Pride  International,  Inc.  where  he  had  served  as  Vice  President,  General  Counsel  and  Secretary  since
August 2009.  Mr. Long joined Pride International, Inc. in June 2005 as Assistant General Counsel and served as Chief Compliance
Officer  from  June  2006  to  February  2009.    He  was  director  of  Transocean  Partners  LLC  from  May  2016  until  December  2016.
 Mr. Long previously practiced corporate and securities law with the law firm of Bracewell LLP.  Mr. Long earned a Bachelor of Arts
degree from Brigham Young University in 1996, a Juris Doctorate degree from the University of Texas School of Law in 1999 and an
Executive LLM in Taxation from New York University in 2019.

Mark L. Mey is Executive Vice President and Chief Financial Officer of the Company.  Before joining the Company in this
position  in  May  2015,  Mr.  Mey  served  as  Executive  Vice  President  and  Chief  Financial  Officer  of  Atwood  Oceanics,  Inc.  from
January 2015 to May 2015, prior to which he served as Senior Vice President and Chief Financial Officer from August 2010.  Mr. Mey
was  director  of  Transocean  Partners  LLC  from  June  2015  until  December  2016.    He  served  as  Director,  Senior  Vice  President  and
Chief  Financial  Officer  of  Scorpion  Offshore  Ltd.  from  August  2005  to  July  2010.    Prior  to  2005,  Mr.  Mey  held  various  senior
financial and other roles in the drilling and financial services industries, including 12 years with Noble Corporation.  He earned an
Advanced Diploma in Accounting and a Bachelor of Commerce degree from the University of Port Elizabeth in South Africa in 1985,
and he is a chartered accountant.  Additionally, Mr. Mey completed the Harvard Business School Executive Advanced Management
Program in 1998.

David  Tonnel  is  Senior  Vice  President  and  Chief  Accounting  Officer.    Before  being  named  to  his  current  position  in
April 2017, he served as Senior Vice President, Supply Chain and Corporate Controller from October 2015 to April 2017, as Senior
Vice President, Finance and Controller from March 2012 to October 2015 and as Senior Vice President of the Europe and Africa Unit
from June 2009 to March 2012.  Mr. Tonnel served as Vice President of Global Supply Chain from November 2008 to June 2009, as
Vice President of Integration and Process Improvement from November 2007 to November 2008, and as Vice President and Controller
from February 2005 to November 2007.  Prior to February 2005, he served in various financial roles, including Assistant Controller;
Finance Manager, Asia Australia Region; and Controller, Nigeria.  Mr. Tonnel joined the Company in 1996 after working for Ernst &
Young in France as Senior Auditor.  Mr. Tonnel earned a Master of Science degree in Management from HEC in Paris, France in 1991.

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PART II

ITEM 5. MARKET FOR REGISTRANT’S COMMON EQUITY, RELATED SHAREHOLDER MATTERS

AND ISSUER PURCHASES OF EQUITY SECURITIES

MARKET FOR SHARES OF OUR COMMON EQUITY

Our shares are listed on the New York Stock Exchange under the ticker symbol “RIG.”  On February 14, 2022, we had

656,377,507 shares outstanding and 5,060 holders of record of our shares.

SHAREHOLDER MATTERS

Swiss tax consequences to our shareholders

Overview—The  tax  consequences  discussed  below  are  not  a  complete  analysis  or  listing  of  all  the  possible  tax
consequences that may be relevant to our shareholders.  Shareholders should consult their own tax advisors in respect of the tax
consequences related to receipt, ownership, purchase or sale or other disposition of our shares and the procedures for claiming a
refund of withholding tax.

Swiss income tax on dividends and similar distributions—A non-Swiss holder is not subject to Swiss income taxes
on  dividend  income  and  similar  distributions  in  respect  of  our  shares,  unless  the  shares  are  attributable  to  a  permanent
establishment or a fixed place of business maintained in Switzerland by such non-Swiss holder.  However, dividends and similar
distributions are subject to Swiss withholding tax, subject to certain exceptions.  See “—Swiss withholding tax on dividends
and similar distributions to shareholders.”

Swiss wealth tax—A non-Swiss holder is not subject to Swiss wealth taxes unless the holder’s shares are attributable

to a permanent establishment or a fixed place of business maintained in Switzerland by such non-Swiss holder.

Swiss capital gains tax upon disposal of shares—A non-Swiss holder is not subject to Swiss income taxes for capital
gains  unless  the  holder’s  shares  are  attributable  to  a  permanent  establishment  or  a  fixed  place  of  business  maintained  in
Switzerland by such non-Swiss holder.  In such case, the non-Swiss holder is required to recognize capital gains or losses on the
sale of such shares, which are subject to cantonal, communal and federal income tax.

Swiss  withholding  tax  on  dividends  and  similar  distributions  to  shareholders—A  Swiss  withholding  tax  of
35 percent is due on dividends and similar distributions to our shareholders from us, regardless of the place of residency of the
shareholder, subject to the exceptions discussed under “—Exemption” below.  We will be required to withhold at such rate and
remit  on  a  net  basis  any  payments  made  to  a  holder  of  our  shares  and  pay  such  withheld  amounts  to  the  Swiss  federal  tax
authorities.

Exemption—Distributions to shareholders in the form of a par value reduction or out of qualifying additional paid-in
capital for Swiss statutory purposes are exempt from Swiss withholding tax.  On December 31, 2021, the aggregate amount of
par value of our outstanding shares was CHF 65.5 million, equivalent to approximately $71.8 million, and the aggregate amount
of  qualifying  additional  paid-in  capital  of  our  outstanding  shares  was  CHF  13.7  billion,  equivalent  to  approximately
$15.0  billion.    Consequently,  we  expect  that  a  substantial  amount  of  any  potential  future  distributions  may  be  exempt  from
Swiss withholding tax.

Refund available to Swiss holders—A Swiss tax resident, corporate or individual, can recover the withholding tax in
full if such resident is the beneficial owner of our shares at the time the dividend or other distribution becomes due and provided
that  such  resident  reports  the  gross  distribution  received  on  such  resident’s  income  tax  return,  or  in  the  case  of  an  entity,
includes the taxable income in such resident’s income statement.

Refund  available  to  non-Swiss  holders—If  the  shareholder  that  receives  a  distribution  from  us  is  not  a  Swiss  tax
resident,  does  not  hold  our  shares  in  connection  with  a  permanent  establishment  or  a  fixed  place  of  business  maintained  in
Switzerland,  and  resides  in  a  country  that  has  concluded  a  treaty  for  the  avoidance  of  double  taxation  with  Switzerland  for
which the conditions for the application and protection of and by the treaty are met, then the shareholder may be entitled to a
full or partial refund of the withholding tax described above.  Switzerland has entered into bilateral treaties for the avoidance of
double  taxation  with  respect  to  income  taxes  with  numerous  countries,  including  the  United  States  (“U.S.”),  whereby  under
certain circumstances all or part of the withholding tax may be refunded.  The procedures for claiming treaty refunds, and the
time frame required for obtaining a refund, may differ from country to country.

Refund available to U.S. residents—The Swiss-U.S. tax treaty provides that U.S. residents eligible for benefits under
the treaty can seek a refund of the Swiss withholding tax on dividends for the portion exceeding 15 percent, leading to a refund
of 20 percent, or a 100 percent refund in the case of qualified pension funds.  As a general rule, the refund will be granted under
the treaty if the U.S. resident can show evidence of the following: (a) beneficial ownership, (b) U.S. residency and (c) meeting
the U.S.-Swiss tax treaty’s limitation on benefits requirements.  The claim for refund must be filed with the Swiss federal tax
authorities (Eigerstrasse 65, 3003 Bern, Switzerland), not later than December 31 of the third year following the year in which
the dividend payments became due.  The relevant Swiss tax form is Form 82C for companies, 82E for other entities and 82I for
individuals.    These  forms  can  be  obtained  from  any  Swiss  Consulate  General  in  the  U.S.  or  from  the  Swiss  federal  tax
authorities at the above address or can be downloaded from the webpage of the Swiss federal tax administration.  Each form
must be completed in triplicate, with each copy duly completed and signed before a notary public in the U.S.  Evidence that the
withholding tax was withheld at the source must also be included.

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Stamp  duties  in  relation  to  the  transfer  of  shares—The  purchase  or  sale  of  our  shares  may  be  subject  to  Swiss
federal stamp taxes on the transfer of securities irrespective of the place of residency of the purchaser or seller if the transaction
takes place through or with a Swiss bank or other Swiss securities dealer, as those terms are defined in the Swiss Federal Stamp
Tax Act and no exemption applies in the specific case.  If a purchase or sale is not entered into through or with a Swiss bank or
other  Swiss  securities  dealer,  then  no  stamp  tax  will  be  due.   The  applicable  stamp  tax  rate  is  0.075  percent  for  each  of  the
two parties to a transaction and is calculated based on the purchase price or sale proceeds.  If the transaction does not involve
cash consideration, the transfer stamp duty is computed on the basis of the market value of the consideration.

Share repurchases

Shares repurchased for the purpose of capital reduction are treated as a partial liquidation subject to a 35 percent Swiss
withholding  tax  based  on  the  difference  between  the  repurchase  price  and  the  related  amount  of  par  value  and  the  related
amount of qualifying additional paid-in capital, if any.  We would be required to remit on a net basis the purchase price with the
Swiss  withholding  tax  deducted  to  a  holder  of  our  shares  and  pay  the  withholding  tax  to  the  Swiss  federal  tax  authorities.
  However,  for  such  repurchased  shares,  the  portions  of  the  repurchase  price  that  are  attributable  to  the  par  value  and  the
qualifying additional paid-in capital for Swiss statutory reporting purposes are not subject to the Swiss withholding tax.

If we repurchase shares, we expect to use an alternative procedure pursuant to which we repurchase our shares via a
"virtual second trading line" from market players, such as banks and institutional investors, who are generally entitled to receive
a  full  refund  of  the  Swiss  withholding  tax.    The  use  of  such  “virtual  second  trading  line”  with  respect  to  share  repurchase
programs is subject to approval of the competent Swiss tax and other authorities.  We may not be able to repurchase as many
shares as we would like to repurchase for purposes of capital reduction on the “virtual second trading line” without subjecting
the selling shareholders to Swiss withholding taxes.  The repurchase of shares for purposes other than for cancellation, such as
to retain as treasury shares for use in connection with stock incentive plans, convertible debt or other instruments within certain
periods, are not generally subject to Swiss withholding tax.

Under Swiss corporate law, the right of a company and its subsidiaries to repurchase and hold its own shares is limited.
 A company may repurchase its shares to the extent it has freely distributable reserves as shown on its Swiss statutory balance
sheet in the amount of the purchase price and if the aggregate par value of all shares held by the company as treasury shares
does not exceed 10 percent of the company’s share capital recorded in the Swiss Commercial Register, whereby for purposes of
determining  whether  the  10  percent  threshold  has  been  reached,  shares  repurchased  under  a  share  repurchase  program  for
cancellation purposes authorized by the company’s shareholders are disregarded.  As of February 14, 2022, Transocean Inc., our
wholly owned subsidiary, held as treasury shares 9.86 percent of our issued shares.  Our board of directors could, to the extent
freely  distributable  reserves  are  available,  authorize  the  repurchase  of  additional  shares  for  purposes  other  than  cancellation,
such as to retain treasury shares for use in satisfying our obligations in connection with incentive plans or other rights to acquire
our shares.  Based on the number of shares held as treasury shares as of February 14, 2022, less than one percent of our issued
shares  could  be  repurchased  for  purposes  of  retention  as  additional  treasury  shares.   Although  our  board  of  directors  has  not
approved such a share repurchase program for the purpose of retaining repurchased shares as treasury shares, if it did so, any
such shares repurchased would be in addition to any shares repurchased under the currently approved program.

ISSUER PURCHASES OF EQUITY SECURITIES

Period

October 2021
November 2021
December 2021

Total

Total number
of shares
purchased

Average
price paid
per share

Total number of shares
purchased as part
of publicly announced
plans or programs (a)

Approximate dollar value
of shares that may yet
be purchased under the plans
or programs (in millions) (a)

 — $
 —
 —
 — $

 —
 —
 —
 —

—  $
—
—
 —  $

 3,552
 3,552
 3,552
 3,552

(a)

In  May  2009,  at  our  annual  general  meeting,  our  shareholders  approved  and  authorized  our  board  of  directors,  at  its  discretion,  to
repurchase for cancellation any amount of our shares for an aggregate purchase price of up to CHF 3.50 billion.  At December 31, 2021,
the authorization remaining under the share repurchase program was for the repurchase of our outstanding shares for an aggregate cost of
up to CHF 3.24 billion, equivalent to $3.55 billion.  The share repurchase program may be suspended or discontinued by our board of
directors  or  company  management,  as  applicable,  at  any  time.    See  “Item  7.  Management’s  Discussion  and  Analysis  of  Financial
Condition and Results of Operations—Liquidity and Capital Resources—Sources and uses of liquidity.”

ITEM 6. RESERVED

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ITEM 7. MANAGEMENT’S  DISCUSSION  AND  ANALYSIS  OF  FINANCIAL  CONDITION  AND
RESULTS OF OPERATIONS

The following information should be read in conjunction with the information contained in “Part I. Item 1. Business,”
“Part I. Item 1A. Risk Factors” and the audited consolidated financial statements and the notes thereto included under “Item 8.
Financial Statements and Supplementary Data” elsewhere in this annual report on Form 10-K.  The following discussion of our
results of operations and liquidity and capital resources includes comparisons for the years ended December 31, 2021 and 2020.
  For  a  discussion,  including  comparisons,  of  our  results  of  operations  and  liquidity  and  capital  resources  for  the  years  ended
December 31, 2020 and 2019, see “Part II. Item 7. Management’s Discussion and Analysis of Financial Condition and Results
of Operations” of our annual report on Form 10-K for the year ended December 31, 2020, filed with the United States (“U.S.”)
Securities and Exchange Commission on March 1, 2021.

BUSINESS

Transocean Ltd. (together with its subsidiaries and predecessors, unless the context requires otherwise, “Transocean,”
“we,”  “us”  or  “our”)  is  a  leading  international  provider  of  offshore  contract  drilling  services  for  oil  and  gas  wells.    As  of
February 14, 2022, we owned or had partial ownership interests in and operated 37 mobile offshore drilling units, consisting of
27  ultra-deepwater  floaters  and  10  harsh  environment  floaters.    As  of  February  14,  2022,  we  were  constructing  two  ultra-
deepwater drillships.

We  provide,  as  our  primary  business,  contract  drilling  services  in  a  single  operating  segment,  which  involves
contracting  our  mobile  offshore  drilling  rigs,  related  equipment  and  work  crews  to  drill  oil  and  gas  wells.   We  specialize  in
technically  demanding  regions  of  the  global  offshore  drilling  business  with  a  particular  focus  on  ultra-deepwater  and  harsh
environment  drilling  services.    Our  drilling  fleet  is  one  of  the  most  versatile  fleets  in  the  world,  consisting  of  drillships  and
semisubmersible floaters used in support of offshore drilling activities and offshore support services on a worldwide basis.

We  perform  contract  drilling  services  by  deploying  our  high-specification  fleet  in  a  single,  global  market  that  is
geographically dispersed in oil and gas exploration and development areas throughout the world.  Although rigs can be moved
from one region to another, the cost of moving rigs and the availability of rig-moving vessels may cause the supply and demand
balance to fluctuate somewhat between regions.  Still, significant variations between regions do not tend to persist long term
because  of  rig  mobility.    The  location  of  our  rigs  and  the  allocation  of  resources  to  operate,  build  or  upgrade  our  rigs  are
determined by the activities and needs of our customers.

SIGNIFICANT EVENTS

Share issuance—In June 2021, we commenced an at the market equity offering program (the “ATM Program”).  In
the year ended December 31, 2021, we received aggregate cash proceeds of $158 million, net of issue costs, for the aggregate
sale of 36.1 million shares under the ATM Program.  See “—Liquidity and Capital Resources—Sources and uses of liquidity.”

Shipyard  financing  arrangement—In  June  2021,  Transocean  Offshore  Deepwater  Holdings  Limited,  a
Cayman  Islands  company  and  our  wholly  owned  indirect  subsidiary,  entered  into  credit  agreements  with  Jurong  Shipyard
Pte Ltd. establishing facilities (the “Shipyard Loans”) to finance the final payments expected to be owed to the shipyard upon
delivery of the ultra-deepwater floaters Deepwater Atlas and Deepwater Titan.  See “—Liquidity and Capital Resources.”

Debt exchanges—In February 2021, we completed private exchanges (the “2021 Private Exchange”) of $323 million
aggregate  principal  amount  of  outstanding  0.50%  exchangeable  senior  bonds  due  January  2023  (the  “0.50%  Exchangeable
Senior  Bonds”)  for  $294  million  aggregate  principal  amount  of  the  4.00%  senior  guaranteed  exchangeable  bonds  due
December  2025  (the  “4.00%  Senior  Guaranteed  Exchangeable  Bonds”),  together  with  an  aggregate  cash  payment  of
$11  million.    In  the  year  ended  December  31,  2021,  we  recognized  a  gain  of  $51  million  associated  with  the  retirement  of
exchanged debt.  See “—Operating Results” and “—Liquidity and Capital Resources—Sources and uses of liquidity.”

Early  debt  retirement—In  the  year  ended  December  31,  2021,  we  repurchased  in  the  open  market  $79  million
aggregate principal amount of our debt securities for an aggregate cash payment of $79 million.  In January 2022, we repaid the
then-outstanding $18 million aggregate principal amount of the 5.52% Senior Secured Notes due May 2022 (the “5.52% Senior
Secured Notes”) early for an aggregate cash payment of $18 million.  See “—Operating Results” and “—Liquidity and Capital
Resources—Sources and uses of liquidity.”

Dispositions—During  the  year  ended  December  31,  2021,  we  completed  the  sale  of  one  harsh  environment  floater,
along with related assets, for which we received $4 million aggregate net cash proceeds and recognized an aggregate net loss of
$57 million.  See “—Operating Results.”

OUTLOOK

Drilling market—Our overall outlook for the offshore drilling industry has improved over the past year and remains
positive,  particularly  for  high-specification  assets,  such  as  those  we  own  and  operate.    During  the  second  half  of  2021,  our
customers’ interest in deepwater and harsh environment offshore projects was renewed due to numerous favorable factors, such
as  sustained  higher  commodity  prices  and  comparably  lower  carbon  intensity  compared  to  other  sources  of  fossil  fuel.
 South America, including Guyana, the

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U.S.  Gulf  of  Mexico  and,  increasingly,  West Africa  remain  key  ultra-deepwater  market  sectors,  while  Norway  continues  to
represent the largest harsh environment market.

In addition, in 2021, we observed continued strong tendering activity for Asia and Australia.  Licensing activity also
indicated  an  increased  interest  in  these  areas  as  energy  companies  looked  to  explore  and  develop  new  prospects.    Certain
customers began to increase their exploration, production and reserve replacement activities by restarting delayed projects and
commencing new campaigns.  We have seen an acceleration in this trend in early 2022.  While we expect this to continue in the
near  term,  and  potentially  longer,  it  depends  upon  many  variables,  including  increased  global  demand  for  hydrocarbons,  the
effects of the COVID-19 pandemic on consumer activity, the actions by some governments and regulators intended to curtail
existing and future drilling activities, and other factors.

Offshore  drilling  activity  is  increasing  in  almost  every  ultra-deepwater  market,  and  due  to  attrition  of  the  global
offshore  fleet  over  the  last  several  years,  there  are  significantly  fewer  available  drilling  units  and,  particularly,  an  increasing
scarcity of the highest specification drilling units as customers look to secure the best equipment for their projects.  In the North
Sea harsh environment market, an accelerated level of recovery is anticipated in 2023 through 2026 as the effect of Norway tax
incentive programs is realized by our customers.

Global energy demand is expected to increase in member and non-member countries of the Organization for Economic
Co-operation and Development.  Non-member countries, in particular, are expected to experience the largest population growth
and most significant increases in living standards, creating a compounding effect on energy consumption.  We believe that this
forecasted increase in global energy demand will support an increase in demand for oil and gas.  In the context of the sharp
decline  in  production  activities  that  resulted  from  the  pandemic  and  the  lack  of  investment  in  exploration  and  production
activities over the past seven years, we believe an increase in demand will precipitate substantial supply constraints that are not
easily reversed without significant new investment in drilling.

With  deepwater  and  harsh  environment  fields  offering  increasingly  competitive  returns,  combined  with  their
comparably low carbon intensity of production, we expect a significant portion of required spending in fossil fuel development
will be allocated to deepwater and harsh environment projects.  As the hydrocarbon supply-demand balance further improves,
we  expect  sustained  prices  to  increase  demand  for  our  high-specification  fleet  of  assets  and,  because  there  are  now  fewer
offshore drilling rigs than in recent years, further improvement of dayrates.

As of February 14, 2022, our contract backlog was $6.47 billion compared to $7.07 billion as of October 25, 2021.
 The risks of drilling project delays, contract renegotiations and contract terminations and cancellations have diminished as oil
prices have improved and stabilized.

Fleet status—We refer to the availability of our rigs in terms of the uncommitted fleet rate.  The uncommitted fleet
rate is defined as the number of uncommitted days divided by the total number of rig calendar days in the measurement period,
expressed  as  a  percentage.   An  uncommitted  day  is  defined  as  a  calendar  day  during  which  a  rig  is  idle  or  stacked,  is  not
contracted to a customer and is not committed to a shipyard.  The uncommitted fleet rates exclude the effect of priced options.
 As of February 14, 2022, our uncommitted fleet rates for each of the five years in the period ending December 31, 2026 were as
follows:

Uncommitted fleet rate
Ultra-deepwater floaters
Harsh environment floaters

     2022      2023      2024      2025      2026  

 60 %  
 48 %  

 72 %  
 76 %  

 81 %  
 98 %  

 83 %  
 100 %  

 88 %
 100 %

PERFORMANCE AND OTHER KEY INDICATORS

Contract backlog—We believe our industry leading contract backlog sets us apart from the competition and provides
indicators  of  our  future  revenue-earning  opportunities.    Contract  backlog  is  defined  as  the  maximum  contractual  operating
dayrate  multiplied  by  the  number  of  days  remaining  in  the  firm  contract  period,  excluding  revenues  for  mobilization,
demobilization,  contract  preparation,  other  incentive  provisions  or  reimbursement  revenues,  which  are  not  expected  to  be
significant to our contract drilling revenues.  The contract backlog represents the maximum contract drilling revenues that can
be earned considering the contractual operating dayrate in effect during the firm contract period.  The contract backlog for our
fleet was as follows:

Contract backlog
Ultra-deepwater floaters
Harsh environment floaters
Total contract backlog

February 14,
2022

October 25,
2021
(In millions)

February 12,  
2021

$

  $

 5,301   $
 1,165
 6,466   $

 5,626   $
 1,443
 7,069   $

 5,911
 1,931
 7,842

Our  contract  backlog  includes  only  firm  commitments,  including  amounts  associated  with  our  contracted  newbuild
units under construction, which are represented by signed drilling contracts or, in some cases, by other definitive agreements
awaiting contract execution.  It does not include conditional agreements and options to extend firm commitments.

The  average  contractual  dayrate  relative  to  our  contract  backlog  is  defined  as  the  average  maximum  contractual
operating dayrate to be earned per operating day in the measurement period.  An operating day is defined as a day for which a
rig is contracted to earn a

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dayrate during the firm contract period after operations commence.  At February 14, 2022, the contract backlog and average
contractual dayrates for our fleet were as follows:

Contract backlog
Ultra-deepwater floaters
Harsh environment floaters
Total contract backlog

Average contractual dayrates
Ultra-deepwater floaters
Harsh environment floaters

Total fleet average

For the years ending December 31,

Total

2022

2023

2024

2025

     Thereafter  

(In millions, except average dayrates)

  $

  $

 5,301   $
 1,165
 6,466   $

 1,255   $

 753

 2,008   $

 1,149
 385
 1,534

$

$

 938
 27
 965

$

$

 858
 —
 858

$

$

 1,101
 —
 1,101

  $  406,000   $  320,000   $  390,000
$  410,000   $  397,000   $  437,000
$  407,000   $  345,000   $  401,000

$  469,000
$  424,000
$  467,000

$  470,000
$
$  470,000

 — $

$  467,000
 —
$  467,000

The actual amount of revenues earned and the actual periods in which revenues are earned will differ from the amounts
and periods shown in the tables above due to various factors, including shipyard and maintenance projects, unplanned downtime
and  other  factors  that  result  in  lower  applicable  dayrates  than  the  full  contractual  operating  dayrate.   Additional  factors  that
could  affect  the  amount  and  timing  of  actual  revenues  to  be  recognized  include  customer  liquidity  issues  and  contract
terminations that may be available to our customers under certain circumstances.

The contractual operating dayrate may be higher than the actual dayrate we ultimately receive because an alternative
contractual dayrate, such as a waiting-on-weather rate, repair rate, standby rate or force majeure rate, may apply under certain
circumstances.  The contractual operating dayrate may also be higher than the actual dayrate we ultimately receive because of a
number of factors, including rig downtime or suspension of operations.  In certain contracts, the actual dayrate may be reduced
to zero if, for example, repairs extend beyond a stated period of time.  See “Part I. Item 1A. Risk Factors—Risks related to our
business—Our current backlog of contract drilling revenues may not be fully realized.”

Average daily revenue—We believe average daily revenue provides a comparative measurement unit for our revenue-
earning  performance.   Average  daily  revenue  is  defined  as  operating  revenues,  excluding  revenues  for  contract  terminations,
reimbursements and contract intangible amortization, earned per operating day.  The average daily revenue for our fleet was as
follows:

Average daily revenue
Ultra-deepwater floaters
Harsh environment floaters
Midwater floaters

Total fleet average daily revenue

Years ended December 31, 

2021

2020

2019

$  355,500   $  324,500
$  339,600
$  386,200
$
 —   $  111,400
$  365,600   $  327,500

$  337,900
$  298,500
$  118,400
$  313,400

Our  average  daily  revenue  fluctuates  relative  to  market  conditions  and  our  revenue  efficiency.    The  average  daily
revenue may be affected by incentive performance bonuses or penalties or demobilization fee revenues.  Our total fleet average
daily revenue is affected by the mix of rig classes being operated.  Midwater floaters, for example, which we no longer operate,
are typically contracted at lower dayrates compared to ultra-deepwater floaters and harsh environment floaters.  Revenues for a
contracted newbuild unit are included in the calculation when the rig commences operations upon acceptance by the customer.
  We  remove  rigs  from  the  calculation  upon  disposal  or  classification  as  held  for  sale,  unless  we  continue  to  operate  rigs
subsequent to sale, in which case we remove the rigs at the time of completion or novation of the contract.

Revenue efficiency—We believe revenue efficiency measures our ability to ultimately convert our contract backlog
into  revenues.    Revenue  efficiency  is  defined  as  actual  operating  revenues,  excluding  revenues  for  contract  terminations  and
reimbursements,  for  the  measurement  period  divided  by  the  maximum  revenue  calculated  for  the  measurement  period,
expressed as a percentage.  Maximum revenue is defined as the greatest amount of contract drilling revenues the drilling unit
could earn for the measurement period, excluding revenues for incentive provisions, reimbursements and contract terminations.
 The revenue efficiency rates for our fleet were as follows:

Years ended December 31, 
2020

2019

2021

Revenue efficiency
Ultra-deepwater floaters
Harsh environment floaters
Midwater floaters

Total fleet average revenue efficiency

 96.1 %
 98.8 %
 — %
 97.0 %

 97.2 %
 95.0 %
 86.2 %
 96.3 %

 98.5 %
 95.0 %
 99.3 %
 97.2 %

Our revenue efficiency rate varies due to revenues earned under alternative contractual dayrates, such as a waiting-on-
weather rate, repair rate, standby rate, force majeure rate or zero rate, that may apply under certain circumstances.  Our revenue
efficiency rate is

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also affected by incentive performance bonuses or penalties.  We include newbuilds in the calculation when the rigs commence
operations  upon  acceptance  by  the  customer.    We  exclude  rigs  that  are  not  operating  under  contract,  such  as  those  that  are
stacked.

Rig  utilization—We  present  our  rig  utilization  as  an  indicator  of  our  ability  to  secure  work  for  our  fleet.    Rig
utilization is defined as the total number of operating days divided by the total number of rig calendar days in the measurement
period, expressed as a percentage.  The rig utilization rates for our fleet were as follows:

Years ended December 31, 
2020

2019

2021

Rig utilization
Ultra-deepwater floaters
Harsh environment floaters
Midwater floaters

Total fleet average rig utilization

 49.3 %
 64.4 %
 — %
 53.4 %

 58.5 %
 72.6 %
 37.1 %
 62.4 %

 51.0 %
 77.5 %
 36.7 %
 57.6 %

Our rig utilization rate declines as a result of idle and stacked rigs and during shipyard and mobilization periods to the
extent these rigs are not earning revenues.  We include newbuilds in the calculation when the rigs commence operations upon
acceptance by the customer.  We remove rigs from the calculation upon disposal or classification as held for sale.  Accordingly,
our rig utilization can increase when we remove idle or stacked units from our fleet.

OPERATING RESULTS

Year ended December 31, 2021 compared to the year ended December 31, 2020

The following is an analysis of our operating results.  See “—Performance and Other Key Indicators” for definitions of

operating days, average daily revenue, revenue efficiency and rig utilization.

Operating days

Average daily revenue
Revenue efficiency
Rig utilization

Contract drilling revenues

Operating and maintenance expense
Depreciation and amortization expense
General and administrative expense
Loss on impairment
Loss on disposal of assets, net
Operating loss

Other income (expense), net

Interest income
Interest expense, net of amounts capitalized
Gain on restructuring and retirement of debt, net
Other, net

Loss before income tax expense
Income tax expense
Net loss

“nm” means not meaningful.

Years ended December 31,

2021

2020

     Change

     % Change

(In millions, except day amounts and percentages)

 7,236

 9,169

 (1,933)

 (21)%

$

365,600

$

327,500

$  38,100

 12 %

 97.0 %  
 53.4 %  

 96.3 %  
 62.4 %  

$

 2,556

$

 3,152

$

 (596)

 (19)%

 (1,697)
 (742)
 (167)
 —
 (62)
 (112)

 15
 (447)
 51
 23
 (470)
 (121)
 (591)

$

 (2,000)
 (781)
 (183)
 (597)
 (84)
 (493)

 21
 (575)
 533
 (27)
 (541)
 (27)
 (568)

$

 303
 39
 16
 597
 22
 381

 (6)
 128
 (482)
 50
 71
 (94)
 (23)

$

 15 %
 5 %
 9 %

nm
 26 %
 77 %

 (29)%
 22 %
 (90)%
nm
 13 %
nm
 (4)%

Contract drilling revenues—Contract drilling revenues decreased for the year ended December 31, 2021, compared
to  the  year  ended  December  31,  2020,  primarily  due  to  the  following:  (a)  approximately  $200  million  resulting  from  the
settlement  of  disputes  and  payments  for  early  termination  of  a  contract  in  the  year  ended  December  31,  2020  with  no
comparable activity in the current year period, (b) approximately $185 million resulting from rigs that were idle or in shipyard
preparing for contracts in the current year, (c) approximately $155 million resulting from rigs that were stacked in the prior year
and (d) approximately $115 million resulting from rigs that were sold.  These decreases were partially offset by the following
increases:  (a)  approximately  $55  million  resulting  from  increased  average  daily  revenue  and  (b)  approximately  $5  million
resulting from higher revenue efficiency.

Costs  and  expenses—Operating  and  maintenance  costs  and  expenses  decreased  for  the  year  ended  December  31,
2021, compared to the year ended December 31, 2020, primarily due to the following: (a) approximately $145 million resulting
from rigs that were stacked in the prior year, (b) approximately $95 million resulting from rigs that were sold, (c) approximately
$55 million resulting from Transocean Norge being idle, (d) approximately $20 million resulting from litigation and settlement
costs in the prior year, (d) approximately

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$20  million  resulting  from  severance  costs  of  offshore  and  onshore  personnel,  (e)  approximately  $15  million  resulting  from
onshore  personnel  costs,  excluding  severance,  (f)  approximately  $10  million  resulting  from  other  changes  in  rig  activity  and
(g) approximately $10 million resulting from reduced costs related to COVID-19 mitigation.  These decreases were partially
offset by the following increases: (a) approximately $28 million resulting from our allowance for excess materials and supplies
due to our identification of certain items that were in excess of our expected future usage based on our current market outlook,
(b)  approximately  $35  million  resulting  from  increased  personnel  costs,  primarily  due  to  unfavorable  exchange  rates,  and
(c) approximately $20 million resulting from shipyard and maintenance costs primarily driven by out-of-service activities.

Depreciation and amortization expense decreased for the year ended December 31, 2021, compared to the year ended
December  31,  2020,  primarily  due  to  approximately  $22  million  resulting  from  rigs  that  were  sold  and  approximately
$16 million resulting from assets that had reached the end of their useful lives or had been retired.

General  and  administrative  expense  decreased  for  the  year  ended  December  31,  2021,  compared  to  the  year  ended
December  31,  2020,  primarily  due  to  the  following:  (a)  approximately  $13  million  resulting  from  reduced  personnel  costs,
including severance, related to our cost savings plan implemented in the year ended December 31, 2020 and (b) approximately
$5 million resulting from reduced costs for information systems and technology, partially offset by (c) approximately $6 million
resulting from increased strategy and innovation costs.

Loss  on  impairment  or  disposal  of  assets—In  the  year  ended  December  31,  2020,  we  recognized  a  loss  on  the
impairment of assets, including an aggregate net loss of $556 million associated with assets that we determined were impaired
at the time we classified them as held for sale, a loss of $31 million associated with the impairment of our midwater floater asset
group and a loss of $10 million associated with the impairment of other assets.

In the year ended December 31, 2021, we recognized an aggregate net loss of $57 million, primarily associated with
the sale of a harsh environment floater and related assets.  In the year ended December 31, 2020, we recognized an aggregate
net  loss  of  $61  million  associated  with  the  sale  of  one  ultra-deepwater  floater,  three  harsh  environment  floaters  and
three midwater floaters, along with related assets.  In the years ended December 31, 2021 and 2020, we recognized an aggregate
net loss of $5 million and $23 million, respectively, associated with the disposal of assets unrelated to rig sales.

Other income and expense—Interest expense, net of amounts capitalized, decreased in the year ended December 31,
2021, compared to the year ended December 31, 2020, primarily due to a decrease of $145 million resulting from debt early
retired, repaid or restructured, partially offset by an increase of $19 million resulting from debt issued.

In  the  year  ended  December  31,  2021,  we  recognized  an  aggregate  net  gain  of  $51  million  associated  with  the
retirement of $323 million aggregate principal amount of the 0.50% Exchangeable Senior Bonds as a result of the 2021 Private
Exchange.  In the year ended December 31, 2020, we recognized a net gain on restructuring and retirement of debt, primarily
due  to  the  following:  (a)  an  aggregate  gain  of  $427  million  associated  with  the  restructuring  of  debt  in  the  private  exchange
transactions in August 2020 (the “2020 Private Exchange”) and the exchange offers in September 2020 (the “2020 Exchange
Offers”), (b) an aggregate gain of $135 million associated with the retirement of $360 million aggregate principal amount of our
debt securities in the tender offers in November 2020, (c) an aggregate gain of $36 million associated with the retirement of
$147 million aggregate principal amount of our debt securities repurchased in the open market, partially offset by (d) a loss of
$65 million associated with the full redemption of the 9.00% senior notes due July 2023 (the “9.00% Senior Notes”).

Other income, net, increased in the year ended December 31, 2021, compared to the year ended December 31, 2020,
primarily due to the following: (a) decreased loss of $22 million resulting from impairment of our equity investment in Orion
Holdings (Cayman) Limited (“Orion”), (b) increased income of $24 million resulting from a settlement of litigation and other
claims,  (c)  increased  income  of  $23  million  related  to  the  non-service  components  of  net  periodic  benefit  income  and
(d)  decreased  losses  of  $7  million  resulting  from  net  changes  to  currency  exchange  rates,  partially  offset  by  (e)  decreased
income of $25 million related to our investment in Orion and (f) decreased income of $4 million related to our dual-activity
patent.

Income tax expense—In the years ended December 31, 2021 and 2020, our effective tax rate was (25.7) percent and
(5.1)  percent,  respectively,  based  on  loss  before  income  tax  expense.    In  the  years  ended  December  31,  2021  and  2020,  the
aggregate effect of discrete period tax items was a net tax expense of $47 million and benefit of $91 million, respectively.  In
the year ended December 31, 2021, such discrete items included the effect of tax law changes in Switzerland and jurisdictional
ownership  changes  of  certain  assets,  loss  on  disposal  of  assets,  expiration  and  settlements  of  various  uncertain  tax  positions,
gain on retirement of debt, changes to our allowance for excess materials and loss on impairment of an equity investment.  In
the  year  ended  December  31,  2020,  such  discrete  items  included  losses  on  impairment  and  disposal  of  assets,  gain  on
restructuring  and  retirement  of  debt,  revenues  recognized  for  the  settlement  of  disputes,  the  loss  on  impairment  of  an  equity
investment, the carryback of net operating losses in the U.S., including the release of valuation allowances previously recorded,
settlements  and  expirations  of  various  uncertain  tax  positions  and  accruals  for  withholding  taxes.    In  the  years  ended
December  31,  2021  and  2020,  our  effective  tax  rate,  excluding  discrete  items,  was  (18.5)  percent  and  (23.4)  percent,
respectively,  based  on  loss  before  income  tax  expense.    In  the  year  ended  December  31,  2021  compared  to  the  year  ended
December 31, 2020, our effective tax rate increased primarily due changes in the relative blend of income from operations in
certain jurisdictions.

Due  to  our  operating  activities  and  organizational  structure,  our  income  tax  expense  does  not  change  proportionally
with our income before income taxes.  Significant decreases in our income before income taxes typically lead to higher effective
tax rates, while significant

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increases in income before income taxes can lead to lower effective tax rates, subject to the other factors impacting income tax
expense  noted  above.   With  respect  to  the  effective  tax  rate  calculation  for  the  year  ended  December  31,  2021,  a  significant
portion of our income tax expense was generated in countries in which income taxes are imposed or treated to be imposed on
gross  revenues,  with  the  most  significant  of  these  countries  being  Angola  and  India.    Conversely,  the  countries  in  which  we
incurred the most significant income taxes during this period that were based on income before income tax include the U.S.,
Switzerland, Norway and Hungary.  Our rig operating structures further complicate our tax calculations, especially in instances
where  we  have  more  than  one  operating  structure  for  the  taxing  jurisdiction  and,  thus,  more  than  one  method  of  calculating
taxes depending on the operating structure utilized by the rig under the contract.

LIQUIDITY AND CAPITAL RESOURCES

Sources and uses of cash

At December 31, 2021, we had $976 million in unrestricted cash and cash equivalents and $436 million in restricted
cash  and  cash  equivalents.    In  the  year  ended  December  31,  2021,  our  primary  sources  of  cash  were  net  cash  provided  by
operating activities and net cash proceeds from the issuance of shares under the ATM Program.  Our primary uses of cash were
debt repayments and capital expenditures.

Cash flows from operating activities
Net loss

Non-cash items, net
Changes in operating assets and liabilities, net

Years ended
December 31, 

2021

2020
(In millions)

    Change

$

$

 (591)  $
 1,243
 (77)
 575   $

 (568) 
 1,380
 (414)
 398  

$

$

 (23)
 (137)
 337
 177

Net  cash  provided  by  operating  activities  increased  primarily  due  to  (a)  reduced  cash  paid  for  interest,  (b)  the  cash
payment  of  $125  million  released  from  restricted  cash  to  satisfy  our  remaining  obligations  under  the  Plaintiff  Steering
Committee  settlement  agreement  in  June  2020  with  no  comparable  activity  in  the  current  year  and  (c)  reduced  cash  paid  for
income taxes.

Cash flows from investing activities

Capital expenditures
Investment in loans to unconsolidated affiliates
Investments in unconsolidated affiliates
Proceeds from disposal of assets, net
Proceeds from maturities of unrestricted and restricted investments

Years ended
December 31, 

2021

2020
(In millions)

    Change

$

$

 (208)  $
 (33)
 (1)
 9
 —
 (233)  $

 (265) 
 (2)
 (19)
 24
 5
 (257) 

$

$

 57
 (31)
 18
 (15)
 (5)
 24

Net  cash  used  in  investing  activities  decreased  primarily  due  to  (a)  reduced  capital  expenditures  unrelated  to  our
two  newbuilds  under  construction  and  (b)  reduced  investments  in  unconsolidated  affiliates,  partially  offset  by  (c)  increased
investments in loans to our unconsolidated affiliates and (d) reduced proceeds from disposal of assets.

Cash flows from financing activities

Repayments of debt
Proceeds from issuance of shares, net of issue costs
Proceeds from issuance of debt, net of discounts and issue costs
Other, net

Years ended
December 31, 

2021

2020
(In millions)

     Change

$

$

 (606) $
 158
 —
 (42)
 (490)  $

 (1,637)
 —
 743
 (36)
 (930) 

$

$

 1,031
 158
 (743)
 (6)
 440

Net  cash  used  in  financing  activities  decreased  primarily  due  to  (a)  reduced  cash  used  to  repay  debt,  primarily  as  a
result  of  the  full  redemption  of  $714  million  aggregate  principal  amount  of  the  9.00%  Senior  Notes  in  February  2020  and
(b) aggregate net cash proceeds from the issuance of 36.1 million shares under the ATM Program in the current year, partially
offset by (c) net cash proceeds from the issuance of the 8.00% senior notes due February 2027 (the “8.00% Senior Notes”) in
January 2020.

Sources and uses of liquidity

Overview—We expect to use existing unrestricted cash balances, internally generated cash flows, borrowings under
the Shipyard Loans or the Secured Credit Facility, as defined below, or proceeds from the disposal of assets, the issuance of
additional debt or the issuance of additional shares under the ATM Program to fulfill anticipated obligations, which may include
capital expenditures, working capital

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and  other  operational  requirements,  scheduled  debt  maturities  or  other  payments.    We  may  consider  establishing  additional
financing arrangements with banks or other capital providers, and subject to market conditions and other factors, we may be
required to provide collateral for any such future financing arrangements.  We continue to evaluate additional potential liability
management  transactions  in  connection  with  our  ongoing  efforts  to  prudently  manage  our  capital  structure  and  improve  our
liquidity.  In each case subject to then existing market conditions and our expected liquidity needs, among other factors, we may
continue  to  use  existing  unrestricted  cash  balances,  internally  generated  cash  flows  and  proceeds  from  asset  sales  to  pursue
liability management transactions, including among others, purchasing or exchanging one or more existing series of our debt
securities in the open market, in privately negotiated transactions, through tender offers or through exchange offers.  Any future
purchases, exchanges or other transactions may be on the same terms or on terms that are more or less favorable to holders than
the terms of any prior transaction, including the exchange transactions completed in the years ended December 31, 2021 and
2020.  We can provide no assurance as to which, if any, of these alternatives, or combinations thereof, we may choose to pursue
in the future, if at all, or as to the timing with respect to any future transactions.

The  ongoing  effect  of  the  COVID-19  pandemic,  including  virus  variants,  and  the  volatility  in  oil  prices  could  have
significant  adverse  consequences  for  general  economic,  financial  and  business  conditions,  as  well  as  for  our  business  and
financial position and the business and financial position of our customers and suppliers and may, among other things, impact
our ability to generate cash flows from operations, access the capital markets on acceptable terms or at all, and affect our future
need or ability to borrow under our Secured Credit Facility.  In addition to our potential sources of funding, the effects of such
global events may impact our liquidity or need to alter our allocation or sources of capital, implement further cost reduction
measures and change our financial strategy.

We  have  generated  positive  cash  flows  from  operating  activities  over  recent  years  and,  although  we  cannot  provide
assurances, we currently expect that such cash flows will continue to be positive over the next year.  However, among other
factors, if the drilling market deteriorates, or if we experience poor operating results, or if we incur expenses to, for example,
reactivate, stack or otherwise assure the marketability of our fleet, cash flows from operations may be reduced or negative.

Our ability and willingness to access the debt and equity markets is a function of a variety of events, including, among
others, general economic conditions, industry conditions, market conditions and market perceptions of us and our industry and
credit rating agencies’ views of our debt.  The rating of the majority of our long-term debt (“Debt Rating”) is below investment
grade.    The  Debt  Rating  is  causing  us  to  experience  increased  fees  and  interest  rates  under  our  Secured  Credit  Facility  and
agreements governing certain of our senior notes.  Future downgrades may further restrict our ability to access the debt market
for sources of capital and may negatively impact the cost of such capital at a time when we would like, or need, to access such
markets, which could have an impact on our flexibility to react to changing economic and business conditions.  An economic
downturn like the one we are currently experiencing could have an impact on the lenders participating in our credit facilities or
on our customers, causing them to fail to meet their obligations to us.

Secured  Credit  Facility—As  of  December  31,  2021,  we  have  a  $1.33  billion  secured  revolving  credit  facility
established under a bank credit agreement (as amended from time to time, the “Secured Credit Facility”), which is scheduled to
expire on June 22, 2023.  The Secured Credit Facility is guaranteed by Transocean Ltd. and certain wholly owned subsidiaries.
 The Secured Credit Facility is secured by, among other things, a lien on nine of our ultra-deepwater floaters and two of our
harsh environment floaters.  The maximum borrowing capacity will be reduced to $1.00 billion if, and so long as, our leverage
ratio,  measured  as  the  aggregate  principal  amount  of  debt  outstanding  to  earnings  before  interest,  taxes,  depreciation  and
amortization,  exceeds  10.00  to  1.00.    The  Secured  Credit  Facility  contains  covenants  that,  among  other  things,  include
maintenance  of  a  minimum  guarantee  coverage  ratio  of  3.0  to  1.0,  a  minimum  collateral  coverage  ratio  of  2.1  to  1.0,  a
maximum debt to capitalization ratio of 0.60 to 1.00 and minimum liquidity of $500 million.  The Secured Credit Facility also
restricts the ability of Transocean Ltd. and certain of our subsidiaries to, among other things, merge, consolidate or otherwise
make changes to the corporate structure, incur liens, incur additional indebtedness, enter into transactions with affiliates and pay
dividends and other distributions.  In order to borrow under the Secured Credit Facility, we must, at the time of the borrowing
request,  not  be  in  default  under  the  Secured  Credit  Facility  and  make  certain  representations  and  warranties,  including  with
respect to compliance with laws and solvency, to the lenders.  Repayment of borrowings under the Secured Credit Facility are
subject  to  acceleration  upon  the  occurrence  of  an  event  of  default.    Under  the  agreements  governing  certain  of  our  debt  and
finance  lease,  we  are  also  subject  to  various  covenants,  including  restrictions  on  creating  liens,  engaging  in  sale/leaseback
transactions  and  engaging  in  certain  merger,  consolidation  or  reorganization  transactions.    A  default  under  our  public  debt
indentures, the agreements governing our senior secured notes, our finance lease contract or any other debt owed to unaffiliated
entities that exceeds $125 million could trigger a default under the Secured Credit Facility and, if not waived by the lenders,
could  cause  us  to  lose  access  to  the  Secured  Credit  Facility.    At  February  14,  2022,  we  had  no  borrowings  outstanding,
$16  million  of  letters  of  credit  issued,  and  we  had  $1.32  billion  of  available  borrowing  capacity  under  the  Secured  Credit
Facility.

Shipyard financing arrangement—In June 2021, we and Jurong Shipyard Pte Ltd. entered into the Shipyard Loans
to  finance  all  or  a  portion  of  the  final  payments  expected  to  be  owed  to  the  shipyard  upon  delivery  of  the  ultra-deepwater
floaters  Deepwater  Atlas  and  Deepwater  Titan.    We  expect  to  borrow  approximately  $370  million  upon  delivery  of
Deepwater Atlas in the six months ending June 30, 2022, and we expect to borrow approximately $90 million upon delivery of
Deepwater  Titan  in  the  six  months  ending  December  31,  2022.    The  Shipyard  Loans  are  guaranteed  by  Transocean  Inc.
 Borrowings under the Shipyard Loan for Deepwater Atlas will be secured by, among other security, a lien on the rig.  In certain
circumstances, the maximum aggregate borrowing capacity under the Shipyard Loan for Deepwater Titan may be increased to
approximately $440 million, and such Shipyard Loan may also be secured by, among other security, a lien on the rig.  We will
repay  the  borrowings,  together  with  interest  of  4.5  percent  per  annum,  according  to  the  selected  installment  schedule  over  a
maximum of a six-year period following delivery of the drilling rigs.  We have the right to prepay any outstanding borrowings,
in full or

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in part, without penalty.  The Shipyard Loans contain covenants that, among other things, limits the ability of the subsidiary
owners  of  the  drilling  rigs  to  incur  certain  types  of  additional  indebtedness  or  make  certain  additional  commitments  or
investments.  At February 14, 2022, we had no borrowings outstanding under the Shipyard Loans.

Share issuance—On June 14, 2021, we entered into an equity distribution agreement with a sales agent for the offer
and sale of our shares, with up to an aggregate net offering price of $400 million, pursuant to the ATM Program.  We intend to
use the net proceeds from the sale of our shares under the ATM Program for general corporate purposes, which may include,
among  other  things  the  repayment  or  refinancing  of  indebtedness  and  the  funding  of  working  capital,  capital  expenditures,
investments and additional balance sheet liquidity.  In the year ended December 31, 2021, we received aggregate cash proceeds
of $158 million, net of issue costs, for the aggregate sale of 36.1 million shares under the ATM Program.

Debt exchanges—On  February  26,  2021,  we  issued  $294  million  aggregate  principal  amount  of  the  4.00%  Senior
Guaranteed  Exchangeable  Bonds  and  made  an  aggregate  cash  payment  of  $11  million  in  the  2021  Private  Exchange  for
$323  million  aggregate  principal  amount  of  the  0.50%  Exchangeable  Senior  Bonds.    The  4.00%  Senior  Guaranteed
Exchangeable  Bonds  are  guaranteed  by  Transocean  Ltd.  and  the  same  subsidiaries  of  Transocean  Inc.  that  guarantee  the
2.50% senior guaranteed exchangeable bonds due January 2027 (the “2.50% Senior Guaranteed Exchangeable Bonds”) and the
11.50%  senior  guaranteed  notes  due  January  2027  (the  “11.50%  Senior  Guaranteed  Notes”).   The  indenture  that  governs  the
4.00%  Senior  Guaranteed  Exchangeable  Bonds  also  requires  such  bonds  to  be  repurchased  upon  the  occurrence  of  certain
fundamental changes and events, at specified prices depending on the particular fundamental change or event, which include
changes  and  events  related  to  certain  (i)  change  of  control  events  applicable  to  Transocean  Ltd.  or  Transocean  Inc.,  (ii)  the
failure of our shares to be listed or quoted on a national securities exchange and (iii) specified tax matters.  The 4.00% Senior
Guaranteed  Exchangeable  Bonds  may  be  exchanged  at  any  time  prior  to  the  close  of  business  on  the  second  business  day
immediately preceding the maturity date at a current exchange rate of 190.4762 Transocean Ltd. shares per $1,000 note, which
implies  an  exchange  price  of  $5.25  per  share,  subject  to  adjustment  upon  the  occurrence  of  certain  events,  and  any  such
exchange may be settled in cash, Transocean Ltd. shares or a combination of cash and Transocean Ltd. shares, at our election.

On  August  14,  2020,  we  issued  $238  million  aggregate  principal  amount  of  the  2.50%  Senior  Guaranteed
Exchangeable  Bonds  in  the  2020  Private  Exchange  for  $397  million  aggregate  principal  amount  of  the  0.50%  Exchangeable
Senior Bonds.  The 2.50% Senior Guaranteed Exchangeable Bonds are fully and unconditionally guaranteed by Transocean Ltd.
and  certain  wholly  owned  indirect  subsidiaries  of  Transocean  Inc.    We  may  redeem  all  or  a  portion  of  the  2.50%  Senior
Guaranteed Exchangeable Bonds (i) on or after August 14, 2022, if certain conditions related to the price of our shares have
been satisfied, at a price equal to 100 percent of the aggregate principal amount and (ii) on or after August 14, 2023, at specified
redemption  prices.    The  indenture  that  governs  the  2.50%  Senior  Guaranteed  Exchangeable  Bonds  contains  covenants  that,
among other things, limit our ability to incur certain liens on our drilling units without equally and ratably securing the notes,
engage  in  certain  sale  and  lease  back  transactions  covering  any  of  our  drilling  units,  allow  our  subsidiaries  to  incur  certain
additional debt, and consolidate, merge or enter into a scheme of arrangement qualifying as an amalgamation.  The indenture
that governs the 2.50% Senior Guaranteed Exchangeable Bonds also requires such bonds to be repurchased upon the occurrence
of certain fundamental changes and events, at specified prices depending on the particular fundamental change or event, which
include  changes  and  events  related  to  certain  (i)  change  of  control  events  applicable  to  Transocean  Ltd.  or  Transocean  Inc.,
(ii)  the  failure  of  our  shares  to  be  listed  or  quoted  on  a  national  securities  exchange  and  (iii)  specified  tax  matters.    The
2.50%  Senior  Guaranteed  Exchangeable  Bonds  may  be  exchanged  at  any  time  prior  to  the  close  of  business  on  the  second
business  day 
the  redemption  date  at  a  current  exchange  rate  of
162.1626 Transocean Ltd. shares per $1,000 note, which implies an exchange price of $6.17 per share, subject to adjustment
upon the occurrence of certain events.

immediately  preceding 

the  maturity  date  or 

On September 11, 2020, we issued $687 million aggregate principal amount of the 11.50% Senior Guaranteed Notes in
the  2020  Exchange  Offers,  pursuant  to  an  exchange  offer  memorandum,  dated  August  10,  2020,  as  supplemented,  for  an
aggregate  principal  amount  of  $1.5  billion  of  several  series  of  our  existing  debt  securities  that  were  validly  tendered  and
accepted for purchase.  The 11.50% Senior Guaranteed Notes are fully and unconditionally guaranteed by Transocean Ltd. and
certain wholly owned indirect subsidiaries of Transocean Inc.  We may redeem all or a portion of the 11.50% Senior Guaranteed
Notes prior to July 30, 2023 at a price equal to 100 percent of the aggregate principal amount plus a make-whole premium, and
subsequently,  at  specified  redemption  prices.    We  may  also  use  the  net  cash  proceeds  of  certain  equity  offerings  by
Transocean Ltd. to redeem, on one or more occasions prior to July 30, 2023, up to a maximum of 40 percent of the original
aggregate principal amount of the 11.50% Senior Guaranteed Notes, subject to certain adjustments, at a redemption price equal
to 111.50 percent of the aggregate principal amount.  The indenture that governs the 11.50% Senior Guaranteed Notes contains
covenants  that,  among  other  things,  limit  our  ability  to  incur  certain  liens  on  our  drilling  units  without  equally  and  ratably
securing the notes, engage in certain sale and lease back transactions covering any of our drilling units, allow our subsidiaries to
incur certain additional debt, make certain internal transfers of our drilling units and consolidate, merge or enter into a scheme
of arrangement qualifying as an amalgamation.

Early  debt  retirement—In  January  2022,  we  made  an  aggregate  cash  payment  of  $18  million  to  repay  the  then-
outstanding  $18  million  aggregate  principal  amount  of  the  5.52%  Senior  Secured  Notes,  and  as  a  result,  the  noteholders
subsequently released all liens, the mortgage on the secured rig and $106 million from restricted cash accounts.  In the years
ended  December  31,  2021  and  2020,  we  made  an  aggregate  cash  payment  of  $79  million  and  $110  million,  respectively,  to
repurchase in the open market $79 million and $147 million, respectively, aggregate principal amount of our debt securities.  In
February 2020, we made an aggregate cash payment of $767 million, including the make-whole premium, to redeem in full the
then-outstanding 9.00% Senior Notes.  In November 2020, we completed the cash

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tender offers to purchase certain debt securities, and as a result, we made an aggregate cash payment of $222 million to settle
the validly tendered notes.

Debt issuances—On January 17, 2020, we issued $750 million aggregate principal amount of our 8.00% Senior Notes,
and  we  received  aggregate  cash  proceeds  of  $743  million,  net  of  issue  costs.    We  may  redeem  all  or  a  portion  of  the
8.00% Senior Notes on or prior to February 1, 2023 at a price equal to 100 percent of the aggregate principal amount plus a
make-whole premium, and subsequently, at specified redemption prices.

Equity and debt investments—We hold equity and debt investments in Orion, the company that, through its wholly
owned subsidiary, owns the harsh environment floater Transocean Norge.  In June 2021, we agreed to participate in a financing
arrangement for Orion, at a rate of 33.0 percent, equivalent to our ownership interest in Orion and made a cash investment of
$33 million in the loan facility.

We  also  hold  equity  and  debt  investments  in  certain  unconsolidated  affiliates  that  are  involved  in  researching  and
developing technology to improve efficiency, reliability, sustainability and safety in drilling and other activities.  One of these
companies, Nauticus Robotics, develops highly sophisticated, ultra-sustainable marine robots and intelligent software to power
them, and commercializes our patented HaloGuard℠ system, which alarms, notifies and, if required, halts equipment to avoid
injury to personnel who move into danger zones.  Nauticus Robotics has recently entered into a definitive business combination
agreement with a publicly traded special purpose acquisition company that will result in it becoming a publicly listed company.

Litigation settlement—In June 2020, the U.S. District Court for the Eastern District of Louisiana (the “MDL Court”)
released the then-remaining $125 million of assets held in the escrow account established to satisfy our remaining obligations
under the settlement agreement that we and the Plaintiff Steering Committee filed in May 2015 with the MDL Court, in which
most claims against us for damages related to the blowout of the Macondo well in April 2010 were consolidated by the U.S.
Judicial Panel on Multidistrict Litigation.  Following the release of assets, all significant litigation, including civil and criminal
claims, resulting from the Macondo well incident had been resolved.

Share repurchase program—In May 2009, at our annual general meeting, our shareholders approved and authorized
our board of directors, at its discretion, to repurchase an amount of our shares for cancellation with an aggregate purchase price
of up to CHF 3.50 billion.  On February 12, 2010, our board of directors authorized our management to implement the share
repurchase  program.    At  December  31,  2021,  the  authorization  remaining  under  the  share  repurchase  program  was  for  the
repurchase of up to CHF 3.24 billion, equivalent to approximately $3.55 billion, of our outstanding shares.  We intend to fund
any  repurchases  using  available  cash  balances  and  cash  from  operating  activities.    The  share  repurchase  program  could  be
suspended  or  discontinued  by  our  board  of  directors  or  company  management,  as  applicable,  at  any  time.    We  may  decide,
based on our ongoing capital requirements, the price of our shares, regulatory and tax considerations, cash flow generation, the
amount and duration of our contract backlog, general market conditions, debt rating considerations and other factors, that we
should retain cash, reduce debt, make capital investments or acquisitions or otherwise use cash for general corporate purposes.
 Decisions regarding the amount, if any, and timing of any share repurchases will be made from time to time based on these
factors.  Any repurchased shares under the share repurchase program would be held by us for cancellation by the shareholders at
a future general meeting of shareholders.  See “Item 5. Market for Registrant’s Common Equity, Related Shareholder Matters
and Issuer Purchases of Equity Securities—Shareholder Matters.”

Contractual obligations—At December 31, 2021, our contractual obligations stated at face value, were as follows:

Debt
Interest on debt
Finance lease liability
Operating lease liabilities
Purchase obligations
Service agreement obligations

Total

Years ending December 31,

Total

2022

    2023 - 2024    2025 - 2026    Thereafter  

(in millions)

$  7,243   $
 2,385
 541
 178
 1,002
 800

 524   $
 389
 71
 14
 950
 116

$  12,149   $  2,064   $

 1,661   $
 666
 141
 26
 52
 247
 2,793   $

 1,799   $  3,259
 875
 188
 113
 —
 173
 2,684   $  4,608

 455
 141
 25
 —
 264

As  of  December  31,  2021,  our  defined  benefit  pension  and  other  postemployment  plans  represented  an  aggregate
liability of $132 million, representing the aggregate projected benefit obligation, net of the aggregate fair value of plan assets.
  The  carrying  amount  of  this  liability  is  influenced  by,  among  others,  significant  current  and  future  assumptions,  funding
contributions,  returns  on  plan  assets,  participant  demographics,  and  plan  amendments.    We  excluded  this  amount  from  our
contractual  obligations  presented  above  due  to  the  uncertainties  resulting  from  these  factors  and  because  the  amount  is  not
representative of future liquidity requirements.  See Notes to Consolidated Financial Statements—Note 10—Postemployment
Benefit Plans.

As of December 31, 2021, we have unrecognized tax benefits of $435 million, including interest and penalties, against
which  we  have  recorded  net  operating  loss  deferred  tax  assets  of  $320  million,  resulting  in  net  unrecognized  tax  benefits  of
$115  million,  including  interest  and  penalties,  that  upon  reversal  would  favorably  impact  our  effective  tax  rate.   Although  a
portion  of  these  could  settle  or  reverse  in  the  coming  year,  we  have  excluded  this  amount  from  our  contractual  obligations
presented  above  due  to  the  high  degree  of  uncertainty  regarding  the  timing  of  future  cash  outflows  associated  with  these
liabilities  and  the  period  in  which  any  cash  settlement  may  be  made  with  the  respective  taxing  authorities.    See  Notes  to
Consolidated Financial Statements—Note 11—Income Taxes.

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Other  commercial  commitments—We  have  other  commercial  commitments,  such  as  standby  letters  of  credit  and
surety bonds that guarantee our performance as it relates to our drilling contracts, insurance, customs, tax and other obligations
in various jurisdictions.  The cash obligations of these commitments, which are primarily geographically concentrated in Brazil,
are not normally called because we typically comply with the underlying performance requirements.  Standby letters of credit
are  issued  under  various  committed  and  uncommitted  credit  lines,  some  of  which  require  cash  collateral.   At  December  31,
2021, the aggregate cash collateral held by banks for letters of credit and surety bonds was $8 million.

At December 31, 2021, these obligations stated in U.S. dollar equivalents and their time to expiration were as follows:

Years ending December 31,

Standby letters of credit
Surety bonds

Total

Total

2022

$

$

 18   $
 146
 164   $

 11
 1
 12

    2023 - 2024    2025 - 2026     Thereafter  
(in millions)
$

$

 7
 73
 80

$

$

 — $
 61
 61

$

 —
 11
 11

We have established a wholly owned captive insurance company to insure various risks of our operating subsidiaries.
 Access to the cash and cash equivalents of the captive insurance company may be limited due to local regulatory restrictions.
 At  December  31,  2021,  the  captive  insurance  company  held  cash  and  cash  equivalents  of  $52  million,  and  such  balance  is
expected to range from $25 million to $75 million through December 31, 2022.  The balance of the cash and cash equivalents
held by the captive insurance company varies, depending on (i) premiums received and (ii) the timing and magnitude of claims
and dividends paid by the captive insurance company.

Drilling fleet

Expansion—From  time  to  time,  we  review  possible  acquisitions  of  businesses  and  drilling  rigs,  as  well  as
noncontrolling interests in other companies, and we may make significant future capital commitments for such purposes.  We
may also consider investments related to major rig upgrades, new rig construction, or the acquisition of a rig under construction.
 Any  such  acquisition  or  investment  could  involve  the  payment  by  us  of  a  substantial  amount  of  cash  or  the  issuance  of  a
substantial  number  of  additional  shares  or  other  securities.    Our  failure  to  subsequently  secure  drilling  contracts  in  these
instances, if not already secured, could have an adverse effect on our results of operations or cash flows.

In  the  years  ended  December  31,  2021  and  2020,  we  made  capital  expenditures  of  $208  million  and  $265  million,
respectively, including $174 million and $143 million, respectively, for our newbuild construction projects.  The historical and
projected capital expenditures and non-cash capital additions for our ongoing newbuild construction projects were as follows:

Deepwater Atlas (a)
Deepwater Titan (b)

Total

Total costs
through
December 31, 
2021

$

$

$

 443
 512
 955   $

Years ending December 31,

2022

2023

Total

$

(In millions)
 610
 599
 1,209   $

$

 37
 59
 96   $

 1,090
 1,170
 2,260

(a) Deepwater Atlas, an ultra-deepwater drillship under construction at the Jurong Shipyard Pte Ltd. in Singapore.  We currently expect that
the shipyard will be ready to deliver Deepwater Atlas in the first half of 2022, and upon delivery, we expect to borrow approximately
$370 million under the Shipyard Loan, which may be discounted for imputed interest, to finance the final installment to the shipyard (see
“—Sources and uses of liquidity”).  The rig is expected to commence operations under its drilling contract, in the first of two phases, in
the  second  half  of  2022,  using  a  15,000  pounds  per  square  inch  blowout  preventer.    Before  the  start  of  the  second  phase,  the  rig  will
undergo installation of a 20,000 pounds per square inch blowout preventer and related equipment, which is expected to be commissioned
in the year ending December 31, 2023.

(b) Deepwater Titan, an ultra-deepwater drillship under construction at the Jurong Shipyard Pte Ltd. in Singapore.  We currently expect that
the shipyard will be ready to deliver Deepwater Titan in the second half of 2022, and upon delivery, we expect to borrow approximately
$90 million under the Shipyard Loan, which may be discounted for imputed interest, to finance a portion of the final installment to the
shipyard (see “—Sources and uses of liquidity”).  The rig is expected to commence operations under its drilling contract in the first half
of 2023.  The projected capital additions include estimates for an upgrade for two 20,000 pounds per square inch blowout preventers and
other equipment required by our customer.

The ultimate amount of our capital expenditures is partly dependent upon financial market conditions, the actual level
of  operational  and  contracting  activity,  the  costs  associated  with  the  current  regulatory  environment  and  customer  requested
capital improvements and equipment for which the customer agrees to reimburse us.  As with any major shipyard project that
takes place over an extended period of time, the actual costs, the timing of expenditures and the project completion date may
vary  from  estimates  based  on  numerous  factors,  including  actual  contract  terms,  weather,  exchange  rates,  shipyard  labor
conditions, availability of suppliers to recertify equipment and the market demand for components and resources required for
drilling unit construction.  We intend to fund the cash requirements relating to our capital expenditures not financed under the
Shipyard Loans by using available cash balances, cash generated from operations and asset sales, borrowings under our Secured
Credit Facility and financing arrangements with banks or other capital providers.  Economic conditions and other factors could
impact the availability of these sources of funding.  See “—Sources and uses of liquidity.”

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Dispositions—From time to time, we may also review the possible disposition of certain drilling assets.  Considering
market conditions, we have committed to plans to sell certain lower specification drilling units for scrap value.  During the two-
year period ended December 31, 2021, we identified eight such drilling units that we sold for scrap value or other purposes.
 During the year ended December 31, 2021, we completed the sale of one harsh environment floater and related assets, and we
received  net  cash  proceeds  of  $4  million.    During  the  year  ended  December  31,  2020,  we  completed  the  sale  of  one  ultra-
deepwater  floater,  three  harsh  environment  floaters  and  three  midwater  floaters,  along  with  related  assets,  and  we  received
aggregate net cash proceeds of $20 million.  We continue to evaluate the drilling units in our fleet and may identify additional
lower-specification drilling units to be sold for scrap value.

RELATED PARTY TRANSACTIONS

We  engage  in  certain  related  party  transactions  with  our  unconsolidated  affiliates,  the  most  significant  of  which  are
under agreements with Orion.  We have a management services agreement for the operation, stacking and maintenance of the
harsh environment floater Transocean Norge and a marketing services agreement for the marketing of the rig.  We also leased
the rig under a short-term bareboat charter agreement, which expired in June 2021.  Prior to the rig’s placement into service, we
engaged  in  certain  related  party  transactions  with  Orion  under  a  shipyard  care  agreement  for  the  construction  of  the  rig  and
other  matters  related  to  its  completion  and  delivery.   Additionally,  in  June  2021,  Orion  refinanced  its  shipyard  loans  under  a
financing  arrangement  for  $100  million,  in  which  we  participated  at  a  rate  equivalent  to  our  ownership  interest  in  Orion.
  Borrowings  under  the  financing  arrangement  are  secured  by  Transocean  Norge.    See  Notes  to  Consolidated  Financial
Statements—Note 4—Unconsolidated Affiliates.

In  August  2020,  Perestroika AS,  an  entity  affiliated  with  one  of  our  directors  that  beneficially  owns  approximately
10  percent  of  our  shares,  exchanged  $356  million  aggregate  principal  amount  of  the  0.50%  Exchangeable  Senior  Bonds  for
$213  million  aggregate  principal  amount  of  2.50%  Senior  Guaranteed  Exchangeable  Bonds.    Perestroika  AS  has  certain
registration  rights  related  to  its  shares  and  shares  that  may  be  issued  in  connection  with  any  exchange  of  its  2.50%  Senior
Guaranteed Exchangeable Bonds.  See Notes to Consolidated Financial Statements—Note 9—Debt.

CRITICAL ACCOUNTING POLICIES AND ESTIMATES

Overview—We  prepare  our  consolidated  financial  statements  in  accordance  with  accounting  principles  generally
accepted  in  the  U.S.,  which  require  us  to  make  estimates  that  affect  the  reported  amounts  of  assets,  liabilities,  revenues,
expenses  and  related  disclosures  of  contingent  assets  and  liabilities.    These  estimates  require  significant  judgments  and
assumptions.    On  an  ongoing  basis,  we  evaluate  our  estimates,  including  those  related  to  our  income  taxes,  property  and
equipment,  equity  investments,  contingencies,  assets  held  for  sale,  intangibles,  allowance  for  excess  materials  and  supplies,
allowance  for  credit  losses,  postemployment  benefit  plans,  leases  and  share-based  compensation.    We  base  our  estimates  on
historical experience and on various other assumptions that we believe are reasonable under the circumstances, the results of
which  form  the  basis  for  making  judgments  about  the  carrying  amounts  of  assets  and  liabilities  that  are  not  readily  apparent
from other sources.  Actual results may differ from these estimates.

We  consider  the  following  to  be  our  critical  accounting  policies  and  estimates  since  they  are  very  important  to  the
portrayal of our financial condition and results and require our most subjective and complex judgments.  We have discussed the
development, selection and disclosure of such policies and estimates with the audit committee of our board of directors.  For a
discussion of our significant accounting policies and accounting standards updates, refer to our Notes to Consolidated Financial
Statements—Note 2—Significant Accounting Policies and Note 3—Accounting Standards Update.

Income  taxes—We  provide  for  income  taxes  based  on  expected  taxable  income,  statutory  rates,  tax  laws  and  tax
planning  opportunities  available  to  us  in  the  jurisdictions  in  which  we  operate  or  have  a  taxable  presence.    The  relationship
between our provision for or benefit from income taxes and our income or loss before income taxes can vary significantly from
period to period considering, among other factors, (a) the overall level of income before income taxes, (b) changes in the blend
of income that is taxed based on gross revenues rather than income before taxes, (c) rig movements between taxing jurisdictions
and (d) our rig operating structures.  Consequently, our income tax expense does not change proportionally with our income or
loss before income taxes.

Uncertain tax positions—We apply significant judgment to evaluate our tax positions based on the interpretation of tax
laws  in  various  jurisdictions  and  with  the  use  of  estimates  and  assumptions  regarding  significant  future  events,  such  as  the
amount, timing and character of income, deductions and tax credits.  Our tax liability in any given year could be affected by
changes  in  tax  laws,  regulations,  agreements,  and  treaties,  currency  exchange  restrictions  or  our  level  or  profitability  of
operations  in  each  jurisdiction.    The  tax  laws  relating  to  the  offshore  drilling  industry  in  certain  jurisdictions  in  which  we
operate are not well developed, requiring us to apply incremental judgment.  Although we employ the best information available
at  the  time  we  prepare  our  annual  tax  provision,  a  number  of  years  may  elapse  before  the  tax  liabilities  in  the  various
jurisdictions are ultimately determined.

We are undergoing examinations of our tax returns in a number of taxing jurisdictions for various years.  We review
our  liabilities  on  an  ongoing  basis  and,  to  the  extent  audits  or  other  events  cause  us  to  adjust  the  liabilities  accrued  in  prior
periods, we recognize those adjustments in the period of the event.  Our tax liabilities are dependent on numerous factors that
cannot be reasonably projected, including among others, the amount and nature of additional taxes potentially asserted by local
tax  authorities;  the  willingness  of  local  tax  authorities  to  negotiate  a  fair  settlement  through  an  administrative  process;  the
impartiality of the local courts; and the potential for changes in the taxes

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paid to one country that either produce, or fail to produce, offsetting tax changes in other countries.  Consequently, we cannot
reasonably estimate the future impact of changes to the assumptions and estimates related to our annual tax provision.

Unrecognized  tax  benefits—We  establish  liabilities  for  estimated  tax  exposures,  and  the  provisions  and  benefits
resulting  from  changes  to  those  liabilities  are  included  in  our  annual  tax  provision  along  with  related  interest  and  penalties.
  Such  tax  exposures  include  potential  challenges  to  permanent  establishment  positions,  intercompany  pricing,  disposition
transactions, and withholding tax rates and their applicability.  These exposures may be affected by changes in applicable tax
law or other factors, which could cause us to revise our prior estimates, and are generally resolved through the settlement of
audits within these tax jurisdictions or by judicial means.  At December 31, 2021 and 2020, our unrecognized tax benefits were
approximately $435 million and $419 million, respectively.

Valuation allowance—We  apply  significant  judgment  to  determine  whether  our  deferred  tax  assets  will  be  fully  or
partially realized.  Our evaluation requires us to consider all available positive and negative evidence, including projected future
taxable income and the existence of cumulative losses in recent years.  We continually evaluate strategies that could allow for
the  future  utilization  of  our  deferred  tax  assets.   When  it  is  estimated  to  be  more  likely  than  not  that  all  or  some  portion  of
certain deferred tax assets, such as foreign tax credit carryovers or net operating loss carryforwards, will not be realized, we
establish a valuation allowance for the amount of the deferred tax assets that is considered to be unrealizable.  During the years
ended December 31, 2021 and 2020, in connection with our evaluation of the projected realizability of our deferred tax assets,
we  determined  that  our  consolidated  cumulative  loss  incurred  over  the  recent  three-year  period  has  limited  our  ability  to
consider other subjective evidence, such as projected contract activity rather than contract backlog.  See Notes to Consolidated
Financial Statements—Note 11—Income Taxes.

Property  and  equipment—We  apply  significant  judgment  to  account  for  our  property  and  equipment,  consisting
primarily  of  offshore  drilling  rigs  and  related  equipment,  related  to  estimates  and  assumptions  for  cost  capitalization,  useful
lives  and  salvage  values.    At  December  31,  2021  and  2020,  the  carrying  amount  of  our  property  and  equipment  was
$17.10 billion and $17.67 billion, respectively, representing 83 percent and 81 percent, respectively, of our total assets.

Capitalized costs—We capitalize costs incurred to enhance, improve and extend the useful lives of our property and
equipment  and  expense  costs  incurred  to  repair  and  maintain  the  existing  condition  of  our  rigs.    For  newbuild  construction
projects, we also capitalize the initial preparation, mobilization and commissioning costs incurred until the drilling unit is placed
into service.  Capitalized costs increase the carrying amounts of, and depreciation expense for, the related assets, which also
impact our results of operations.

Useful lives and salvage values—We depreciate our assets using the straight-line method over their estimated useful
lives after allowing for salvage values.  We estimate useful lives and salvage values by applying judgments and assumptions
that  reflect  both  historical  experience  and  expectations  regarding  future  operations,  rig  utilization  and  asset  performance.
 Useful lives and salvage values of rigs are difficult to estimate due to a variety of factors, including (a) technological advances
that impact the methods or cost of oil and gas exploration and development, (b) changes in market or economic conditions and
(c) changes in laws or regulations affecting the drilling industry.  Applying different judgments and assumptions in establishing
the useful lives and salvage values would likely result in materially different net carrying amounts and depreciation expense for
our  assets.    We  reevaluate  the  remaining  useful  lives  and  salvage  values  of  our  rigs  when  certain  events  occur  that  directly
impact the useful lives and salvage values of the rigs, including changes in operating condition, functional capability and market
and economic factors.  We may also consider major capital upgrades required to perform certain contracts and the long-term
impact of those upgrades on future marketability.  At December 31, 2021, a hypothetical one-year increase in the useful lives of
all of our rigs would cause a decrease in our annual depreciation expense of approximately $31 million and a hypothetical one-
year decrease would cause an increase in our annual depreciation expense of approximately $36 million.

Long-lived  asset  impairment—We  review  our  property  and  equipment  for  impairment  when  events  or  changes  in
circumstances  indicate  that  the  carrying  amounts  of  our  assets  held  and  used  may  not  be  recoverable.    Potential  impairment
indicators  include  rapid  declines  in  commodity  prices  and  related  market  conditions,  declines  in  dayrates  or  utilization,
cancellations of contracts or credit concerns of multiple customers.  During periods of oversupply, we may idle or stack rigs for
extended periods of time or we may elect to sell certain rigs for scrap, which could be an indication that an asset group may be
impaired since supply and demand are the key drivers of rig utilization and our ability to contract our rigs at economical rates.
 Our rigs are mobile units, equipped to operate in geographic regions throughout the world and, consequently, we may mobilize
rigs from an oversupplied region to a more lucrative and undersupplied region when it is economical to do so.  Many of our
contracts generally allow our customers to relocate our rigs from one geographic region to another, subject to certain conditions,
and our customers utilize this capability to meet their worldwide drilling requirements.  Accordingly, our rigs are considered to
be interchangeable within classes or asset groups, and we evaluate impairment by asset group.  We consider our asset groups to
be ultra-deepwater floaters and harsh environment floaters.

We  assess  recoverability  of  assets  held  and  used  by  projecting  undiscounted  cash  flows  for  the  asset  group  being
evaluated.  When the carrying amount of the asset group is determined to be unrecoverable, we recognize an impairment loss,
measured as the amount by which the carrying amount of the asset group exceeds its estimated fair value.  To estimate the fair
value of each asset group, we apply a variety of valuation methods, incorporating income, market and cost approaches.  We may
weigh the approaches, under certain circumstances, when relevant data is limited, when results are inconclusive or when results
deviate significantly.  Our estimate of fair value generally requires us to use significant unobservable inputs, representative of
Level 3 fair value measurements, including assumptions related to the long-term future performance of our asset groups, such as
projected revenues and costs, dayrates, rig utilization and revenue efficiency.  These projections involve uncertainties that rely
on assumptions about demand for our services, future market conditions and

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technological developments.  Because our business is cyclical in nature, the results of our impairment testing are expected to
vary significantly depending on the timing of the assessment relative to the business cycle.  Altering either the timing of or the
assumptions  used  to  estimate  fair  value  and  significant  unanticipated  changes  to  the  assumptions  could  materially  alter  an
outcome  that  could  otherwise  result  in  an  impairment  loss.    Given  the  nature  of  these  evaluations  and  their  application  to
specific  asset  groups  and  specific  time  periods,  it  is  not  possible  to  reasonably  quantify  the  impact  of  changes  in  these
assumptions.  In the year ended December 31, 2020, we recognized a loss of $31 million, which had no tax effect, associated
with  the  impairment  of  the  midwater  floater  asset  group.    See  Notes  to  Consolidated  Financial  Statements—Note 7—Long-
Lived Assets.

Equity-method investments and impairment—We review our equity-method investments for potential impairment
when events or changes in circumstances indicate that the carrying amount of the investment might not be recoverable in the
near  term.    Such  circumstances  include  the  following:  (a)  evidence  we  are  unable  to  recover  the  carrying  amount  of  our
investment, (b) evidence that the investee is unable to sustain earnings that would justify the carrying amount or (c) the current
fair value of the investment is less than the carrying amount.  If an evaluation of such circumstances results in the determination
that an impairment that is other than temporary exists, we recognize an impairment loss, measured as the amount by which the
carrying  amount  of  the  investment  exceeds  its  estimated  fair  value.    To  estimate  the  fair  value  of  the  investment,  we  apply
valuation methods that rely primarily on the income and market approaches.  Our estimate of fair value generally requires us to
use  significant  unobservable  inputs,  representative  of  Level  3  fair  value  measurements,  including  assumptions  related  to  the
estimated  discount  rate  and  the  investee’s  long-term  future  operational  performance  factors,  such  as  projected  revenues  and
costs  and  market  factors,  including  demand  for  the  investee’s  industry,  services  and  product  lines.    Such  projections  involve
significant uncertainties and require significant judgment.  In the years ended December 31, 2021 and 2020, we recognized a
loss of $37 million and $59 million, respectively, associated with an other-than-temporary impairment of the carrying amount of
our equity-method investments.  See Notes to Consolidated Financial Statements—Note 4—Unconsolidated Affiliates.

OTHER MATTERS

Regulatory matters

We occasionally receive inquiries from governmental regulatory agencies regarding our operations around the world,
including  inquiries  with  respect  to  various  tax,  environmental,  regulatory  and  compliance  matters.   To  the  extent  appropriate
under the circumstances, we investigate such matters, respond to such inquiries and cooperate with the regulatory agencies.  See
Notes to Consolidated Financial Statements—Note 13—Commitments and Contingencies.

Tax matters

We conduct operations through our various subsidiaries in countries throughout the world.  Each country has its own
tax regimes with varying nominal rates, deductions and tax attributes that are subject to changes resulting from new legislation,
interpretation or guidance.  From time to time, as a result of these changes, we may revise previously evaluated tax positions,
which could cause us to adjust our recorded tax assets and liabilities.  Tax authorities in certain jurisdictions are examining our
tax returns and, in some cases, have issued assessments.  We intend to defend our tax positions vigorously.  Although we can
provide  no  assurance  as  to  the  outcome  of  the  aforementioned  changes,  examinations  or  assessments,  we  do  not  expect  the
ultimate liability to have a material adverse effect on our consolidated financial position or results of operations; however, it
could have a material adverse effect on our consolidated cash flows.  See Notes to Consolidated Financial Statements—Note 11
—Income Taxes.

ITEM 7A.QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK

Interest  rate  risk—We  are  exposed  to  interest  rate  risk,  primarily  associated  with  our  long-term  debt,  including
current maturities.  The following table presents the scheduled installment amounts and related weighted-average interest rates
of  our  long-term  debt  instruments  by  contractual  maturity  date.    The  scheduled  installment  amounts  include  the  contractual
principal  and  interest  payments  resulting  from  previously  restructured  debt.    The  following  table  presents  information  as  of
December  31,  2021  for  each  of  the  five  years  in  the  period  ending  December  31,  2026  and  thereafter  (in  millions,  except
interest rate percentages):

2022

Years ending December 31,
2024

2023

2025

2026

Thereafter

Total

    Fair value 

Debt
Fixed rate (USD)

Average interest rate

  $

$

 524
 5.49 %  

$

 798
 4.58 %  

 863
 6.01 %  

$  1,069

$

 5.65 %  

 730
 6.71 %  

$  3,259

$  7,243

$  5,661

 5.47 %  

At  December  31,  2021  and  2020,  the  fair  value  of  our  outstanding  debt  was  $5.66  billion  and  $4.82  billion,
respectively.    During  the  year  ended  December  31,  2021,  the  fair  value  of  our  debt  increased  by  $841  million  due  to  the
following:  (a)  a  net  increase  of  $1.24  billion  resulting  from  changes  in  the  market  prices  of  our  outstanding  debt,  (b)  a  net
increase of $117 million due to the issuance of the 4.00% senior guaranteed exchangeable bonds due December 2025 in private
exchanges for the 0.50% exchangeable senior bonds due January 2023, partially offset by (c) a decrease of $474 million due to
repayments of debt at scheduled maturities and (d) a decrease of $43 million due to debt repurchased in the open market.  See
Notes to Consolidated Financial Statements—Note 9—Debt.

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The  majority  of  our  cash  equivalents  is  subject  to  variable  interest  rates  or  short-term  interest  rates  and  such  cash

equivalents would earn commensurately higher rates of return if interest rates increase.

Currency  exchange  rate  risk—We  are  exposed  to  currency  exchange  rate  risk  primarily  related  to  employee
compensation costs and purchasing costs that are denominated in currencies other than our functional currency, the U.S. dollar.
 We use a variety of techniques to minimize the exposure to currency exchange rate risk, including the structuring of customer
contract payment terms and occasional use of forward exchange contracts.  Our primary tool to manage currency exchange rate
risk  involves  structuring  customer  contracts  to  provide  for  payment  in  both  U.S.  dollars  and  local  currency.    The  payment
portion  denominated  in  local  currency  is  based  on  anticipated  local  currency  requirements  over  the  contract  term.    Due  to
various factors, including customer acceptance, local banking laws, national content requirements, other statutory requirements,
local currency convertibility, local inflation and revenue efficiency, actual local currency needs may vary from those realized in
the  customer  contracts,  resulting  in  partial  exposure  to  currency  exchange  rate  risk.    The  currency  exchange  effect  resulting
from our international operations generally has not had a material impact on our operating results.  See Notes to Consolidated
Financial Statements—Note 19—Risk Concentration.

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ITEM 8. FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA

Management’s Report on Internal Control Over Financial Reporting

Management of Transocean Ltd. (the “Company,” “we” or “our”) is responsible for the integrity and objectivity of the
financial information included in this annual report.  We have prepared our financial statements in accordance with accounting
principles  generally  accepted  in  the  United  States,  which  require  us  to  apply  our  best  judgement  to  make  estimates  and
assumptions  for  certain  amounts.    We  are  responsible  for  establishing  and  maintaining  a  system  of  internal  controls  and
procedures  to  provide  reasonable  assurance  regarding  the  reliability  of  financial  reporting  and  the  preparation  of  the
consolidated  financial  statements.    Our  internal  control  system  is  supported  by  a  program  of  internal  audits  and  appropriate
reviews  by  management,  written  policies  and  guidelines,  careful  selection  of  qualified  personnel,  and  a  written  Code  of
Integrity.  Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements
and,  even  when  determined  to  be  effective,  can  only  provide  reasonable  assurance  with  respect  to  financial  statement
preparation and presentation.  Also, projections of any evaluation of effectiveness in future periods are subject to the risk that
controls  may  become  inadequate  because  of  changes  in  conditions,  or  that  the  degree  of  compliance  with  the  policies  or
procedures may deteriorate.

Management of the Company is responsible for establishing and maintaining adequate internal control over financial
reporting as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934.  Management assessed the
effectiveness of the Company’s internal control over financial reporting as of December 31, 2021.  In making this assessment,
management  used  the  criteria  set  forth  by  the  Committee  of  Sponsoring  Organizations  of  the  Treadway  Commission,  as
described in Internal  Control-Integrated  Framework,  as  published  in  2013.    Based  on  this  assessment,  management  believes
that the Company maintained effective internal control over financial reporting as of December 31, 2021.

The Company’s independent auditors, Ernst & Young LLP, a registered public accounting firm, are appointed by the
audit  committee  of  the  Company’s  board  of  directors,  subject  to  ratification  by  our  shareholders.    Ernst  &  Young  LLP  has
audited and reported on the consolidated financial statements of Transocean Ltd. and subsidiaries, and the Company’s internal
control over financial reporting.  The reports of the independent auditors are contained in this annual report.

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Report of Independent Registered Public Accounting Firm

To the Shareholders and the Board of Directors of Transocean Ltd.

Opinion on Internal Control over Financial Reporting

We have audited Transocean Ltd. and subsidiaries’ internal control over financial reporting as of December 31, 2021, based on
criteria  established  in  Internal  Control—Integrated  Framework  issued  by  the  Committee  of  Sponsoring  Organizations  of  the
Treadway Commission (2013 framework) (the COSO criteria).  In our opinion, Transocean Ltd. and subsidiaries (the Company)
maintained, in all material respects, effective internal control over financial reporting as of December 31, 2021, based on the
COSO criteria.

We  also  have  audited,  in  accordance  with  the  standards  of  the  Public  Company  Accounting  Oversight  Board  (United  States)
(PCAOB), the consolidated balance sheets of the Company as of December 31, 2021 and 2020, and the related consolidated
statements  of  operations,  comprehensive  loss,  equity  and  cash  flows  for  each  of  the  three  years  in  the  period  ended
December 31, 2021, and the related notes and financial statement schedule listed in the Index at Item 15(a), and our report dated
February 23, 2022, expressed an unqualified opinion thereon.

Basis for Opinion

The  Company’s  management  is  responsible  for  maintaining  effective  internal  control  over  financial  reporting  and  for  its
assessment of the effectiveness of internal control over financial reporting included in the accompanying Management’s Report
on  Internal  Control  over  Financial  Reporting.    Our  responsibility  is  to  express  an  opinion  on  the  Company’s  internal  control
over financial reporting based on our audit.  We are a public accounting firm registered with the PCAOB and are required to be
independent  with  respect  to  the  Company  in  accordance  with  the  U.S.  federal  securities  laws  and  the  applicable  rules  and
regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB.  Those standards require that we plan and perform the
audit  to  obtain  reasonable  assurance  about  whether  effective  internal  control  over  financial  reporting  was  maintained  in  all
material respects.

Our  audit  included  obtaining  an  understanding  of  internal  control  over  financial  reporting,  assessing  the  risk  that  a  material
weakness exists, testing and evaluating the design and operating effectiveness of internal control based on the assessed risk, and
performing  such  other  procedures  as  we  considered  necessary  in  the  circumstances.    We  believe  that  our  audit  provides  a
reasonable basis for our opinion.

Definition and Limitations of Internal Control Over Financial Reporting

A  company’s  internal  control  over  financial  reporting  is  a  process  designed  to  provide  reasonable  assurance  regarding  the
reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally
accepted accounting principles.  A company’s internal control over financial reporting includes those policies and procedures
that  (1)  pertain  to  the  maintenance  of  records  that,  in  reasonable  detail,  accurately  and  fairly  reflect  the  transactions  and
dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit
preparation  of  financial  statements  in  accordance  with  generally  accepted  accounting  principles,  and  that  receipts  and
expenditures  of  the  company  are  being  made  only  in  accordance  with  authorizations  of  management  and  directors  of  the
company;  and  (3)  provide  reasonable  assurance  regarding  prevention  or  timely  detection  of  unauthorized  acquisition,  use,  or
disposition of the company’s assets that could have a material effect on the financial statements.

Because  of  its  inherent  limitations,  internal  control  over  financial  reporting  may  not  prevent  or  detect  misstatements.   Also,
projections  of  any  evaluation  of  effectiveness  to  future  periods  are  subject  to  the  risk  that  controls  may  become  inadequate
because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate

/s/ Ernst & Young LLP

Houston, Texas
February 23, 2022

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Report of Independent Registered Public Accounting Firm

To the Shareholders and the Board of Directors of Transocean Ltd.

Opinion on the Financial Statements

We  have  audited  the  accompanying  consolidated  balance  sheets  of  Transocean  Ltd.  and  subsidiaries  (the  Company)  as  of
December 31, 2021 and 2020, the related consolidated statements of operations, comprehensive loss, equity and cash flows for
each of the three years in the period ended December 31, 2021, and the related notes and financial statement schedule listed in
the  Index  at  Item  15(a)  (collectively  referred  to  as  the  consolidated  financial  statements).    In  our  opinion,  the  consolidated
financial  statements  present  fairly,  in  all  material  respects,  the  financial  position  of  the  Company  at  December  31,  2021  and
2020, and the results of its operations and its cash flows for each of the three years in the period ended December 31, 2021, in
conformity with U.S. generally accepted accounting principles.

We  also  have  audited,  in  accordance  with  the  standards  of  the  Public  Company  Accounting  Oversight  Board  (United  States)
(PCAOB),  the  Company's  internal  control  over  financial  reporting  as  of  December  31,  2021,  based  on  criteria  established  in
Internal  Control-Integrated  Framework  issued  by  the  Committee  of  Sponsoring  Organizations  of  the  Treadway  Commission
(2013 framework) and our report dated February 23, 2022, expressed an unqualified opinion thereon.

Basis for Opinion

These financial statements are the responsibility of the Company's management.  Our responsibility is to express an opinion on
the Company’s financial statements based on our audits.  We are a public accounting firm registered with the PCAOB and are
required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable
rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB.  Those standards require that we plan and perform the
audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to
error  or  fraud.    Our  audits  included  performing  procedures  to  assess  the  risks  of  material  misstatement  of  the  financial
statements,  whether  due  to  error  or  fraud,  and  performing  procedures  that  respond  to  those  risks.    Such  procedures  included
examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements.  Our audits also included
evaluating  the  accounting  principles  used  and  significant  estimates  made  by  management,  as  well  as  evaluating  the  overall
presentation of the financial statements.  We believe that our audits provide a reasonable basis for our opinion.

Critical Audit Matters

The critical audit matters communicated below are matters arising from the current period audit of the financial statements that
were communicated or required to be communicated to the audit committee and that: (1) relate to accounts or disclosures that
are  material  to  the  financial  statements  and  (2)  involved  our  especially  challenging,  subjective,  or  complex  judgments.    The
communication of the critical audit matters does not alter in any way our opinion on the consolidated financial statements, taken
as a whole, and we are not, by communicating the critical audit matters below, providing separate opinions on the critical audit
matters or on the accounts or disclosures to which they relate.

Description of the
Matter

Income Taxes

As  discussed  in  Notes  2  and  11  to  the  consolidated  financial  statements,  the  Company  operates  in
multiple  jurisdictions  through  a  complex  operating  structure  and  is  subject  to  applicable  tax  laws,
treaties  or  regulations  in  each  jurisdiction  where  it  operates.    The  Company’s  provision  for  income
taxes is based on the tax laws and rates applicable in each jurisdiction.  The Company recognizes tax
benefits  they  believe  are  more  likely  than  not  to  be  sustained  upon  examination  by  the  taxing
authorities based on the technical merits of the position.

Auditing management’s provision for income taxes and related deferred taxes was complex because of
the  Company’s  multi-national  operating  structure.    In  addition,  a  higher  degree  of  auditor  judgment
was  required  to  evaluate  the  Company’s  deferred  tax  provision  as  a  result  of  the  Company’s
interpretation of tax law in each jurisdiction across its multiple subsidiaries.

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How We Addressed
the Matter in Our
Audit

We obtained an understanding, evaluated the design and tested the operating effectiveness of controls
over  the  Company’s  income  tax  provision  process,  including  controls  over  management’s  review  of
the identification and valuation of deferred income taxes and changes in tax laws and regulations that
may impact the Company’s deferred income tax provision.

Description of the
Matter

Our  audit  procedures  also  included,  among  others,  (i)  obtaining  an  understanding  of  the  Company’s
overall tax structure, evaluating changes in the Company’s tax structure that occurred during the year
as  well  as  changes  in  tax  law,  and  assessing  the  interpretation  of  those  changes  under  the  relevant
jurisdiction’s  tax  law;  (ii)  utilizing  tax  resources  with  appropriate  knowledge  of  local  jurisdictional
laws  and  regulations;  (iii)  evaluating  the  completeness  and  accuracy  of  deferred  income  taxes,  and
(iv)  assessing  the  reasonableness  of  the  Company’s  valuation  allowance  on  deferred  tax  assets,
including  projections  of  taxable  income  from  the  future  reversal  of  existing  taxable  temporary
differences.

Equity-Method Investment in Orion Holdings (Cayman) Limited

As discussed in Notes 2 and 4, the Company recorded an impairment loss of $37 million associated
with its equity-method investment in Orion Holdings (Cayman) Limited (Orion) upon determination
that the carrying amount of its investment exceeded the estimated fair value and that the impairment
was other than temporary.   At December 31, 2021, the aggregate carrying amount of the Company’s
equity-method investment in Orion was $57 million.

Auditing management’s equity-method investment valuation was complex and judgmental due to the
estimation  required  in  determining  the  fair  value  of  the  investment.    In  particular,  the  fair  value
estimate of the equity-method investment in Orion was sensitive to significant assumptions such as the
discount  rate,  future  demand  and  supply  of  harsh  environment  floaters,  rig  utilization,  revenue
efficiency and dayrates.

How We Addressed
the Matter in Our
Audit

We obtained an understanding, evaluated the design and tested the operating effectiveness of controls
over the Company’s process to determine the fair value of the investment in Orion, including controls
over  management’s  review  of  the  significant  assumptions  described  above  as  well  as  over  the
underlying data used in the fair value determination.

To test the estimated fair value of the Company’s equity-method investment in Orion, we performed
audit  procedures  that  included,  among  others,  assessing  the  valuation  methodologies  utilized  by
management  and  testing  the  significant  assumptions  discussed  above  and  the  completeness  and
accuracy  of  the  underlying  data  used  by  the  Company  in  its  analysis.    We  involved  a  valuation
specialist to assist in our evaluation of the Company's model, valuation methodology and significant
assumptions.  We reviewed for contrary evidence related to the determination of the fair value of the
equity-method investment, including reviewing relevant market data and internal Company forecasts.

/s/ Ernst & Young LLP

We have served as the Company’s auditor since 1999.
Houston, Texas
February 23, 2022

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TRANSOCEAN LTD. AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF OPERATIONS
(In millions, except per share data)

Years ended December 31, 
2020

2019

2021

Contract drilling revenues

Costs and expenses

Operating and maintenance
Depreciation and amortization
General and administrative

Loss on impairment
Loss on disposal of assets, net
Operating loss

Other income (expense), net

Interest income
Interest expense, net of amounts capitalized
Gain (loss) on restructuring and retirement of debt
Other, net

Loss before income tax expense
Income tax expense

Net loss
Net income (loss) attributable to noncontrolling interest
Net loss attributable to controlling interest

Loss per share, basic and diluted
Weighted-average shares, basic and diluted

See accompanying notes.

- 45 -

$ 2,556

$

3,152   $

3,088

1,697
742
167
2,606
—
(62)
(112)

15
(447)
51
23
(358)
(470)
121

2,000
781
183
2,964
(597)
(84)
(493)

21
(575)
533
(27)
(48)
(541)
27

2,140
855
193
3,188
(609)
(12)
(721)

43
(660)
(41)
181
(477)
(1,198)
59

(591)
1
(592) $

(568)
(1)

(1,257)
(2)
(567)  $ (1,255)

(0.93) $

(0.92)  $

637

615

(2.05)
612

$

$

 
   
    
    
  
 
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TRANSOCEAN LTD. AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF COMPREHENSIVE LOSS
(In millions)

Years ended December 31, 
2020

2019

2021

Net loss
Net income (loss) attributable to noncontrolling interest
Net loss attributable to controlling interest

Components of net periodic benefit income (costs) before reclassifications
Components of net periodic benefit costs reclassified to net loss

Other comprehensive income (loss) before income taxes
Income taxes related to other comprehensive income (loss)
Other comprehensive income (loss)
Other comprehensive income attributable to noncontrolling interest
Other comprehensive income (loss) attributable to controlling interest

Total comprehensive loss
Total comprehensive income (loss) attributable to noncontrolling interest
Total comprehensive loss attributable to controlling interest

$

(591) $
1
(592)

(568) $ (1,257)
(2)
(1,255)

(1)
(567)

175
10

185
(6)
179
—
179

38
25

63
(2)
61
—
61

(25)
4

(21)
—
(21)
—
(21)

(412)
1
(413) $

(507)
(1)

(1,278)
(2)
(506) $ (1,276)

$

See accompanying notes.

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Table of Contents

TRANSOCEAN LTD. AND SUBSIDIARIES
CONSOLIDATED BALANCE SHEETS
(In millions, except share data)

Assets
Cash and cash equivalents
Accounts receivable, net
Materials and supplies, net
Restricted cash and cash equivalents
Other current assets

Total current assets

Property and equipment
Less accumulated depreciation

Property and equipment, net

Contract intangible assets
Deferred tax assets, net
Other assets

Total assets

Liabilities and equity
Accounts payable
Accrued income taxes
Debt due within one year
Other current liabilities

Total current liabilities

Long-term debt
Deferred tax liabilities, net
Other long-term liabilities

Total long-term liabilities

Commitments and contingencies

Shares, CHF 0.10 par value, 891,379,306 authorized, 142,363,356 conditionally authorized, 728,176,456 issued
and 655,505,335 outstanding at December 31, 2021, and 824,650,660 authorized, 142,363,647 conditionally
authorized, 639,676,165 issued and 615,140,276 outstanding at December 31, 2020

Additional paid-in capital
Accumulated deficit
Accumulated other comprehensive loss

Total controlling interest shareholders’ equity
Noncontrolling interest

Total equity
Total liabilities and equity

See accompanying notes.

- 47 -

December 31, 

2021

2020

$

$

$

$

976
492
392
436
148
2,444

23,152
(6,054)
17,098
173
7
959
20,681

228
17
513
545
1,303

6,657
447
1,068
8,172

64
13,683
(2,458)
(84)
11,205
1
11,206
20,681

$

$

$

$

1,154
583
434
406
163
2,740

23,040
(5,373)
17,667
393
9
995
21,804

194
28
505
659
1,386

7,302
315
1,366
8,983

60
13,501
(1,866)
(263)
11,432
3
11,435
21,804

 
 
    
  
 
Table of Contents

Shares
Balance, beginning of period
Issuance of shares

Balance, end of period

TRANSOCEAN LTD. AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF EQUITY
(In millions)

Years ended December 31, 
  2021    2020    2019   
Quantity

Years ended December 31, 
2020
2019
2021
Amount

615
40
655

612
3
615

610
2
612

$

$

60 $
4
64 $

59 $
1
60 $

59
—
59

Additional paid-in capital
Balance, beginning of period
Share-based compensation
Issuance of shares
Equity component of convertible debt instruments
Reallocated capital for transactions with holders of noncontrolling interest
Other, net

Balance, end of period

Accumulated deficit
Balance, beginning of period
Net loss attributable to controlling interest
Effect of adopting accounting standards updates

Balance, end of period

Accumulated other comprehensive loss
Balance, beginning of period
Other comprehensive income (loss) attributable to controlling interest
Effect of adopting accounting standards update

Balance, end of period

Total controlling interest shareholders’ equity
Balance, beginning of period
Total comprehensive loss attributable to controlling interest
Share-based compensation
Issuance of shares
Equity component of convertible debt instruments
Reallocated capital for transactions with holders of noncontrolling interest
Other, net

Balance, end of period

Noncontrolling interest
Balance, beginning of period
Total comprehensive income (loss) attributable to noncontrolling interest
Acquisition of noncontrolling interest
Reallocated capital for transactions with holders of noncontrolling interest

Balance, end of period

Total equity
Balance, beginning of period
Total comprehensive loss
Share-based compensation
Issuance of shares
Equity component of convertible debt instrument
Other, net

Balance, end of period

See accompanying notes.

- 48 -

$13,501 $13,424 $ 13,394
37
—
—
—
(7)
$13,683 $13,501 $ 13,424

28
154
—
—
—

31
(1)
46
1
—

$ (1,866) $ (1,297) $

(67)
(1,255)
25
$ (2,458) $ (1,866) $ (1,297)

(592)
—

(567)
(2)

$ (263) $ (324) $

179
—
(84) $ (263) $

61
—

$

(279)
(21)
(24)
(324)

$11,432 $11,862 $ 13,107
(1,276)
37
—
—
—
(6)
$11,205 $11,432 $ 11,862

(506)
31
—
46
1
(2)

(413)
28
158
—
—
—

$

$

3 $
1
(3)
—
1 $

5 $
(1)
—
(1)
3 $

7
(2)
—
—
5

$11,435 $11,867 $ 13,114
(1,278)
37
—
—
(6)
$11,206 $11,435 $ 11,867

(412)
28
158
—
(3)

(507)
31
—
46
(2)

  
  
 
Table of Contents

TRANSOCEAN LTD. AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF CASH FLOWS
(In millions)

Years ended December 31, 
2020

2019

2021

Cash flows from operating activities

Net loss
Adjustments to reconcile to net cash provided by operating activities:

Contract intangible asset amortization
Depreciation and amortization
Share-based compensation expense
Loss on impairment
Loss on impairment of investment in unconsolidated affiliates
Loss on disposal of assets, net
(Gain) loss on restructuring and retirement of debt
Gain on termination of construction contracts
Deferred income tax expense
Other, net
Changes in deferred revenues, net
Changes in deferred costs, net
Changes in other operating assets and liabilities, net

Net cash provided by operating activities

Cash flows from investing activities

Capital expenditures
Investment in loans to unconsolidated affiliate
Investments in unconsolidated affiliates
Proceeds from disposal of assets, net
Proceeds from maturities of unrestricted and restricted investments
Other, net

Net cash used in investing activities

Cash flows from financing activities

Repayments of debt
Proceeds from issuance of shares, net of issue costs
Proceeds from issuance of debt, net of discounts and issue costs
Other, net

Net cash used in financing activities

$

(591) $

(568) $ (1,257)

220
742
28
—
37
62
(51)
—
128
77
(108)
(6)
37
575

(208)
(33)
(1)
9
—
—
(233)

(606)
158
—
(42)
(490)

215
781
31
597
62
84
(533)
—
60
83
(73)
12
(353)
398

(265)
(2)
(19)
24
5
—
(257)

187
855
37
609
—
12
41
(132)
248
41
43
(33)
(311)
340

(387)
—
(77)
70
123
3
(268)

(1,637)
—
743
(36)
(930)

(1,325)
—
1,056
(43)
(312)

Net decrease in unrestricted and restricted cash and cash equivalents
Unrestricted and restricted cash and cash equivalents, beginning of period
Unrestricted and restricted cash and cash equivalents, end of period

(148)
1,560
1,412

$

(789)
2,349
1,560

$

(240)
2,589
2,349

$

See accompanying notes.

- 49 -

 
    
    
  
Table of Contents

NOTE 1—BUSINESS

TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

Transocean Ltd. (together with its subsidiaries and predecessors, unless the context requires otherwise, “Transocean,”
“we,”  “us”  or  “our”)  is  a  leading  international  provider  of  offshore  contract  drilling  services  for  oil  and  gas  wells.    As  of
December 31, 2021, we owned or had partial ownership interests in and operated a fleet of 37 mobile offshore drilling units,
consisting of 27 ultra-deepwater floaters and 10 harsh environment floaters.  As of December 31, 2021, we were constructing
two ultra-deepwater drillships.

We  provide,  as  our  primary  business,  contract  drilling  services  in  a  single  operating  segment,  which  involves
contracting  our  mobile  offshore  drilling  rigs,  related  equipment  and  work  crews  to  drill  oil  and  gas  wells.   We  specialize  in
technically  demanding  regions  of  the  global  offshore  drilling  business  with  a  particular  focus  on  ultra-deepwater  and  harsh
environment  drilling  services.    Our  drilling  fleet  is  one  of  the  most  versatile  fleets  in  the  world,  consisting  of  drillships  and
semisubmersible floaters used in support of offshore drilling activities and offshore support services on a worldwide basis.

We  perform  contract  drilling  services  by  deploying  our  high-specification  fleet  in  a  single,  global  market  that  is
geographically dispersed in oil and gas exploration and development areas throughout the world.  The location of our rigs and
the allocation of our resources to build or upgrade rigs are determined by the activities and needs of our customers.

NOTE 2—SIGNIFICANT ACCOUNTING POLICIES

Accounting estimates—To prepare financial statements in accordance with accounting principles generally accepted
in the United States (“U.S.”), we must make judgments by applying estimates and assumptions that affect the reported amounts
of assets, liabilities, revenues and expenses and the disclosures of contingent assets and liabilities.  On an ongoing basis, we
evaluate  our  estimates  and  assumptions,  including  those  related  to  our  income  taxes,  property  and  equipment,  equity
investments,  contingencies,  allowance  for  excess  materials  and  supplies,  intangibles,  allowance  for  credit  losses,  leases,
postemployment benefit plans and share-based compensation.  We base our estimates and assumptions on historical experience
and other factors that we believe are reasonable.  Actual results could differ from such estimates.

Fair value measurements—We estimate fair value at an exchange price that would be received to sell an asset or paid
to transfer a liability in the principal or most advantageous market for the asset or liability in an orderly transaction between
market participants.  Our valuation techniques require inputs that we categorize using a three-level hierarchy, from highest to
lowest level of observable inputs, as follows: (1) significant observable inputs, including unadjusted quoted prices for identical
assets or liabilities in active markets (“Level 1”), (2) significant other observable inputs, including direct or indirect market data
for  similar  assets  or  liabilities  in  active  markets  or  identical  assets  or  liabilities  in  less  active  markets  (“Level  2”)  and
(3) significant unobservable inputs, including those that require considerable judgment for which there is little or no market data
(“Level 3”).  When a valuation requires multiple input levels, we categorize the entire fair value measurement according to the
lowest level of input that is significant to the measurement even though we may have also utilized significant inputs that are
more readily observable.

Consolidation—We consolidate entities in which we have a majority voting interest and entities that meet the criteria
for  variable  interest  entities  for  which  we  are  deemed  to  be  the  primary  beneficiary  for  accounting  purposes.    We  eliminate
intercompany transactions and accounts in consolidation.  We apply the equity method of accounting for an equity investment in
an unconsolidated entity if we have the ability to exercise significant influence over the entity that (a) does not meet the variable
interest  entity  criteria  or  (b)  meets  the  variable  interest  entity  criteria,  but  for  which  we  are  not  deemed  to  be  the  primary
beneficiary.  We measure other equity investments at fair value if the investment has a fair value that is readily determinable;
otherwise, we measure the investment at cost, less any impairment.  We separately present within equity on our consolidated
balance sheets the ownership interests attributable to parties with noncontrolling interests in our consolidated subsidiaries, and
we  separately  present  net  income  attributable  to  such  parties  on  our  consolidated  statements  of  operations.    See  Note  4—
Unconsolidated Affiliates and Note 14—Equity.

Revenues  and  related  pre-operating  costs—We  recognize  revenues  earned  under  our  drilling  contracts  based  on
variable dayrates, which range from a full operating dayrate to lower rates or zero rates for periods when drilling operations are
interrupted or restricted, based on the specific activities we perform during the contract on an hourly, or more frequent, basis.
 Such dayrate consideration is attributed to the distinct time period to which it relates within the contract term, and therefore, is
recognized as we perform the services.  When the operating dayrate declines over the contract term, we recognize revenues on a
straight-line basis over the estimated contract period.  We recognize reimbursement revenues and the corresponding costs as we
provide  the  customer-requested  goods  and  services,  when  such  reimbursable  costs  are  incurred  while  performing  drilling
operations.    Prior  to  performing  drilling  operations,  we  may  receive  pre-operating  revenues,  on  either  a  fixed  lump-sum  or
variable  dayrate  basis,  for  mobilization,  contract  preparation,  customer-requested  goods  and  services  or  capital  upgrades,  for
which we record a contract liability and recognize as revenues on a straight-line basis over the estimated contract period.  We
recognize  losses  for  loss  contracts  as  such  losses  are  incurred.    We  recognize  revenues  for  demobilization  over  the  contract
period  unless  otherwise  constrained.   We  recognize  revenues  from  contract  terminations  as  we  fulfill  our  obligations  and  all
contingencies  have  been  resolved.    We  apply  the  optional  exemption  that  permits  us  to  exclude  disclosure  of  the  estimated
transaction price related to the variable portion of unsatisfied performance obligations at the end of the reporting period, as our
transaction price is based

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TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

on a single performance obligation consisting of a series of distinct hourly, or more frequent, periods, the variability of which
will be resolved at the time of the future services.

To obtain contracts with our customers, we incur pre-operating costs to prepare a rig for contract and mobilize a rig to
the drilling location.  We defer such pre-operating contract preparation and mobilization costs for recognition in operating and
maintenance costs over the estimated contract period on a straight-line basis, consistent with the general pace of activity.  See
Note 5—Revenues.

Contract intangible assets—We recognize contract intangible assets related to acquired executory contracts, such as
drilling  contracts.    The  drilling  contract  intangible  assets  represent  the  amount  by  which  the  fixed  dayrates  of  the  acquired
contracts  were  above  the  market  dayrates  that  were  available  or  expected  to  be  available  during  the  term  of  the  contract  for
similar contracts, measured as of the acquisition date.  We amortize the carrying amount of the drilling contract intangible assets
using  the  straight-line  method  as  a  reduction  of  contract  drilling  revenues  over  the  expected  remaining  contract  period.    See
Note 6—Contract Intangible Assets.

Share-based compensation—To measure the fair values of granted or modified service-based restricted share units,
we use the market price of our shares on the grant date or modification date.  To measure the fair values of granted or modified
stock  options,  we  use  the  Black-Scholes-Merton  option-pricing  model  and  apply  assumptions  for  the  expected  life,  risk-free
interest  rate,  expected  volatility  and  dividend  yield.    To  measure  the  fair  values  of  granted  or  modified  performance-based
restricted  share  units  subject  to  market  factors,  we  use  a  Monte  Carlo  simulation  model  and,  in  addition  to  the  assumptions
applied  for  the  Black-Scholes-Merton  option-pricing  model,  we  use  a  risk  neutral  approach  and  an  average  price  at  the
performance  start  date.    To  measure  the  fair  values  of  granted  or  modified  performance-based  restricted  share  units  that  are
subject to performance targets, we use the market price of our shares on the grant date or modification date adjusted for the
projected  performance  rate  expected  to  be  achieved  at  the  end  of  the  measurement  period.    We  recognize  share-based
compensation expense in the same financial statement line item as cash compensation paid to the respective employees or non-
employee directors.  We recognize such compensation expense on a straight-line basis over the service period through the date
the employee or non-employee director is no longer required to provide service to earn the award.  See Note 15—Share-Based
Compensation.

Capitalized interest—We capitalize interest costs for qualifying construction and upgrade projects and only capitalize
interest  costs  during  periods  in  which  progress  for  the  construction  projects  continues  to  be  underway.    In  the  years  ended
December 31, 2021, 2020 and 2019, we capitalized interest costs of $50 million, $47 million and $38 million, respectively, for
our construction work in progress.

Functional currency—We  consider  the  U.S.  dollar  to  be  the  functional  currency  for  all  of  our  operations  since  the
majority of our revenues and expenditures are denominated in U.S. dollars, which limits our exposure to currency exchange rate
fluctuations.  We recognize currency exchange rate gains and losses in other, net.  In the years ended December 31, 2021, 2020
and 2019, we recognized a net loss of $1 million, a net loss of $8 million and a net gain of $2 million, respectively, related to
currency exchange rates.

Income  taxes—We  provide  for  income  taxes  based  on  expected  taxable  income,  statutory  rates,  tax  laws  and  tax
planning opportunities available to us in the jurisdictions in which we operate or have a taxable presence.  We recognize the
effect of changes in tax laws as of the date of enactment.  We recognize potential global intangible low-taxed income inclusions
as a period cost.

We maintain liabilities for estimated tax exposures in our jurisdictions of operation, and we recognize the provisions
and  benefits  resulting  from  changes  to  those  liabilities  in  our  income  tax  expense  or  benefit  along  with  related  interest  and
penalties.  Income tax exposure items include potential challenges to permanent establishment positions, intercompany pricing,
disposition transactions, and withholding tax rates and their applicability.  These tax exposures are resolved primarily through
the settlement of audits within these tax jurisdictions or by judicial means, but can also be affected by changes in applicable tax
law or other factors, which could cause us to revise past estimates.

We measure deferred tax assets and liabilities using enacted tax rates that will apply in the years in which the deferred
tax  assets  and  liabilities  are  expected  to  be  recovered  or  paid.    In  evaluating  our  ability  to  realize  deferred  tax  assets,  we
consider all available positive and negative evidence, including projected future taxable income and the existence of cumulative
losses in recent years.  We record a valuation allowance for deferred tax assets when it is more likely than not that some or all of
the benefit from the deferred tax asset will not be realized.  For example, we may record a valuation allowance for deferred tax
assets resulting from net operating losses incurred during the year in certain jurisdictions for which the benefit of the losses will
not be realized or for foreign tax credit carryforwards that may expire prior to their utilization.  See Note 11—Income Taxes.

Cash  and  cash  equivalents—We  consider  cash  equivalents  to  include  highly  liquid  debt  instruments  with  original
maturities of three months or less, such as time deposits with commercial banks that have high credit ratings, U.S. Treasury and
government securities, Eurodollar time deposits, certificates of deposit and commercial paper.  We may also invest excess funds
in  no-load,  open-ended,  management  investment  trusts.    Such  management  trusts  invest  exclusively  in  high-quality  money
market instruments.

Restricted cash and cash equivalents—We maintain restricted cash and cash equivalents that are either pledged for
debt  service  under  certain  bond  indentures,  as  required  under  certain  bank  credit  arrangements,  or  held  in  accounts  that  are
subject  to  restrictions  due  to  legislation,  regulation  or  court  order.    We  classify  such  restricted  cash  and  cash  equivalents  in
current assets if the restriction is expected to expire or otherwise be resolved within one year or if such funds are considered to
offset  liabilities  that  are  properly  classified  as  current  liabilities.  See  Note  9—Debt  and  Note  13—Commitments  and
Contingencies.

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TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

Materials and supplies—We record materials and supplies at their average cost less an allowance for excess items.
 We estimate the allowance for excess items based on historical experience and expectations for future use of the materials and
supplies.  During the year ended December 31, 2021, we identified certain materials and supplies that were in excess of our
expected  future  usage  based  on  our  current  market  outlook.    As  a  result  of  these  items,  we  increased  our  allowance  by
$28  million  ($0.04  per  diluted  share,  net  of  tax).    At  December  31,  2021  and  2020,  our  allowance  for  excess  items  was
$183 million and $143 million, respectively.

Assets held for sale—We classify an asset as held for sale when the facts and circumstances meet the criteria for such
classification, including the following: (a) we have committed to a plan to sell the asset, (b) the asset is available for immediate
sale,  (c)  we  have  initiated  actions  to  complete  the  sale,  including  locating  a  buyer,  (d)  the  sale  is  expected  to  be  completed
within one year, (e) the asset is being actively marketed at a price that is reasonable relative to its fair value, and (f) the plan to
sell is unlikely to be subject to significant changes or termination.  At December 31, 2021 and 2020, we had no assets classified
as held for sale.

Property  and  equipment—We  apply  judgment  to  account  for  our  property  and  equipment,  consisting  primarily  of
offshore  drilling  rigs  and  related  equipment,  related  to  estimates  and  assumptions  for  cost  capitalization,  useful  lives  and
salvage  values.    We  base  our  estimates  and  assumptions  on  historical  experience  and  expectations  regarding  future  industry
conditions and operations.  At December 31, 2021, the aggregate carrying amount of our property and equipment represented
approximately 83 percent of our total assets.

We capitalize expenditures for newbuilds, renewals, replacements and improvements, including capitalized interest, if
applicable, and we recognize the expense for maintenance and repair costs as incurred.  For newbuild construction projects, we
also  capitalize  the  initial  preparation,  mobilization  and  commissioning  costs  incurred  until  the  drilling  unit  is  placed  into
service.  Upon sale or other disposition of an asset, we recognize a net gain or loss on disposal of the asset, which is measured
as the difference between the net carrying amount of the asset and the net proceeds received.  We compute depreciation using
the straight-line method after allowing for salvage values.

The  estimated  original  useful  life  of  our  drilling  units  is  35  years,  our  buildings  and  improvements  range  from
two to 30 years and our machinery and equipment range from four to 20 years.  We reevaluate the remaining useful lives and
salvage  values  of  our  rigs  when  certain  events  occur  that  directly  impact  the  useful  lives  and  salvage  values  of  the  rigs,
including  changes  in  operating  condition,  functional  capability  and  market  and  economic  factors.    When  evaluating  the
remaining useful lives of rigs, we also consider major capital upgrades required to perform certain contracts and the long-term
impact of those upgrades on future marketability.

Long-lived  asset  impairment—We  review  the  carrying  amounts  of  long-lived  assets,  including  property  and
equipment and right-of-use assets, for potential impairment when events occur or circumstances change that indicate that the
carrying amount of such assets may not be recoverable.  For assets classified as held and used, we determine recoverability by
evaluating the estimated undiscounted future net cash flows based on projected dayrates and utilization of the asset group under
review.  We consider our asset groups to be ultra-deepwater floaters and harsh environment floaters.  When an impairment of
one or more of our asset groups is indicated, we measure the impairment as the amount by which the asset group’s carrying
amount  exceeds  its  estimated  fair  value.   We  measure  the  fair  values  of  our  asset  groups  by  applying  a  variety  of  valuation
methods,  incorporating  a  combination  of  cost,  income  and  market  approaches,  using  projected  discounted  cash  flows  and
estimates of the exchange price that would be received for the assets in the principal or most advantageous market for the assets
in an orderly transaction between market participants as of the measurement date.  For an asset classified as held for sale, we
consider the asset to be impaired to the extent its carrying amount exceeds its estimated fair value less cost to sell.  See Note 7
—Long-Lived Assets.

Equity investments and impairment—We review our equity-method investments, and other equity investments for
which  a  readily  determinable  fair  value  is  not  available,  for  potential  impairment  when  events  or  changes  in  circumstances
indicate  that  the  carrying  amount  of  the  investment  might  not  be  recoverable  in  the  near  term.    If  we  determine  that  an
impairment that is other than temporary exists, we recognize an impairment loss, measured as the amount by which the carrying
amount  of  the  investment  exceeds  its  estimated  fair  value.   To  estimate  the  fair  value  of  the  investment,  we  apply  valuation
methods  that  rely  primarily  on  the  income  and  market  approaches.    In  the  years  ended  December  31,  2021  and  2020,  we
recognized  a  loss  of  $37  million  and  $62  million,  respectively,  associated  with  the  other-than-temporary  impairment  of  the
carrying amount of our equity investments. See Note 4—Unconsolidated Affiliates.

Pension  and  other  postemployment  benefit  plans—We  use  a  measurement  date  of  January  1  for  determining  net
periodic  benefit  costs  and  December  31  for  determining  plan  benefit  obligations  and  the  fair  values  of  plan  assets.    We
determine  our  net  periodic  benefit  costs  based  on  a  market-related  value  of  assets  that  reduces  year-to-year  volatility  by
including  investment  gains  or  losses  subject  to  amortization  over  a  five-year  period  from  the  year  in  which  they  occur.   We
calculate investment gains or losses for this purpose as the difference between the expected return calculated using the market-
related value of assets and the actual return based on the market-related value of assets.  If gains or losses exceed 10 percent of
the greater of plan assets or plan liabilities, we amortize such gains or losses over the average expected future service period of
the employee participants.

We  measure  our  actuarially  determined  obligations  and  related  costs  for  our  defined  benefit  pension  and  other
postemployment  benefit  plans,  retiree  life  insurance  and  medical  benefits,  by  applying  assumptions,  the  most  significant  of
which include long-term rate of return on plan assets, discount rates and mortality rates.  For the long-term rate of return, we
develop our assumptions regarding the expected rate of return on plan assets based on historical experience and projected long-
term investment returns, and we weight the assumptions based on each plan’s asset allocation.  For the discount rate, we base
our assumptions on a yield curve approach using Aa-rated corporate

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TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

bonds  and  the  expected  timing  of  future  benefit  payments.    At  December  31,  2021  and  2020,  our  pension  and  other
postemployment benefit plan obligations represented an aggregate liability of $132 million and $277 million, respectively, and
an aggregate asset of $102 million and $37 million, respectively, representing the funded status of the plans.  See Note 10—
Postemployment Benefit Plans.

Contingencies—We perform assessments of our contingencies on an ongoing basis to evaluate the appropriateness of
our liabilities and disclosures for such contingencies.  We establish liabilities for estimated loss contingencies when we believe a
loss  is  probable  and  the  amount  of  the  probable  loss  can  be  reasonably  estimated.    Once  established,  we  adjust  the  carrying
amount of a contingent liability upon the occurrence of a recognizable event when facts and circumstances change, altering our
previous  assumptions  with  respect  to  the  likelihood  or  amount  of  loss.    We  recognize  corresponding  assets  for  those  loss
contingencies that we believe are probable of being recovered through insurance.  We recognize expense for legal costs as they
are  incurred,  and  we  recognize  a  corresponding  asset  for  such  legal  costs  only  if  we  expect  such  legal  costs  to  be  recovered
through insurance.

NOTE 3—ACCOUNTING STANDARDS UPDATE

Recently adopted accounting standards

Debt  with  conversion  and  other  options—Effective  January  1,  2021,  we  early  adopted  the  accounting  standards
update  that  simplifies  the  accounting  for  convertible  instruments,  such  as  our  exchangeable  debt,  by  limiting  the  accounting
models that result in separately recognizing embedded conversion features from the host contract.  The accounting standards
update also enhances information transparency by making targeted improvements to the disclosures for convertible instruments
and  earnings  per  share  guidance.    Our  adoption  did  not  result  in  any  accounting  changes  for  the  0.50%  exchangeable  senior
bonds due January 2023 (the “0.50% Exchangeable Senior Bonds”) or the 2.50% senior guaranteed exchangeable bonds due
January  2027  (the  “2.50%  Senior  Guaranteed  Exchangeable  Bonds”).    Under  previous  accounting  guidance,  for  the
4.00% senior guaranteed exchangeable bonds due December 2025 (the “4.00% Senior Guaranteed Exchangeable Bonds”), we
would  have  recorded  the  debt  and  exchange  features  separately  and,  consequently,  we  would  have  recognized  in  current  and
future periods greater amortization, as a component of interest expense.  See Note 9—Debt.

NOTE 4—UNCONSOLIDATED AFFILIATES

Equity  investments—We  hold  noncontrolling  equity  investments  in  various  unconsolidated  companies,  including
(a) our 33.0 percent ownership interest in Orion Holdings (Cayman) Limited (together with its subsidiary, “Orion”), a Cayman
Islands company that, through its wholly owned subsidiary, owns the harsh environment floater Transocean Norge, and (b) our
interests  in  certain  companies  that  are  involved  in  researching  and  developing  technology  to  improve  efficiency,  reliability,
sustainability and safety for drilling and other activities.  At December 31, 2021 and 2020, the aggregate carrying amount of our
equity investments was $91 million and $138 million, respectively, recorded in other assets.

Our  equity-method  investment  in  Orion  is  the  most  significant  of  our  equity  investments.    In  the  years  ended
December 31, 2020 and 2019, we made an aggregate cash contribution of $8 million and $74 million, respectively, to Orion.  In
the years ended December 31, 2021 and 2020, we recognized a loss of $37 million and $59 million, respectively, which had no
tax effect, recorded in other, net, associated with the impairment of our equity investment in Orion upon determination that the
carrying amount exceeded the estimated fair value and that the impairment was other than temporary.  We estimated the fair
value  of  our  investment  by  applying  the  income  method  using  significant  unobservable  inputs,  representative  of  Level  3  fair
value  measurements,  including  an  assumed  discount  rate  of  12  percent  and  assumptions  about  the  future  performance  of  the
investment, such as future demand and supply for harsh environment floaters, rig utilization, revenue efficiency and dayrates.
  At  December  31,  2021  and  2020,  the  aggregate  carrying  amount  of  our  equity  investment  in  Orion  was  $57  million  and
$104 million, respectively.

Related party transactions—We  engage  in  certain  related  party  transactions  with  our  unconsolidated  affiliates,  the
most significant of which are under agreements with Orion.  We have a management services agreement for the operation and
maintenance of the harsh environment floater Transocean Norge and a marketing services agreement for the marketing of the
rig.    We  also  leased  the  rig  under  a  short-term  bareboat  charter  agreement,  which  expired  in  June  2021.    Prior  to  the  rig’s
placement into service, we also engaged in certain related party transactions with Orion under a shipyard care agreement for the
construction  of  the  rig  and  other  matters  related  to  its  completion  and  delivery.    Additionally,  we  procure  services  and
equipment from other unconsolidated affiliates for technological innovation.

In  the  years  ended  December  31,  2021,  2020  and  2019,  we  received  an  aggregate  cash  payment  of  $16  million,
$46  million  and  $96  million,  respectively,  under  the  shipyard  care  agreement  with  Orion,  primarily  related  to  the
commissioning, preparation and mobilization of Transocean Norge.  In the years ended December 31, 2021, 2020 and 2019, we
recognized rent expense of $12 million, $22 million and $9 million, respectively, recorded in operating and maintenance costs,
and made an aggregate cash payment of $15 million, $22 million and $6 million, respectively, to charter the rig and rent other
equipment  from  Orion.    In  the  years  ended  December  31,  2021,  2020  and  2019,  we  made  an  aggregate  cash  payment  of
$6 million, $15 million and $11 million, respectively, to other unconsolidated affiliates for research and development and for
equipment to reduce emissions and improve reliability.

Additionally,  in  June  2021,  Orion  refinanced  its  shipyard  loans  under  a  financing  arrangement  for  $100  million,  in
which we participated at a rate equivalent to our ownership interest in Orion.  Borrowings under the financing arrangement are
secured by

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TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

Transocean  Norge.    The  financing  arrangement,  which  expires  in  June  2024,  requires  interest  to  be  paid  on  outstanding
borrowings at the London Interbank Offered Rate plus a margin of 6.50 percent per annum.  In the year ended December 31,
2021,  we  made  a  cash  investment  in  loans  of  $33  million.    At  December  31,  2021,  the  outstanding  borrowings,  including
accrued and unpaid interest, due to us under the financing arrangement were $34 million, recorded in other assets.

NOTE 5—REVENUES

Overview—We  earn  revenues  primarily  by  performing  the  following  activities:  (i)  providing  our  drilling  rig,  work
crews,  related  equipment  and  services  necessary  to  operate  the  rig  (ii)  delivering  the  drilling  rig  by  mobilizing  to  and
demobilizing from the drill location, and (iii) performing certain pre-operating activities, including rig preparation activities or
equipment modifications required for the contract.  These services represent a single performance obligation under our drilling
contracts with customers that is satisfied over time, the duration of which varies by contract.  At December 31, 2021, the drilling
contract with the longest expected remaining duration, excluding unexercised options, extends through February 2028.

Disaggregation—Our  contract  drilling  revenues,  disaggregated  by  asset  group  and  by  country  in  which  they  were

earned, were as follows (in millions):

Year ended December 31, 2021

Year ended December 31, 2020

Year ended December 31, 2019

Ultra-deepwater floaters
Harsh environment floaters
Deepwater floaters
Midwater floaters

Total contract drilling revenues

   U.S.

  Norway  Other (a)   Total

  Norway  Other (a)   Total

   U.S.
  Norway  Other (a)   Total
  $1,096 $ — $ 624 $1,720  $1,302 $ — $ 792 $2,094 $1,264 $ — $ 693 $ 1,957
1,069
7
55
  $1,098 $ 790 $ 668 $2,556  $1,302 $ 876 $ 974 $3,152 $1,264 $ 775 $ 1,049 $ 3,088

— 775
—
—
—
—

— 876
—
—
—
—

1,046
—
12

836
—
—

294
7
55

170
—
12

790
—
—

2
—
—

44
—
—

   U.S.

(a) Other  represents  the  aggregate  value  for  countries  in  which  we  operate  that  individually  had  attributable  operating  revenues  representing  less  than

10 percent of consolidated operating revenues earned.

Major  customers—For  the  year  ended  December  31,  2021,  Shell  plc  (together  with  its  affiliates,  “Shell”)  and
Equinor ASA (together with its affiliates, “Equinor”) represented approximately 31 percent and 30 percent, respectively, of our
consolidated operating revenues.  For the year ended December 31, 2020, Shell, Equinor and Chevron Corporation (together
with  its  affiliates,  “Chevron”)  represented  approximately  28  percent,  27  percent  and  14  percent,  respectively,  of  our
consolidated  operating  revenues.    For  the  year  ended  December  31,  2019,  Shell,  Equinor  and  Chevron  represented
approximately 26 percent, 21 percent and 17 percent, respectively, of our consolidated operating revenues.

Contract liabilities—Contract liabilities for our contracts with customers were as follows (in millions):

Deferred contract revenues, recorded in other current liabilities
Deferred contract revenues, recorded in other long-term liabilities

Total contract liabilities

Significant changes in contract liabilities were as follows (in millions):

Total contract liabilities, beginning of period
Decrease due to recognition of revenues for goods and services
Increase due to goods and services transferred over time

Total contract liabilities, end of period

December 31, 

2021

2020

83
265
348

$

$

133
323
456

  $

  $

Years ended December 31, 

2021

2020

$

$

456
(149)
41
348

$

$

529
(184)
111
456

Performance obligations satisfied in prior periods—In June 2020, we entered into a settlement and mutual release
agreement with a customer, which provided for the final settlement of disputes related to performance obligations satisfied in
prior periods.  In connection with the settlement, among other things, our customer agreed to pay us $185 million in four equal
installments  through  January  15,  2023.    In  the  year  ended  December  31,  2020,  we  recognized  revenues  of  $177  million,
representing  the  discounted  value  of  the  future  payments,  and  recorded  corresponding  accounts  receivable,  net  of  imputed
interest.  In the years ended December 31, 2021 and 2020, we received an aggregate cash payment of $46 million in scheduled
installments under the arrangement.  At December 31, 2021 and 2020, the aggregate carrying amount of the related receivable
was  $90  million  and  $133  million,  respectively,  net  of  imputed  interest,  including  $46  million  and  $45  million,  respectively,
recorded in accounts receivable, and $44 million and $88 million, respectively, recorded in other assets.

In  the  year  ended  December  31,  2019,  we  recognized  revenues  of  $10  million  for  other  performance  obligations

satisfied in prior periods due to certain revenues recognized on a cash basis.

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TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

Pre-operating costs—In the years ended December 31, 2021, 2020 and 2019, we recognized pre-operating costs of
$48 million, $60 million and $18 million, respectively, recorded in operating and maintenance costs.  At December 31, 2021
and 2020, the unrecognized pre-operating costs to obtain contracts was $21 million and $20 million, respectively, recorded in
other assets.

NOTE 6—CONTRACT INTANGIBLE ASSETS

The  gross  carrying  amount  and  accumulated  amortization  of  our  drilling  contract  intangible  assets  were  as  follows

(in millions):

Year ended December 31, 2021
Gross
carrying
     amount

Accumulated
amortization

Net
carrying
amount

Year ended December 31, 2020  
Gross
carrying
     amount

    amortization     amount

Net
carrying  

Accumulated

Drilling contract intangible assets
Balance, beginning of period
Amortization

Balance, end of period

  $

  $

907 $
—
907 $

(514) $
(220)
(734) $

393
(220)
173

$

$

907
—
907

$

$

(299)  $
(215)
(514)  $

608
(215)
393

As of December 31, 2021, the estimated future amortization over the expected remaining contract periods, the longest

of which currently extends through March 2024, was as follows (in millions):

Years ending December 31,
2022
2023
2024

Total carrying amount of contract intangible assets

Total

  $

$

117
52
4
173

NOTE 7—LONG-LIVED ASSETS

Disaggregation—The aggregate carrying amount of our long-lived assets, including our property and equipment and

our right-of-use assets, disaggregated by country in which they were located, was as follows (in millions):

Long-lived assets
U.S.
Norway
Greece
Other countries (a)

Total long-lived assets

December 31, 

2021

2020

  $

5,779
3,379
3,162
5,293
  $ 17,613

$

6,007
3,560
3,294
5,347
$ 18,208

(a) Other countries represents the aggregate value for countries in which we operate that individually had attributable long-lived

assets representing less than 10 percent of consolidated long-lived assets.

Because the majority of our assets are mobile, the geographic locations of such assets at the end of the periods are not
necessarily  indicative  of  the  geographic  distribution  of  the  operating  revenues  generated  by  such  assets  during  the  periods
presented.  Our international operations are subject to certain political and other uncertainties, including risks of war and civil
disturbances or other market disrupting events, expropriation of equipment, repatriation of income or capital, taxation policies,
and  the  general  hazards  associated  with  certain  areas  in  which  we  operate.    Although  we  are  organized  under  the  laws  of
Switzerland, we have minimal assets located in Switzerland, and we do not conduct any operations or earn operating revenues
in Switzerland.

Construction work in progress—The changes in our construction work in progress were as follows (in millions):

Years ended December 31, 
2020

2019

2021

Construction work in progress, beginning of period

$

828

$

753

$

632

Capital expenditures
Newbuild construction program
Other equipment and construction projects

Total capital expenditures

Changes in accrued capital additions
Construction work in progress impaired

Property and equipment placed into service

Construction work in progress, end of period

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174
34
208
13
—

143
122
265
(33)
—

129
258
387
20
(5)

(32)
$ 1,017

$

(157)
828

$

(281)
753

 
 
   
 
    
    
 
 
 
    
    
 
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TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

Impairments of assets held and used—During the year ended December 31, 2020, we identified indicators that the
carrying  amounts  of  our  asset  groups  may  not  be  recoverable.    Such  indicators  included  significant  declines  in  commodity
prices and the market value of our stock, a reduction of expected demand for our drilling services as our customers announced
reductions  of  capital  investments  in  response  to  commodity  prices  and  a  reduction  of  projected  dayrates.   As  a  result  of  our
testing,  we  determined  that  the  carrying  amount  of  our  midwater  floater  asset  group  was  impaired.    In  the  year  ended
December 31, 2020, we recognized a loss of $31 million ($0.05 per diluted share), which had no tax effect, associated with the
impairment of our midwater floater asset group.  We estimated the fair value of the rig and related assets in this asset group by
applying  the  market  approach  using  significant  other  observable  inputs,  representative  of  Level  2  fair  value  measurements,
including the marketability of the rig and prices of comparable rigs that may be sold for scrap value.

Impairments  of  assets  held  for  sale—In  the  year  ended  December  31,  2020,  we  recognized  an  aggregate  loss  of
$556 million ($0.90 per diluted share), which had no tax effect, associated with the impairment of the ultra-deepwater floater
GSF Development Driller II, the harsh environment floaters Polar Pioneer and Songa Dee and the midwater floaters Sedco 711,
Sedco 714 and Transocean 712, along with related assets, which we determined were impaired at the time that we classified the
assets  as  held  for  sale.    In  the  year  ended  December  31,  2019,  we  recognized  an  aggregate  loss  of  $578  million  ($0.94  per
diluted share), which had no tax effect, associated with the impairment of the ultra-deepwater floaters Discoverer  Deep  Seas,
Discoverer Enterprise  and  Discoverer  Spirit,  along  with  related  assets,  which  we  determined  were  impaired  at  the  time  we
classified the assets as held for sale.  

We  measured  the  impairment  of  the  drilling  units  and  related  assets  as  the  amount  by  which  the  carrying  amount
exceeded the estimated fair value less costs to sell.  We estimated the fair value of the assets using significant other observable
inputs, representative of Level 2 fair value measurements, including indicative market values for the drilling units and related
assets to be sold for scrap value or binding contracts to sell such assets for alternative purposes.  If we commit to plans to sell
additional rigs for values below the respective carrying amounts, we will be required to recognize additional losses in future
periods associated with the impairment of such assets.

Dispositions—During the year ended December 31, 2021, in connection with our efforts to dispose of non-strategic
assets,  we  completed  the  sale  of  the  harsh  environment  floater  Leiv  Eiriksson  and  related  assets.    In  the  year  ended
December 31, 2021, we received aggregate net cash proceeds of $4 million and recognized an aggregate net loss of $57 million
($0.09  per  diluted  share),  which  had  no  tax  effect,  primarily  associated  with  the  disposal  of  these  assets.    In  the  year  ended
December 31, 2021, we received aggregate net cash proceeds of $5 million and recognized an aggregate net loss of $5 million
associated with the disposal of assets unrelated to rig sales.

During 

the  year  ended  December  31,  2020,  we  completed 

floater
GSF Development Driller II, the harsh environment floaters Polar Pioneer, Songa Dee and Transocean Arctic and the midwater
floaters  Sedco  711,  Sedco  714  and  Transocean  712,  along  with  related  assets.    In  the  year  ended  December  31,  2020,  we
received  aggregate  net  cash  proceeds  of  $20  million  and  recognized  an  aggregate  net  loss  of  $61  million  ($0.10  per  diluted
share), which had no tax effect, associated with the disposal of these assets.  In the year ended December 31, 2020, we received
aggregate net cash proceeds of $4 million and recognized an aggregate net loss of $23 million associated with the disposal of
assets unrelated to rig sales.

the  ultra-deepwater 

the  sale  of 

During the year ended December 31, 2019, we completed the sale of the ultra-deepwater floaters Deepwater Frontier,
Deepwater  Millennium,  Discoverer  Deep  Seas,  Discoverer  Enterprise,  Discoverer  Spirit  and  Ocean  Rig  Paros,  the  harsh
environment floater Eirik Raude, the deepwater floaters Jack Bates and Transocean 706 and the midwater floaters Actinia and
Songa Delta,  along  with  related  assets.    In  the  year  ended  December  31,  2019,  we  received  aggregate  net  cash  proceeds  of
$64 million and recognized an aggregate net gain of $4 million ($0.01 per diluted share), which had no tax effect, associated
with the disposal of these assets.  In the year ended December 31, 2019, we received aggregate net cash proceeds of $6 million
and recognized an aggregate net loss of $16 million associated with the disposal of assets unrelated to rig sales.

Cancelled  construction  contracts—In  the  year  ended  December  31,  2019,  we  recognized  income  of  $132  million,
recorded in other income, net, associated with the cancellation of certain construction contracts acquired in December 2018 in
connection with our acquisition of Ocean Rig UDW Inc., a Cayman Islands exempted company with limited liability, for the
construction of two ultra-deepwater drillships.  Under the acquisition method of accounting for the business combination, the
contract  liabilities  represented  the  amount  by  which  the  remaining  payments  due  under  the  acquired  contracts  were  above
market construction rates for similar drilling units, measured as of the acquisition date.

NOTE 8—LEASES

Overview—Our operating leases are principally for office space, storage facilities, operating equipment and land.  At
December 31, 2021, our operating leases had a weighted-average discount rate of 6.4 percent and a weighted-average remaining
lease term of 13.5 years.

Our  finance  lease  for  the  ultra-deepwater  drillship  Petrobras  10000  has  an  implicit  interest  rate  of  7.8  percent  and
requires scheduled monthly installments through the lease expiration in August 2029, after which we are obligated to acquire
the drillship from the lessor for one dollar.  We recognize expense for the amortization of the right-of-use asset in depreciation
and amortization.

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TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

Lease costs—The components of our lease costs were as follows (in millions):

Lease costs
Short-term lease costs
Operating lease costs
Finance lease costs, amortization of right-of-use asset
Finance lease costs, interest on lease liability

Total lease costs

Years ended December 31, 
2019
2020
2021

$

$

17 $
12
20
33
82 $

27 $
13
21
36
97 $

13
25
21
39
98

In  the  year  ended  December  31,  2019,  we  recognized  a  loss  of  $26  million,  with  no  tax  effect,  associated  with  the
impairment  of  right-of-use  assets  and  leasehold  improvements  for  certain  office  facilities  that  we  vacated  or  committed  to
sublease.

Lease payments—Supplemental cash flow information for our leases was as follows (in millions):

Cash paid for amounts included in the measurement of lease liabilities:
Operating cash flows from operating leases
Operating cash flows from finance lease
Financing cash flows from finance lease

Years ended December 31, 
2019
2020
2021

13 $
37
33

17 $
36
35

19
39
32

At December 31, 2021, the aggregate future minimum lease payments were as follows (in millions):

Years ending December 31,
2022
2023
2024
2025
2026
Thereafter

Total future minimum rental payment
Less amount representing imputed interest
Present value of future minimum rental payments

Current portion, recorded in other current liabilities
Long-term lease liabilities, recorded in other long-term liabilities

- 57 -

  Operating  Finance

leases

lease

$

$

14 $
13
13
13
12
113
178
(61)
117
8
109 $

71
70
71
70
71
188
541
(135)
406
40
366

 
 
 
 
Table of Contents

NOTE 9—DEBT

Overview

TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

Outstanding  debt—The  aggregate  principal  amounts  and  aggregate  carrying  amounts,  including  the  contractual
interest  payments  of  debt  restructured  in  the  year  ended  December  31,  2020  and  unamortized  debt-related  balances,  such  as
discounts, premiums and issue costs, were as follows (in millions):

6.375% Senior Notes due December 2021
5.52% Senior Secured Notes due May 2022
3.80% Senior Notes due October 2022
0.50% Exchangeable Senior Bonds due January 2023
5.375% Senior Secured Notes due May 2023
5.875% Senior Secured Notes due January 2024
7.75% Senior Secured Notes due October 2024
6.25% Senior Secured Notes due December 2024
6.125% Senior Secured Notes due August 2025
7.25% Senior Notes due November 2025
4.00% Senior Guaranteed Exchangeable Bonds due December 2025
7.50% Senior Notes due January 2026
2.50% Senior Guaranteed Exchangeable Bonds due January 2027
11.50% Senior Guaranteed Notes due January 2027
6.875% Senior Secured Notes due February 2027
8.00% Senior Notes due February 2027
7.45% Notes due April 2027
8.00% Debentures due April 2027
7.00% Notes due June 2028
7.50% Notes due April 2031
6.80% Senior Notes due March 2038
7.35% Senior Notes due December 2041

Total debt

Less debt due within one year

6.375% Senior Notes due December 2021
5.52% Senior Secured Notes due May 2022
3.80% Senior Notes due October 2022
5.375% Senior Secured Notes due May 2023
5.875% Senior Secured Notes due January 2024
7.75% Senior Secured Notes due October 2024
6.25% Senior Secured Notes due December 2024
6.125% Senior Secured Notes due August 2025
2.50% Senior Guaranteed Exchangeable Bonds due January 2027
11.50% Senior Guaranteed Notes due January 2027
6.875% Senior Secured Notes due February 2027

Total debt due within one year
Total long-term debt

Principal amount

Carrying amount

December 31, December 31,   December 31, December 31,  

2021

2020

2021

2020

(a)
(b)
(a)
(a)
(c)
(c)
(c)
(c)
(c)
(d)
(e)
(d)
(e)
(e)
(c)
(d)
(a)
(a)
(f)
(a)
(a)
(a)

(a)
(b)
(a)
(c)
(c)
(c)
(c)
(c)
(e)
(e)
(c)

$

 $

— $
18
27
140
306
435
300
313
402
411
294
569
238
687
550
612
52
22
261
396
610
177
6,820

—
18
27
63
83
60
62
66
—
—
69
448
6,372

$

38
111
27
463
364
585
360
375
468
411
—
569
238
687
550
612
52
22
261
396
610
177
7,376

38
93
—
47
83
60
62
66
—
—
—
449
6,927

$

 $

— $
18
27
140
304
430
296
309
397
406
264
565
271
1,078
544
607
52
22
265
394
605
176
7,170

—
18
27
62
80
58
61
64
6
70
67
513
6,657

$

38
111
27
462
360
577
354
369
461
405
—
565
277
1,139
542
606
51
22
266
394
605
176
7,807

38
92
—
46
80
58
60
64
6
61
—
505
7,302

(a) Transocean Inc., a 100 percent owned direct subsidiary of Transocean Ltd., is the issuer of the notes and debentures (the “Legacy Guaranteed

Notes”).  The Legacy Guaranteed Notes are fully and unconditionally, jointly and severally, guaranteed by Transocean Ltd.

(b) The subsidiary issuer of the unregistered senior secured notes is a wholly owned indirect subsidiary of Transocean Inc.  The senior secured notes

are fully and unconditionally guaranteed by the owner of the collateral rig.

(c) Each subsidiary issuer of the respective unregistered senior secured notes is a wholly owned indirect subsidiary of Transocean Inc.  The senior
secured notes are fully and unconditionally, jointly and severally, guaranteed by Transocean Ltd., Transocean Inc. and, in each case, the owner of
the respective collateral rig or rigs.

(d) Transocean Inc. is the issuer of the unregistered notes (collectively, the “Priority Guaranteed Notes”).  The guaranteed senior unsecured notes are
fully and unconditionally, jointly and severally, guaranteed by Transocean Ltd. and certain wholly owned indirect subsidiaries of Transocean Inc.
and rank equal in right of payment of all of our existing and future unsecured unsubordinated obligations.  Such notes are structurally senior to
the Legacy Guaranteed Notes and the 7.00% notes due June 2028 and are structurally subordinate to the Senior Priority Guaranteed Notes, as
defined below, to the extent of the value of the assets of the subsidiaries guaranteeing the notes.

(e) Transocean  Inc.  is  the  issuer  of  the  unregistered  notes  (together,  the  “Senior  Priority  Guaranteed  Notes”).    The  priority  guaranteed  senior
unsecured  notes  are  fully  and  unconditionally,  jointly  and  severally,  guaranteed  by  Transocean  Ltd.  and  certain  wholly  owned  indirect
subsidiaries of Transocean Inc. and rank equal in right of payment of all of our existing and future unsecured unsubordinated obligations.  Such
notes are structurally senior to the Priority Guaranteed Notes to the extent of the value of the assets of the subsidiaries guaranteeing the notes.
(f) The subsidiary issuer of the registered notes is a wholly owned indirect subsidiary of Transocean Inc.  The notes are fully and unconditionally

guaranteed by Transocean Inc.

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TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

Transocean  Ltd.  has  no  independent  assets  or  operations,  and  its  other  subsidiaries  not  owned  indirectly  through
Transocean Inc. are minor.  Transocean Inc. has no independent assets and operations, other than those related to its investments
in  non-guarantor  operating  companies  and  balances  primarily  pertaining  to  its  cash  and  cash  equivalents  and  debt.
 Transocean Ltd. and Transocean Inc. are not subject to any significant restrictions on their ability to obtain funds from their
consolidated subsidiaries by dividends, loans or capital distributions.

Indentures—The  indentures  that  govern  our  debt  generally  contain  covenants  that,  among  other  things,  limit  our
ability to incur certain liens on our drilling units without equally and ratably securing the notes, to engage in certain sale and
lease back transactions covering any of our drilling units, to allow our subsidiaries to incur certain additional debt, or to engage
in  certain  merger,  consolidation  or  reorganization  transactions  or  to  enter  into  a  scheme  of  arrangement  qualifying  as  an
amalgamation.

The  indentures  that  govern  the  5.52%  senior  secured  notes  due  May  2022  (the  “5.52%  Senior  Secured  Notes”),  the
5.375%  Senior  Secured  Notes  due  May  2023  (the  “5.375%  Senior  Secured  Notes”),  the  5.875%  senior  secured  notes  due
January  2024,  the  7.75%  senior  secured  notes  due  October  2024,  the  6.25%  senior  secured  notes  due  December  2024,  the
6.125% senior secured notes due August 2025 and the 6.875% senior secured notes due February 2027 (the “6.875% Senior
Secured Notes”) contain covenants that limit the ability of our subsidiaries that own or operate the collateral rigs to declare or
pay dividends to their affiliates.

The  indentures  that  govern  the  4.00%  Senior  Guaranteed  Exchangeable  Bonds,  the  2.50%  Senior  Guaranteed
Exchangeable Bonds and the 0.50% Exchangeable Senior Bonds require such bonds to be repurchased upon the occurrence of
certain  fundamental  changes  and  events,  at  specified  prices  depending  on  the  particular  fundamental  change  or  event,  which
include  changes  and  events  related  to  certain  (i)  change  of  control  events  applicable  to  Transocean  Ltd.  or  Transocean  Inc.,
(ii) the failure of our shares to be listed or quoted on a national securities exchange and (iii) specified tax matters.

Interest rate adjustments—The interest rates for certain of our notes are subject to adjustment from time to time upon
a change to the credit rating of our non-credit enhanced senior unsecured long-term debt.  At December 31, 2021, the interest
rate in effect for the 3.80% senior notes due October 2022 and the 7.35% senior notes due December 2041 was 5.80 percent and
9.35 percent, respectively.

Scheduled  maturities—At  December  31,  2021,  the  scheduled  maturities  of  our  debt,  including  the  principal
installments  and  other  installments,  representing  the  contractual  interest  payments  of  previously  restructured  debt,  were  as
follows (in millions):

Years ending December 31,
2022
2023
2024
2025
2026
Thereafter

Total installments of debt
Total unamortized debt-related balances, net

Total carrying amount of debt

     Principal
    installments    installments    

     Other

Total

$

$

448
722
786
992
652
3,220
6,820

$

$

76
76
77
77
78
39
423

$

$

524
798
863
1,069
730
3,259
7,243
(73)
7,170

Credit agreements

Invictus,  Deepwater  Mykonos,  Deepwater  Orion,  Deepwater 

Secured  Credit  Facility—As  of  December  31,  2021,  we  have  a  $1.33  billion  secured  revolving  credit  facility
established under a bank credit agreement (as amended from time to time, the “Secured Credit Facility”), which is scheduled to
expire on June 22, 2023.  The Secured Credit Facility is guaranteed by Transocean Ltd. and certain wholly owned subsidiaries.
  The  Secured  Credit  Facility  is  secured  by,  among  other  things,  a  lien  on  the  ultra-deepwater  floaters  Deepwater  Asgard,
Deepwater  Corcovado,  Deepwater 
Skyros,
Development  Driller  III,  Dhirubhai  Deepwater  KG2  and  Discoverer  Inspiration  and  the  harsh  environment  floaters
Transocean  Barents  and  Transocean  Spitsbergen,  and  at  December  31,  2021,  the  aggregate  carrying  amount  of  which  was
$5.07  billion.    The  maximum  borrowing  capacity  will  be  reduced  to  $1.00  billion  if,  and  so  long  as,  our  leverage  ratio,
measured  as  the  aggregate  principal  amount  of  debt  outstanding  to  earnings  before  interest,  taxes,  depreciation  and
amortization,  exceeds  10.00  to  1.00.    The  Secured  Credit  Facility  contains  covenants  that,  among  other  things,  include
maintenance  of  a  minimum  guarantee  coverage  ratio  of  3.0  to  1.0,  a  minimum  collateral  coverage  ratio  of  2.1  to  1.0,  a
maximum debt to capitalization ratio of 0.60 to 1.00 and minimum liquidity of $500 million.  The Secured Credit Facility also
restricts the ability of Transocean Ltd. and certain of our subsidiaries to, among other things, merge, consolidate or otherwise
make changes to the corporate structure, incur liens, incur additional indebtedness, enter into transactions with affiliates and pay
dividends and other distributions.

We  may  borrow  under  the  Secured  Credit  Facility  at  either  (1)  the  reserve  adjusted  London  Interbank  Offered  Rate
plus  a  margin  (the  “Secured  Credit  Facility  Margin”),  which  ranges  from  2.625  percent  to  3.375  percent  based  on  the  credit
rating  of  the  Secured  Credit  Facility,  or  (2)  the  base  rate  specified  in  the  credit  agreement  plus  the  Secured  Credit  Facility
Margin, minus one percent per annum.  Throughout the term of the Secured Credit Facility, we pay a facility fee on the amount
of the underlying commitment which ranges from 0.375 percent to 1.00 percent based on the credit rating of the Secured Credit
Facility.  At December 31, 2021, based on the credit rating of

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TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

the  Secured  Credit  Facility  on  that  date,  the  Secured  Credit  Facility  Margin  was  3.375  percent  and  the  facility  fee  was
0.875 percent.  At December 31, 2021, we had no borrowings outstanding, $17 million of letters of credit issued, and we had
$1.32 billion of available borrowing capacity under the Secured Credit Facility.

Shipyard  financing  arrangement—In  June  2021,  Transocean  Offshore  Deepwater  Holdings  Limited,  a
Cayman  Islands  company  and  our  wholly  owned  indirect  subsidiary,  entered  into  credit  agreements  with  Jurong  Shipyard
Pte Ltd. establishing facilities (the “Shipyard Loans”) to finance all or a portion of the final payments expected to be owed to
the  shipyard  upon  delivery  of  the  ultra-deepwater  floaters  Deepwater  Atlas  and  Deepwater  Titan.    The  Shipyard  Loans  are
guaranteed  by  Transocean  Inc.    Borrowings  under  the  Shipyard  Loan  for  Deepwater Atlas  will  be  secured  by,  among  other
security,  a  lien  on  the  rig.    In  certain  circumstances,  borrowings  under  the  Shipyard  Loan  for  Deepwater Titan  may  also  be
secured  by,  among  other  security,  a  lien  on  the  rig.    We  will  repay  the  borrowings,  together  with  interest  of  4.5  percent  per
annum, according to the selected installment schedule over a maximum of a six-year period following delivery of the drilling
rigs.  We have the right to prepay any outstanding borrowings, in full or in part, without penalty.  The Shipyard Loans contain
covenants  that,  among  other  things,  limit  the  ability  of  the  subsidiary  owners  of  the  drilling  rigs  to  incur  certain  types  of
additional indebtedness or make certain additional commitments or investments.  At December 31, 2021, we had no borrowings
outstanding under the Shipyard Loans.

Exchangeable bonds

Exchange terms—At December 31, 2021, the (a) current exchange rates, expressed as the number of Transocean Ltd.
shares per $1,000 note, (b) implied exchange prices per Transocean Ltd. share and (c) aggregate shares, expressed in millions,
issuable upon exchange of our exchangeable bonds were as follows:

0.50% Exchangeable Senior Bonds due January 2023
4.00% Senior Guaranteed Exchangeable Bonds due December 2025
2.50% Senior Guaranteed Exchangeable Bonds due January 2027

Implied

     Exchange      exchange      Shares

rate
97.29756
190.47620
162.16260

$

price

10.28
5.25
6.17

issuable     
13.6
56.0
38.6

The  exchange  rates  of  our  exchangeable  bonds,  identified  above,  are  subject  to  adjustment  upon  the  occurrence  of
certain events.  The 0.50% Exchangeable Senior Bonds may be exchanged by holders into Transocean Ltd. shares at any time
prior  to  the  close  of  business  on  the  business  day  immediately  preceding  the  maturity  date.    The  2.50%  Senior  Guaranteed
Exchangeable Bonds may be exchanged by holders into Transocean Ltd. shares at any time prior to the close of business on the
second business day immediately preceding the maturity date or redemption date.  The 4.00% Senior Guaranteed Exchangeable
Bonds  may  be  exchanged  by  holders  at  any  time  prior  to  the  close  of  business  on  the  second  business  day  immediately
preceding the maturity date and, at our election, such exchange may be settled by delivering cash, Transocean Ltd. shares or a
combination of cash and shares.

Effective interest rates and fair values—At December 31, 2021, the effective interest rates and estimated fair values

of our exchangeable bonds were as follows (in millions, except effective interest rates):

0.50% Exchangeable Senior Bonds due January 2023
4.00% Senior Guaranteed Exchangeable Bonds due December 2025
2.50% Senior Guaranteed Exchangeable Bonds due January 2027

     Effective     
    interest rate    

Fair
value

0.5% $
6.9%
0.0%

119
278
196

We estimated the fair values of the exchangeable debt instruments, including the exchange features, by employing a
binomial lattice model using significant other observable inputs, representative of Level 2 fair value measurements, including
the terms and credit spreads of our debt and the expected volatility of the market price for our shares.

Related  balances—At  December  31,  2021  and  2020,  the  premium  associated  with  the  original  issuance  of  the
0.50%  Exchangeable  Senior  Bonds  had  a  carrying  amount  of  $172  million,  recorded  in  equity  as  a  component  of  additional
paid-in capital.

Debt issuance

Senior guaranteed exchangeable bonds—On February 26, 2021, we issued $294 million aggregate principal amount
of the 4.00% Senior Guaranteed Exchangeable Bonds and made an aggregate cash payment of $11 million in private exchanges
(collectively,  the  “2021  Private  Exchange”)  for  $323  million  aggregate  principal  amount  of  the  0.50%  Exchangeable  Senior
Bonds.  In the year ended December 31, 2021, as a result of the 2021 Private Exchange, we recognized a gain of $51 million
($0.08 per diluted share), with no tax effect, associated with the retirement of debt (see “—Debt restructuring, repayment and
retirement”).  The initial carrying amount of the 4.00% Senior Guaranteed Exchangeable Bonds, measured at the estimated fair
value on the date of issuance, was $260 million.  We estimated the fair value of the exchangeable debt instrument, including the
exchange feature, by employing a binomial lattice model using significant other observable inputs, representative of Level 2 fair
value  measurements,  including  the  terms  and  credit  spreads  of  our  debt  and  expected  volatility  of  the  market  price  for  our
shares.

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TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

On August 14, 2020, we issued $238 million aggregate principal amount of 2.50% Senior Guaranteed Exchangeable
Bonds in non-cash private exchanges (collectively, the “2020 Private Exchange”) for $397 million aggregate principal amount
of the 0.50% Exchangeable Senior Bonds.  In the year ended December 31, 2020, as a result of the 2020 Private Exchange, we
recognized a gain of $72 million ($0.12 per diluted share), with no tax effect, associated with the restructuring of debt (see “—
Debt restructuring, repayment and retirement”).  We may redeem all or a portion of the 2.50% Senior Guaranteed Exchangeable
Bonds (i) on or after August 14, 2022, if certain conditions related to the price of our shares have been satisfied, at a price equal
to  100  percent  of  the  aggregate  principal  amount  and  (ii)  on  or  after  August  14,  2023,  at  specified  redemption  prices.    We
recorded the conversion feature of the 2.50% Senior Guaranteed Exchangeable Bonds, measured at its estimated fair value of
$46 million, to additional paid-in capital.  We estimated the fair value by employing a binomial lattice model using significant
other observable inputs, representative of Level 2 fair value measurements, including the expected volatility of the market price
for our shares.

Related  party  transactions—In  August  2020,  Perestroika  AS,  an  entity  affiliated  with  one  of  our  directors  that
beneficially  owns  approximately  10  percent  of  our  shares,  exchanged  $356  million  aggregate  principal  amount  of  the
0.50%  Exchangeable  Senior  Bonds  for  $213  million  aggregate  principal  amount  of  2.50%  Senior  Guaranteed  Exchangeable
Bonds.  Perestroika AS has certain registration rights related to its shares and shares that may be issued in connection with any
exchange  of  its  2.50%  Senior  Guaranteed  Exchangeable  Bonds.    At  December  31,  2021  and  2020,  Perestroika  AS  held
$213 million aggregate principal amount of the 2.50% Senior Guaranteed Exchangeable Bonds.

Guaranteed senior unsecured notes—On January 17, 2020, we issued $750 million aggregate principal amount of
8.00% senior notes due February 2027 (the “8.00% Senior Notes”), and we received aggregate cash proceeds of $743 million,
net of issue costs.  We may redeem all or a portion of the 8.00% Senior Notes on or prior to February 1, 2023 at a price equal to
100 percent of the aggregate principal amount plus a make-whole premium, and subsequently, at specified redemption prices.

Priority guaranteed senior unsecured notes—On September 11, 2020, we issued $687 million aggregate principal
amount of 11.50% senior guaranteed notes due January 2027 (the “11.50% Senior Guaranteed Notes”) in non-cash exchange
offers, pursuant to an exchange offer memorandum, dated August 10, 2020, as supplemented, for an aggregate principal amount
of  $1.5  billion  of  several  series  of  our  existing  debt  securities  that  were  validly  tendered  and  accepted  for  purchase  (the
“2020 Exchange Offers” and, together with the 2020 Private Exchange, the “2020 Exchange Transactions”).  In the year ended
December 31, 2020, as a result of the 2020 Exchange Offers, we recognized a gain of $355 million ($0.58 per diluted share),
with no tax effect, associated with the restructuring of debt (see “—Debt restructuring, repayment and retirement”).  We may
redeem all or a portion of the 11.50% Senior Guaranteed Notes prior to July 30, 2023 at a price equal to 100 percent of the
aggregate principal amount plus a make-whole premium, and subsequently, at specified redemption prices.  We may also use the
net cash proceeds of certain equity offerings by Transocean Ltd. to redeem, on one or more occasions prior to July 30, 2023, up
to  a  maximum  of  40  percent  of  the  original  aggregate  principal  amount  of  the  11.50%  Senior  Guaranteed  Notes,  subject  to
certain adjustments, at a redemption price equal to 111.50 percent of the aggregate principal amount.

Senior secured notes—On February 1, 2019, we issued $550 million aggregate principal amount of 6.875% Senior
Secured  Notes,  and  we  received  $539  million  aggregate  cash  proceeds,  net  of  discount  and  issue  costs.   The  6.875%  Senior
Secured Notes are secured by the assets and earnings associated with the ultra-deepwater floater Deepwater Poseidon and the
equity of the wholly owned subsidiaries that own or operate the collateral rig.  Additionally, we are required to maintain certain
balances  in  restricted  cash  accounts  to  satisfy  debt  service  requirements.   We  are  required  to  pay  semiannual  installments  of
principal and interest.  We may redeem all or a portion of the 6.875% Senior Secured Notes on or prior to February 1, 2022 at a
price  equal  to  100  percent  of  the  aggregate  principal  amount  plus  a  make-whole  premium,  and  subsequently,  at  specified
redemption prices.

On  May  24,  2019,  we  issued  $525  million  aggregate  principal  amount  of  5.375%  Senior  Secured  Notes,  and  we
received $517 million aggregate cash proceeds, net of discount and issue costs.  The 5.375% Senior Secured Notes are secured
by the assets and earnings associated with the harsh environment floaters Transocean Endurance and Transocean Equinox and
the equity of the wholly owned subsidiaries that own or operate the collateral rigs.  Additionally, we are required to maintain
certain balances in restricted cash accounts to satisfy debt service requirements.  We are required to pay semiannual installments
of principal and interest.  We may redeem all or a portion of the 5.375% Senior Secured Notes on or prior to May 15, 2021 at a
price  equal  to  100  percent  of  the  aggregate  principal  amount  plus  a  make-whole  premium,  and  subsequently,  at  specified
redemption prices.

Encumbered assets—At December 31, 2021, we had restricted cash and cash equivalents of $409 million deposited in
restricted accounts to satisfy debt service and reserve requirements for the senior secured notes.  At December 31, 2021, the rigs
encumbered  for  the  senior  secured  notes,  including  Deepwater  Conqueror,  Deepwater  Pontus,  Deepwater  Proteus,
Deepwater  Thalassa,  Deepwater  Poseidon,  Transocean  Enabler,  Transocean  Encourage,  Transocean  Endurance  and
Transocean Equinox,  had  an  aggregate  carrying  amount  of  $5.93  billion.    We  will  be  required  to  redeem  the  senior  secured
notes at a price equal to 100 percent of the aggregate principal amount without a make-whole premium, upon the occurrence of
certain events related to the respective collateral rigs and related drilling contracts.

Debt restructuring, repayment and retirement

Restructuring and early retirement—During the years ended December 31, 2021, 2020 and 2019, we restructured or
retired certain notes as a result of exchange offers, private exchanges, redemption, tender offers and open market repurchases.
 We recorded the

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TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

2020 Exchange Transactions completed in August 2020 and September 2020 under ASC 470-60, Troubled Debt Restructuring
by Debtors.  The aggregate principal amounts, cash payments and recognized gain or loss for such transactions were as follows
(in millions):

6.50% Senior Notes due November 2020
6.375% Senior Notes due December 2021
3.80% Senior Notes due October 2022
0.50% Exchangeable Senior Bonds due January 2023
5.375% Senior Secured Notes due May 2023
9.00% Senior Notes due July 2023
5.875% Senior Secured Notes due January 2024
7.25% Senior Notes due November 2025
7.50% Senior Notes due January 2026
8.00% Senior Notes due February 2027
7.45% Notes due April 2027
8.00% Debentures due April 2027
7.00% Notes due June 2028
7.50% Notes due April 2031
6.80% Senior Notes due March 2038
7.35% Senior Notes due December 2041

Aggregate principal amount restructured or retired

Aggregate cash payment
Aggregate principal amount of debt issued in exchanges
Aggregate net gain (loss)

$

$
$
$

Year ended December 31, 2021

Year ended December 31, 2020

   Exchange    Repurchase   

Total
$ — $ — $ — $ — $ — $

   Exchange    Redeem    Tender Repurchase   Total

Year ended December 31, 2019
Repurchase  

Tender

Total

—
—
323
—
—
—
—
—
—
—
—
—
—
—
—
323 $

38 $
77
—
37
—
10
—
136
—
—
—
397
—
— 103
—
11
—
— 714
—
—
—
—
68
— 132
207
—
—
—
181
—
—
—
138
—
—
—
35
—
—
—
35
—
—
—
39
—
—
—
192
—
—
—
390
—
—
—
—
123
79 $ 402 $1,910 $ 714 $ 360 $

—
—
323
11
—
68
—
—
—
—
—
—
—
—
—

53
15 $
183
69
162
16
401
4
146
43
714
—
—
—
339
—
181
—
138
—
35
—
35
—
39
—
192
—
390
—
—
123
147 $ 3,131

$

57 $
63
190
—
—
200
—
—
—
—
—
—
—
—
—
—
$ 510 $

23 $
43
32
—
—
336
—
—
—
—
—
—
—
—
—
—
434 $

80
106
222
—
—
536
—
—
—
—
—
—
—
—
—
—
944

11 $

79 $

110 $ 1,109
294 $ — $ 294 $ 925 $ — $ — $ — $ 925
36 $ 533
51 $ — $

51 $ 427 $ (65) $ 135 $

10 $ 767 $ 222 $

90 $

449 $

$ 522 $
971
$ — $ — $ —
(41)
$ (18) $

(23) $

Scheduled  maturities  and  installments—On  the  scheduled  maturity  date  of  December  15,  2021,  we  made  a  cash
payment  of  $38  million  to  repay  an  equivalent  aggregate  principal  amount  of  the  outstanding  6.375%  senior  notes  due
December 2021.  On the scheduled maturity date of November 16, 2020, we made a cash payment of $153 million to repay an
equivalent  aggregate  principal  amount  of  the  outstanding  6.50%  senior  notes  due  November  2020.    In  the  years  ended
December  31,  2021,  2020  and  2019,  we  made  an  aggregate  cash  payment  of  $478  million,  $375  million  and  $354  million,
respectively, to repay other indebtedness in scheduled installments.

NOTE 10—POSTEMPLOYMENT BENEFIT PLANS

Defined contribution plans

We sponsor defined contribution plans for our employees in most markets in which we operate worldwide, the most
significant  of  which  were  as  follows:  (1)  a  qualified  savings  plan  covering  certain  eligible  employees  working  in  the  U.S.,
(2)  various  savings  plans  covering  eligible  employees  working  in  Norway,  (3)  a  non-qualified  savings  plan  covering  certain
eligible  employees  working  outside  the  U.S.,  the  United  Kingdom  (“U.K.”)  and  Norway  and  (4)  a  qualified  savings  plan
covering certain eligible employees working in the U.K.  In the years ended December 31, 2021, 2020 and 2019, we recognized
expense  of  $52  million,  $56  million  and  $52  million,  respectively,  related  to  our  defined  contribution  plans,  recorded  in  the
same financial statement line item as cash compensation paid to the respective employees.

Defined benefit pension and other postemployment benefit plans

Overview—As  of  December  31,  2021,  we  had  defined  benefit  plans  in  the  U.S.,  including  three  funded  and
three  unfunded  defined  benefit  plans  (the  “U.S.  Plans”),  and  in  the  U.K.,  we  had  one  funded  defined  benefit  plan  (the
“U.K. Plan”).  During the year ended December 31, 2021, as required by local authorities, we terminated our two remaining
plans  in  Norway  (together  with  the  U.K.  Plan,  the  “Non-U.S.  Plans”).    We  also  maintain  certain  unfunded  other
postemployment benefit plans (collectively, the “OPEB Plans”), under which benefits to eligible participants diminish during a
phase-out period ending December 31, 2025.  We maintain the benefit obligations under our plans until they are fully satisfied.

Net  periodic  benefit  costs—We  estimated  our  net  periodic  benefit  costs  using  the  following  weighted-average

assumptions:

Discount rate
Expected rate of return

“na” means not applicable.

U.S.
    Plans

Year ended December 31, 2021
OPEB
Non-U.S.
Plans
Plans
1.21 % 
1.50 % 
na
3.20 % 

2.60 % 
5.51 % 

Year ended December 31, 2020
OPEB
Non-U.S.
Plans
Plans
2.39 % 
2.10 % 
na
3.10 % 

U.S.
Plans
3.27 % 
5.90 % 

Year ended December 31, 2019
OPEB
Non-U.S.
Plans
Plans
3.56 %
2.86 % 
na
4.39 % 

U.S.
Plans
4.32 % 
6.20 % 

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TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

Net periodic benefit costs recognized included the following components (in millions):

Year ended December 31, 2021

U.S.
Plans

Non-U.S.

   Plans

OPEB
   Plans

   Total

Year ended December 31, 2020

U.S.
Plans

Non-U.S.

   Plans

OPEB
   Plans

   Total

Year ended December 31, 2019

U.S.
Plans

Non-U.S.
Plans

OPEB
Plans

Total

Net periodic benefit costs
Service cost
Interest cost
Expected return on plan assets
Settlements and curtailments
Actuarial loss, net
Prior service gain, net

Net periodic benefit costs
(income)

$ — $ — $ — $ — $ — $
—
—
—
—
(2)

6
(13)
(2)
1
—

53
(79)
(2)
12
(2)

47
(66)
—
11
—

55
(67)
1
9
—

1 $ — $
8
(14)
12
1
—

—
—
—
1
(2)

1
63
(81)
13
11
(2)

$ — $
63
(71)
1
3
—

7 $ — $
10
(17)
2
—
—

1
—
—
—
(2)

7
74
(88)
3
3
(2)

$

(8) $

(8) $

(2) $

(18)

$

(2) $

8 $

(1) $

5

$

(4) $

2 $

(1) $

(3)

Funded status—We estimated our benefit obligations using the following weighted-average assumptions:

Discount rate
Expected long-term rate of return

“na” means not applicable.

December 31, 2021
U.K.
U.S.
Plan
Plans
2.91 % 
1.90 % 
4.82 % 2.00 % 

OPEB
Plans
1.83 % 
na

December 31, 2020
Non-U.S.
U.S.
Plans
Plans
2.60 % 
1.50 % 
5.51 % 3.20 % 

OPEB
Plans
1.21 %
na

The  changes  in  projected  benefit  obligation,  plan  assets  and  funded  status  and  the  amounts  recognized  on  our

consolidated balance sheets were as follows (in millions):

Change in projected benefit obligation
Projected benefit obligation, beginning of period
Actuarial losses (gains), net
Service cost
Interest cost
Currency exchange rate changes
Benefits paid
Settlements
Plan amendment

Projected benefit obligation, end of period

Change in plan assets
Fair value of plan assets, beginning of period
Actual return on plan assets
Currency exchange rate changes
Employer contributions
Benefits paid
Settlements

Fair value of plan assets, end of period

Year ended December 31, 2021

Year ended December 31, 2020

U.S.
Plans

Non-U.S.
Plans

OPEB
Plans

Total

U.S.
Plans

Non-U.S.
Plans

OPEB
Plans

Total

$

  $ 1,825
(72)
—
47
—
(76)
—
—
1,724

1,565
131
—
1
(76)
—
1,621

$

384
(21)
—
6
(2)
(17)
(2)
—
348

420
29
(3)
7
(17)
(2)
434

16
(1)
—
—
—
(2)
—
—
13

—
—
—
2
(2)
—
—

$

$ 2,225
(94)
—
53
(2)
(95)
(2)
—
2,085

$ 1,696
148
—
55
—
(72)
(2)
—
1,825

1,985
160
(3)
10
(95)
(2)
2,055

1,369
267
—
3
(72)
(2)
1,565

$

395
46
1
8
9
(24)
(52)
1
384

430
50
6
9
(24)
(51)
420

$

17
1
—
—
—
(2)
—
—
16

—
—
—
2
(2)
—
—

2,108
195
1
63
9
(98)
(54)
1
2,225

1,799
317
6
14
(98)
(53)
1,985

Funded status, end of period

  $ (103) $

86

$

(13) $

(30) $

(260) $

36

$

(16) $

(240)

Balance sheet classification, end of period:
Pension asset, non-current
Pension liability, current
Pension liability, non-current
Accumulated other comprehensive loss (income), before taxes

  $

$

16
(1)
(118)
95

86
—
—
42

$ — $

(3)
(10)
(10)

102
(4)
(128)
127

$ — $

(1)
(259)
242

37
(1)
—
80

$ — $

(3)
(13)
(10)

37
(5)
(272)
312

Accumulated benefit obligation, end of period

$ 1,724

$

348

$

13

$ 2,085

$ 1,825

$

384

$

16

$

2,225

Certain  amounts  related  to  plans  with  a  projected  benefit  obligation  in  excess  of  plan  assets  were  as  follows

(in millions):

Projected benefit obligation
Fair value of plan assets

U.S.
Plans

December 31, 2021
OPEB
Plans

U.K.
Plan

  $

140
20

$ — $
—

$

13
—

Total

153
20

U.S.
Plans
$ 1,825
1,565

December 31, 2020
OPEB
Non-U.S.
Plans
Plans

$

$

2
1

$

16
—

Total
1,843
1,566

Certain  amounts  related  to  plans  with  an  accumulated  benefit  obligation  in  excess  of  plan  assets  were  as  follows

(in millions):

Accumulated benefit obligation
Fair value of plan assets

U.S.
Plans

December 31, 2021
OPEB
Plans

U.K.
Plan

  $

$ — $
—

140
20
- 63 -

$

13
—

Total

153
20

U.S.
Plans
$ 1,825
1,565

December 31, 2020
OPEB
Non-U.S.
Plans
Plans

$

$

2
1

$

16
—

Total
1,843
1,566

 
 
 
  
  
  
  
  
  
 
 
   
   
   
   
   
 
 
 
    
    
    
    
    
    
    
    
 
 
 
    
    
    
    
    
    
    
    
 
 
 
    
    
    
    
    
    
    
    
 
Table of Contents

TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

The  amounts  in  accumulated  other  comprehensive  loss  (income)  that  have  not  been  recognized  were  as  follows

(in millions):

Actuarial loss, net
Prior service cost, net

Accumulated other comprehensive loss (income), before taxes

U.S.
Plans

December 31, 2021
OPEB
Plans

U.K.
Plan

Total

U.S.
Plans

December 31, 2020
OPEB
Non-U.S.
Plans
Plans

  $

  $

95
—
95

$

$

40
2
42

$ — $
(10)
(10) $

$

135
(8)
127

$

$

242
—
242

$

$

78
2
80

$

$

$

2
(12)
(10) $

Total

322
(10)
312

Plan assets—The weighted-average target and actual allocations of assets for the funded defined benefit plans were as

follows:

December 31, 2021

December 31, 2020

Target allocation
U.K.
U.S.
     Plans
Plan

Actual allocation
U.K.
U.S.
     Plans
Plan

Target allocation
U.S.
     Plans

     Plans

Non-U.S.

Actual allocation  
U.S.
     Plans

     Plans

Non-U.S.

Equity securities
Fixed income securities
Other investments

Total

25 %
19 %  
19 %  
38 %  
74 %
80 %  
62 %  
81 %  
1 %
1 %   —
— % — %   — %
100 %   100 %   100 %   100 %   100 %   100 %   100 %   100 %

27 %  
73 %  
— %   —

38 %  
62 %  

55 %  
45 %  

50 %  
50 %  

We  periodically  review  our  investment  policies,  plan  assets  and  asset  allocation  strategies  to  evaluate  performance
relative  to  specified  objectives.    In  determining  our  asset  allocation  strategies  for  the  U.S.  Plans,  we  review  the  results  of
regression  models  to  assess  the  most  appropriate  target  allocation  for  each  plan,  given  the  plan’s  status,  demographics  and
duration.  For the U.K. Plan, the plan trustees establish the asset allocation strategies consistent with the regulations of the U.K.
pension  regulators  and  in  consultation  with  financial  advisors  and  company  representatives.    Investment  managers  for  the
U.S. Plans and the U.K. Plan are given established ranges within which the investments may deviate from the target allocations.

The investments for the funded defined benefit plans were categorized as follows (in millions):

Significant observable inputs
U.K.
Plan

U.S.
Plans

Total

December 31, 2021
Significant other observable inputs
U.K.
Plan

U.S.
Plans

Total

U.S.
Plans

Total
U.K.
Plan

Total

Mutual funds
U.S. equity funds
Non-U.S. equity funds
Bond funds

Total mutual funds

Other investments
Cash and money market funds

  $

421 $ — $
184
999
1,604

421
184
—
—
999
— 1,604

$

— $
7
4
11

— $
85
346
431

— $
92
350
442

421 $ — $
191
1,003
1,615

85
346
431

421
276
1,349
2,046

6

3

9

—

—

—

6

3

9

Total investments

  $ 1,610 $

3 $ 1,613

$

11

$

431

$

442

$ 1,621 $

434 $ 2,055

Significant observable inputs
Non-U.S.
Plans

U.S.
Plans

Total

December 31, 2020
Significant other observable inputs
Non-U.S.
Plans

U.S.
Plans

Total

U.S.
Plans

Total
Non-U.S.
Plans

Total

Mutual funds
U.S. equity funds
Non-U.S. equity funds
Bond funds

Total mutual funds

Other investments
Cash and money market funds
Investment contracts

Total other investments

  $

586 $ — $
263
699
1,548

586
263
—
699
—
— 1,548

$

— $
7
4
11

— $
103
310
413

— $
110
314
424

586 $ — $
270
703
1,559

103
310
413

586
373
1,013
1,972

6
—
6

6
—
6

12
—
12

—
—
—

—
1
1

—
1
1

6
—
6

6
1
7

12
1
13

Total investments

  $ 1,554 $

6 $ 1,560

$

11

$

414

$

425

$ 1,565 $

420 $ 1,985

We  estimated  the  fair  values  of  the  plan  assets  by  applying  the  market  approach,  as  categorized  above,  using  either
(i) significant observable inputs, representative of Level 1 fair value measurements, including market prices of actively traded
funds, or (ii) significant other observable inputs, representative of Level 2 fair value measurements, including market prices of
the  underlying  securities  in  the  collective  trust  funds.    The  U.S.  Plans  and  the  U.K.  Plan  invest  in  passively  and  actively
managed funds that are referenced to or benchmarked against market indices.  The plan investment managers have discretion to
select the securities held within each asset category.  Given this discretion, the managers may occasionally invest in our debt or
equity securities and may hold either long or short positions in such securities.  Since plan investment managers are required to
maintain well diversified portfolios, the actual investment in our securities would be immaterial relative to asset categories and
the overall plan assets.

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Table of Contents

TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

Funding contributions and benefit payments—In the years ended December 31, 2021, 2020 and 2019, we made an
aggregate contribution of $10 million, $14 million and $22 million, respectively, to the defined benefit pension plans and the
OPEB Plans using our cash flows from operations.  In the year ending December 31, 2022, we expect to make an aggregate
contribution  of  $4  million,  including  $1  million  and  $3  million  to  the  defined  benefit  pension  plans  and  the  OPEB  Plans,
respectively.

The projected benefits payments were as follows (in millions):

Years ending December 31,
2022
2023
2024
2025
2026
2027 - 2031

NOTE 11—INCOME TAXES

U.S.
Plans

U.K.
Plan

OPEB
Plans

Total

  $

$

82
83
83
84
84
424

$

6
6
6
7
8
52

$

3
3
3
2
1
1

91
92
92
93
93
477

Overview—Transocean  Ltd.,  a  holding  company  and  Swiss  resident,  is  subject  to  Swiss  federal,  cantonal  and
communal income tax.  For Swiss income taxes, however, qualifying net dividend income and net capital gains on the sale of
qualifying investments in subsidiaries are exempt from taxation.  Consequently, there is not a direct relationship between our
Swiss earnings before income taxes and our Swiss income tax expense.

Tax  provision  and  rate—In  the  years  ended  December  31,  2021,  2020  and  2019,  our  effective  tax  rate  was
(25.7) percent, (5.1) percent and (4.9) percent, respectively, based on loss before income tax expense.  The relationship between
our provision for or benefit from income taxes and our income or loss before income taxes can vary significantly from period to
period considering, among other factors, (a) the overall level of income before income taxes, (b) changes in the blend of income
that  is  taxed  based  on  gross  revenues  rather  than  income  before  taxes,  (c)  rig  movements  between  taxing  jurisdictions  and
(d) our rig operating structures.

The components of our income tax provision (benefit) were as follows (in millions):

Current tax benefit
Deferred tax expense

Income tax expense

Years ended December 31, 
     2021      2020      2019
  $

(7) $

128
121

$

  $

(33) $ (189)
248
60
59
27

$

A reconciliation of the income tax benefit computed at the Swiss holding company federal statutory rate of 7.83% and

our reported consolidated income tax expense was as follows (in millions):

Income tax benefit at Swiss federal statutory rate
Changes in valuation allowance
Earnings subject to rates different than the Swiss federal statutory rate
Deemed profits taxes
Jurisdictional ownership changes of certain assets
Withholding taxes
Losses on impairment
Changes in unrecognized tax benefits, net
Swiss Federal Act on Tax Reform and AHV Financing
Base erosion and anti-abuse tax
U.S. Coronavirus Aid, Relief, and Economic Security Act
Operating structural changes
Other, net

Income tax expense

Years ended December 31, 
     2021      2020      2019
  $

(36) $

1,167
78
17
16
10
5
(43)
(1,095)
—
—
—
2
121

$

  $

(42) $
(31)
82
19
—
6
52
(15)
—
5
(28)
—
(21)
27

$

(94)
37
189
22
—
11
35
(268)
—
21
—
98
8
59

In January 2020, Switzerland made effective the Federal Act on Tax Reform and AHV Financing (“TRAF”), which
will  subject  us  to  ordinary  taxation,  effective  January  1,  2022,  following  the  expiration  of  our  transition  rulings.    In
November 2021, we reached an agreement with the Swiss tax authorities regarding the manner by which TRAF will apply to
certain  Swiss  subsidiaries,  which  will  allow  us  to  access  historic  depreciation  and  costs  related  to  financing  assets  not
previously  deducted  on  Swiss  tax  returns,  which  can  be  apportioned  to  offset  taxable  income  based  on  the  remaining  useful
lives of the rigs and financing assets.  In the year ended December 31, 2021, we recorded a deferred tax liability of $238 million
and a deferred tax asset of $1.33 billion, offset with a valuation allowance of $1.17 billion.

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TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

The Coronavirus Aid, Relief, and Economic Security Act, enacted in March 2020, made certain changes to U.S. tax
law,  including,  among  others,  extending  up  to  five  years  the  carryback  period  for  net  operating  losses  generated  between
December  31,  2017  and  January  1,  2021.    In  the  year  ended  December  31,  2020,  we  recognized  an  income  tax  benefit  of
$28 million related to the carryback of our net operating losses under this provision.

In the year ended December 31, 2019, as a result of the U.S. base erosion and anti-abuse tax, we recognized income
tax expense of $21 million related to the bareboat charter structure of our U.S. operations, a significant portion of which was
contractually reimbursed by our customers under a change-in-law provision in our drilling contracts.

Deferred taxes—The significant components of our deferred tax assets and liabilities were as follows (in millions):

Deferred tax assets
Swiss historic depreciation and financing asset costs
Net operating loss carryforwards
Interest expense limitation
United Kingdom charter limitation
Accrued expenses
Tax credits
Deferred income
Accrued payroll costs not currently deductible
Loss contingencies
Other
Valuation allowance

Total deferred tax assets

Deferred tax liabilities
Depreciation
Contract intangible amortization
Other

Total deferred tax liabilities

December 31, 

2021

2020

$

$

1,333
915
67
53
23
19
7
2
2
31
(1,820)
632

(1,052)
(11)
(9)
(1,072)

—
809
72
40
18
21
14
46
3
27
(685)
365

(658)
(6)
(7)
(671)

Deferred tax assets (liabilities), net

  $

(440) $

(306)

As  of  December  31,  2021,  we  include  taxes  related  to  the  earnings  of  all  of  our  subsidiaries  since  we  no  longer

consider the earnings of any of our subsidiaries to be indefinitely reinvested.

At  December  31,  2021  and  2020,  our  deferred  tax  assets  included  U.S.  foreign  tax  credits  of  $19  million  and
$21  million,  respectively,  which  will  expire  between  2024  and  2031.    Deferred  tax  assets  related  to  our  net  operating  losses
were  generated  in  various  worldwide  tax  jurisdictions.   At  December  31,  2021,  our  net  deferred  tax  assets  related  to  our  net
operating loss carryforwards included $668 million, which do not expire, and $247 million, which will expire between 2022 and
2038.

As  of  December  31,  2021,  our  consolidated  cumulative  loss  incurred  over  the  recent  three-year  period  represented
significant objective negative evidence for the evaluation of the realizability of our deferred tax assets.  Although such evidence
has limited our ability to consider other subjective evidence, we evaluate each jurisdiction separately.  We consider objective
evidence, such as contract backlog activity, in jurisdictions in which we have profitable contracts, and the ability to carryback
losses or utilize losses against potential exposures.  If estimated future taxable income changes during the carryforward periods
or if the cumulative loss is no longer present, we may adjust the amount of deferred tax assets that we expect to realize.  At
December 31, 2021 and 2020, due to uncertainty of realization, we had a valuation allowance of $1.82 billion and $685 million,
respectively, on net operating losses and other deferred tax assets due to the uncertainty of realization.

Unrecognized  tax  benefits—The  changes  to  unrecognized  tax  benefits,  excluding  interest  and  penalties  that  we

recognize as a component of income tax expense, were as follows (in millions):

Years ended December 31, 
2021    

2020    

Balance, beginning of period
Additions for current year tax positions
Additions for prior year tax positions
Reductions related to statute of limitation expirations and changes in law
Reductions due to settlements
Reductions for prior year tax positions

Balance, end of period

  $

  $

378 $
28
46
(19)
(31)
—
402 $

335 $
90
11
(7)
—
(51)
378 $

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2019  
408
144
6
(138)
(19)
(66)
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TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

Our unrecognized tax benefits, including related interest and penalties that we recognize as a component of income tax

expense, were as follows (in millions):

Unrecognized tax benefits, excluding interest and penalties
Interest and penalties

Unrecognized tax benefits, including interest and penalties

December 31, 
2021

2020

$

$

402
33
435

$

$

378
41
419

In the years ended December 31, 2021, 2020 and 2019, we recognized, as a component of our income tax provision,
expense of $8 million, expense of $7 million and benefit of $72 million, respectively, related to interest and penalties associated
with  our  unrecognized  tax  benefits.    As  of  December  31,  2021,  we  have  unrecognized  benefits  of  $435  million,  including
interest and penalties, against which we have recorded net operating loss deferred tax assets of $320 million, resulting in net
unrecognized  tax  benefits  of  $115  million,  including  interest  and  penalties,  that  upon  reversal  would  favorably  impact  our
effective  tax  rate.    During  the  year  ending  December  31,  2022,  it  is  reasonably  possible  that  our  existing  liabilities  for
unrecognized  tax  benefits  may  increase  or  decrease,  primarily  due  to  the  progression  of  open  audits  and  the  expiration  of
statutes  of  limitation.    However,  we  cannot  reasonably  estimate  a  range  of  potential  changes  in  our  existing  liabilities  for
unrecognized tax benefits due to various uncertainties, such as the unresolved nature of various audits.

Tax  positions  and  returns—We  conduct  operations  through  our  various  subsidiaries  in  countries  throughout  the
world.    Each  country  has  its  own  tax  regimes  with  varying  nominal  rates,  deductions  and  tax  attributes  that  are  subject  to
changes  resulting  from  new  legislation,  interpretation  or  guidance.    From  time  to  time,  as  a  result  of  these  changes,  we  may
revise previously evaluated tax positions, which could cause us to adjust our recorded tax assets and liabilities.  Tax authorities
in certain jurisdictions are examining our tax returns and, in some cases, have issued assessments.  We intend to defend our tax
positions vigorously.  Although we can provide no assurance as to the outcome of the aforementioned changes, examinations or
assessments, we do not expect the ultimate liability to have a material adverse effect on our condensed consolidated statement
of financial position or results of operations; however, it could have a material adverse effect on our condensed consolidated
statement of cash flows.

Brazil tax investigations—In December 2005, the Brazilian tax authorities began issuing tax assessments with respect
to  our  tax  returns  for  the  years  2000  through  2004.    In  May  2014,  the  Brazilian  tax  authorities  issued  an  additional  tax
assessment  for  the  years  2009  and  2010.    We  filed  protests  with  the  Brazilian  tax  authorities  for  the  assessments  and  are
engaged in the appeals process, and a portion of two cases were favorably closed.  As of December 31, 2021, the remaining
aggregate  tax  assessment,  including  interest  and  penalties,  was  for  corporate  income  tax  of  BRL  638  million,  equivalent  to
approximately  $115  million,  and  indirect  tax  of  BRL  110  million,  equivalent  to  $20  million.    We  believe  our  returns  are
materially  correct  as  filed,  and  we  are  vigorously  contesting  these  assessments.   An  unfavorable  outcome  on  these  proposed
assessments  could  have  a  material  adverse  effect  on  our  consolidated  statement  of  financial  position,  results  of  operations  or
cash flows.

NOTE 12—LOSS PER SHARE

The computation of basic and diluted loss per share was as follows (in millions, except per share data):

Numerator for loss per share, basic and diluted
Net loss attributable to controlling interest

Denominator for loss per share, basic and diluted
Weighted-average shares outstanding
Effect of share-based awards

Weighted-average shares for per share calculation

Loss per share, basic and diluted

Years ended December 31, 
2019
2020
2021

$ (592) $ (567) $ (1,255)

636
1
637

614
1
615

611
1
612

$ (0.93) $ (0.92) $ (2.05)

In the years ended December 31, 2021, 2020 and 2019, we excluded from the calculation 12.6 million, 10.8 million
and  12.0  million  share-based  awards,  respectively,  since  the  effect  would  have  been  anti-dilutive.    In  the  years  ended
December  31,  2021,  2020  and  2019,  we  excluded  from  the  calculation  104.4  million,  84.0  million  and  84.0  million  shares,
respectively, issuable upon conversion of the 0.50% Exchangeable Senior Bonds, the 2.50% Senior Guaranteed Exchangeable
Bonds and the 4.00% Senior Guaranteed Exchangeable Bonds since the effect would have been anti-dilutive.

NOTE 13—COMMITMENTS AND CONTINGENCIES

Purchase and service agreement obligations

We  have  purchase  obligations  with  shipyards  and  other  contractors  primarily  related  to  our  newbuild  construction
programs.   We  also  have  long-term  service  agreements  with  original  equipment  manufacturers  to  provide  services  and  parts,
primarily related to our pressure

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TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

control systems and drilling systems.  The future payments required under our service agreements were estimated based on our
projected  operating  activity  and  may  vary  subject  to  actual  operating  activity.   At  December  31,  2021,  the  aggregate  future
payments required under our purchase obligations and our service agreement obligations were as follows (in millions):

Years ending December 31,
2022
2023
2024
2025
2026
Thereafter
Total

Purchase
     obligations

Service
agreement
obligations

  $

  $

950
52
—
—
—
—
1,002

$

$

116
121
126
130
134
173
800

Letters of credit and surety bonds

At  December  31,  2021  and  2020,  we  had  outstanding  letters  of  credit  totaling  $18  million  and  $24  million,
respectively,  issued  under  various  committed  and  uncommitted  credit  lines  provided  by  banks  to  guarantee  various  contract
bidding,  performance  activities  and  customs  obligations.   At  December  31,  2021  and  2020,  we  also  had  outstanding  surety
bonds totaling $146 million and $153 million, respectively, to secure customs obligations related to the importation of our rigs
and  certain  performance  and  other  obligations.    At  December  31,  2021  and  2020,  the  aggregate  cash  collateral  held  by
institutions to secure our letters of credit and surety bonds was $8 million.

Legal proceedings

Debt  exchange  litigation  and  purported  notice  of  default—Prior  to  the  consummation  of  the  2020  Exchange
Transactions (see Note 9—Debt), we completed certain internal reorganization transactions (the “Internal Reorganization”).  In
September 2020, funds managed by, or affiliated with, Whitebox Advisors LLC (“Whitebox”) as holders of certain series of our
notes subject to the 2020 Exchange Offers, filed a claim (the “Claim”) in the U.S. District Court for the Southern District of
New  York  (the  “Trial  Court”)  related  to  such  certain  internal  reorganization  transactions  and  the  2020  Exchange  Offers.
  Additionally,  in  September  and  October  2020,  Whitebox  and  funds  managed  by,  or  affiliated  with,  Pacific  Investment
Management Company LLC, as debtholders, together with certain other advisors and debtholders, provided purported notices of
alleged default with respect to the indentures governing, respectively, the 8.00% Senior Notes and the 7.25% senior notes due
November 2025 (the “7.25% Senior Notes”).

On September 23, 2020, we filed an answer to the Claim with the Trial Court and asserted counterclaims seeking a
declaratory  judgment  that,  among  other  matters,  the  Internal  Reorganization  did  not  cause  a  default  under  the  indenture
governing the 8.00% Senior Notes.  Concurrently, with our answer and counterclaims, we also submitted a motion for summary
judgment seeking an expedited judgment on our request for declaratory judgment.  Whitebox subsequently submitted a cross-
motion  for  summary  judgment  seeking  dismissal  of  our  counterclaims.    On  November  30,  2020,  while  awaiting  the  Trial
Court’s ruling on our motion for summary judgment, we amended certain of our financing documents and implemented certain
internal  reorganization  transactions,  which  resolved  the  allegations  contained  in  the  purported  notices  of  default.    On
December  17,  2020,  the  Trial  Court  issued  its  ruling  granting  our  motion  for  summary  judgment  and  denying  the  plaintiff’s
cross-motion  for  summary  judgment,  holding,  among  other  matters,  that  the  allegations  contained  in  the  purported  notice  of
default  did  not  constitute  a  default  under  the  indenture  governing  the  8.00%  Senior  Notes.   Whitebox  has  appealed  the  Trial
Court’s ruling.

The facts alleged in the purported notice of default under the 8.00% Senior Notes were the same as the facts underlying
the  Claim  and  the  purported  notice  of  default  under  the  7.25%  Senior  Notes.    Accordingly,  following  the  amendment  and
internal reorganization transactions on November 30, 2020, and the subsequent ruling from the Trial Court granting our motion
for summary judgment, we do not expect the liability, if any, resulting from these matters to have a material adverse effect on
our consolidated statement of financial position, results of operations or cash flows.  See Note 20—Subsequent Event.

Asbestos  litigation—In  2004,  several  of  our  subsidiaries  were  named,  along  with  numerous  other  unaffiliated
defendants, in complaints filed in the Circuit Courts of the State of Mississippi, and in 2014, a group of similar complaints were
filed  in  Louisiana.   The  plaintiffs,  former  employees  of  some  of  the  defendants,  generally  allege  that  the  defendants  used  or
manufactured  asbestos  containing  drilling  mud  additives  for  use  in  connection  with  drilling  operations,  claiming  negligence,
products liability, strict liability and claims allowed under the Jones Act and general maritime law.  The plaintiffs generally seek
awards of unspecified compensatory and punitive damages, but the court-appointed special master has ruled that a Jones Act
employer  defendant,  such  as  us,  cannot  be  sued  for  punitive  damages.    One  of  our  subsidiaries  was  named  in  additional
complaints  filed  in  Illinois  and  Missouri,  where  the  plaintiffs  similarly  allege  that  the  defendants  manufactured  asbestos
containing products or used asbestos-containing drilling mud additives in connection with land-based drilling operations.  At
December  31,  2021,  11  plaintiffs  have  claims  pending  in  Louisiana  and  9  plaintiffs  have  claims  pending  in  Illinois  and
Missouri, in which we have or may have an interest.  We intend to defend these lawsuits vigorously, although we can provide no
assurance as to the outcome.  We historically have maintained broad liability insurance, although we are not certain whether
insurance will cover the liabilities, if any, arising out of these claims.  Based on our evaluation of the exposure to date, we do
not expect the liability, if any, resulting from these claims to have a material adverse effect on our consolidated statement of
financial position, results of operations or cash flows.

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NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

One of our subsidiaries was named as a defendant, along with numerous other companies, in lawsuits arising out of the
subsidiary’s manufacture and sale of heat exchangers, and involvement in the construction and refurbishment of major industrial
complexes  alleging  bodily  injury  or  personal  injury  as  a  result  of  exposure  to  asbestos.    As  of  December  31,  2021,  the
subsidiary  was  a  defendant  in  approximately  250  lawsuits  with  a  corresponding  number  of  plaintiffs.    For  many  of  these
lawsuits, we have not been provided sufficient information from the plaintiffs to determine whether all or some of the plaintiffs
have claims against the subsidiary, the basis of any such claims, or the nature of their alleged injuries.  The operating assets of
the subsidiary were sold in 1989.  In December 2021, the subsidiary and certain insurers agreed to a settlement of outstanding
disputes that provide the subsidiary with cash.  An earlier settlement, achieved in September 2018, provided the subsidiary with
cash and an annuity that begins making payments in 2024.  Together with a coverage-in-place agreement with certain insurers
and  additional  coverage  issued  by  other  insurers,  we  believe  the  subsidiary  has  sufficient  resources  to  respond  to  both  the
current lawsuits as well as future lawsuits of a similar nature.  While we cannot predict or provide assurance as to the outcome
of these matters, we do not expect the ultimate liability, if any, resulting from these claims to have a material adverse effect on
our consolidated statement of financial position, results of operations or cash flows.

Macondo  well  incident—In  June  2020,  the  U.S.  District  Court  for  the  Eastern  District  of  Louisiana  (the
“MDL  Court”)  released  the  then-remaining  $125  million  of  assets  held  in  the  escrow  account  established  to  satisfy  our
remaining obligations under the settlement agreement that we and the Plaintiff Steering Committee filed in May 2015 with the
MDL  Court,  in  which  most  claims  against  us  for  damages  related  to  the  blowout  of  the  Macondo  well  in  April  2010  were
consolidated  by  the  U.S.  Judicial  Panel  on  Multidistrict  Litigation.    Following  the  release  of  assets,  all  significant  litigation,
including civil and criminal claims, resulting from the Macondo well incident had been resolved.

Other matters—We  are  involved  in  various  regulatory  matters  and  a  number  of  claims  and  lawsuits,  asserted  and
unasserted, all of which have arisen in the ordinary course of our business.  We do not expect the liability, if any, resulting from
these other matters to have a material adverse effect on our consolidated statement of financial position, results of operations or
cash flows.  We cannot predict with certainty the outcome or effect of any of the litigation matters specifically described above
or  of  any  such  other  pending,  threatened,  or  possible  litigation  or  liability.   We  can  provide  no  assurance  that  our  beliefs  or
expectations  as  to  the  outcome  or  effect  of  any  tax,  regulatory,  lawsuit  or  other  litigation  matter  will  prove  correct  and  the
eventual outcome of these matters could materially differ from management’s current estimates.

Environmental matters

We have certain potential liabilities under the Comprehensive Environmental Response, Compensation, and Liability
Act (“CERCLA”) and similar state acts regulating cleanup of hazardous substances at various waste disposal sites, including
those  described  below.    CERCLA  is  intended  to  expedite  the  remediation  of  hazardous  substances  without  regard  to  fault.
 Potentially responsible parties (“PRPs”) for each site include present and former owners and operators of, transporters to and
generators of the substances at the site.  It is difficult to quantify the potential cost of environmental matters and remediation
obligations.  Liability is strict and can be joint and several.

One of our subsidiaries was named as a PRP in connection with a site located in Santa Fe Springs, California, known
as  the  Waste  Disposal,  Inc.  site.    We  and  other  PRPs  agreed,  under  a  participation  agreement  with  the  U.S.  Environmental
Protection Agency (the “EPA”) and the U.S. Department of Justice, to settle our potential liabilities by remediating the site.  The
remedial  action  for  the  site  was  completed  in  2006.    Our  share  of  the  ongoing  operating  and  maintenance  costs  has  been
insignificant, and we do not expect any additional potential liabilities to be material.  Resolutions of other claims by the EPA,
the  involved  state  agency  or  PRPs  are  at  various  stages  of  investigation.    Nevertheless,  based  on  available  information  with
respect to all environmental matters, including all related pending legal proceedings, asserted legal claims and known potential
legal claims that are likely to be asserted, we do not expect the ultimate liability, if any, resulting from such matters, to have a
material adverse effect on our consolidated statement of financial position, results of operations or cash flows.

NOTE 14—EQUITY

Share issuance—In June 2021, we commenced an at the market equity offering program (the “ATM Program”) with
no expected expiration.  On June 14, 2021, we entered into an equity distribution agreement with a sales agent for the offer and
sale of our shares, with up to a maximum aggregate net offering price of $400 million, under the ATM Program.  We intend to
use  the  net  proceeds  from  the  ATM  Program  for  general  corporate  purposes,  which  may  include,  among  other  things  the
repayment or refinancing of indebtedness and the funding of working capital, capital expenditures, investments and additional
balance  sheet  liquidity.    In  the  year  ended  December  31,  2021,  we  received  aggregate  cash  proceeds  of  $158  million,  net  of
issue costs, for the aggregate sale of 36.1 million shares, under the ATM Program.

Shares held by subsidiaries—One of our subsidiaries holds our shares for future use to deliver shares in connection
with sales under the ATM Program and in connection with awards granted under our incentive plans or other rights to acquire
our shares.  At December 31, 2021 and 2020, our subsidiary held 72.7 million and 24.5 million shares, respectively.

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TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

NOTE 15—SHARE-BASED COMPENSATION

Overview

We  have  a  long-term  incentive  plan  (the  “Long-Term  Incentive  Plan”)  for  executives,  key  employees  and  non-
employee  directors  under  which  awards  can  be  granted  in  the  form  of  restricted  share  units,  restricted  shares,  stock  options,
stock appreciation rights and cash performance awards.  Awards may be granted as service awards that are earned over a defined
service  period  or  as  performance  awards  that  are  earned  based  on  the  achievement  of  certain  market  factors  or  performance
targets  or  a  combination  of  market  factors  and  performance  targets.    The  compensation  committee  of  our  board  of  directors
determines the terms and conditions of the awards granted under the Long-Term Incentive Plan.  At December 31, 2021, we had
85.7  million  shares  authorized  and  30.0  million  shares  available  to  be  granted  under  the  Long-Term  Incentive  Plan.    At
December  31,  2021,  the  total  unrecognized  compensation  cost  related  to  our  unvested  share-based  awards  was  $29  million,
which we expect to recognize over a weighted-average period of 1.8 years.

Service awards typically vest either in three  equal  annual  installments  beginning  on  the  first  anniversary  date  of  the
grant or in an aggregate installment at the end of the stated vesting period.  Service-based stock options, once fully vested, are
typically exercisable during a seven-year period.  Performance awards typically vest in one aggregate installment following the
ultimate  determination  date.    Performance  awards  are  typically  subject  to  a  three-year  measurement  period  during  which  the
number of shares to be issued remains uncertain until the end of the performance period, at which time the awarded number of
shares to be issued is determined.

Service awards

Restricted share units—A restricted share unit is a notional unit that is equal to one share but has no voting rights
until  the  underlying  share  is  issued.   The  following  table  summarizes  unvested  activity  during  the  year  ended  December  31,
2021 for service-based units granted under our incentive plan:

Unvested at January 1, 2021

Granted
Vested
Forfeited

Unvested at December 31, 2021

Number
of
units

Weighted-average  
grant-date fair value  
per unit

8,902,970 $
6,148,361
(4,368,749)
(19,717)
10,662,865 $

3.14  
3.56
3.75
6.24
3.13

In  the  year  ended  December  31,  2021,  the  vested  service-based  units  had  an  aggregate  grant-date  fair  value  of
$16 million.  During the years ended December 31, 2020 and 2019, we granted 7,093,421 and 3,044,494 service-based units,
respectively, with a per unit weighted-average grant-date fair value of $1.41 and $8.33, respectively.  During the years ended
December 31, 2020 and 2019, we had 2,817,155 and 2,224,030 service-based units, respectively, that vested with an aggregate
grant-date fair value of $24 million and $23 million, respectively.

Stock options—The  following  table  summarizes  activity  during  the  year  ended  December  31,  2021  for  vested  and

unvested service-based stock options outstanding under our incentive plan:

Outstanding at January 1, 2021

Forfeited
Expired

Outstanding at December 31, 2021

Number
of shares
     under option     

Weighted-average
exercise price
per share

4,385,147 $
(74,728)
(47,145)
4,263,274 $

12.31
19.21
78.76
11.45

Vested and exercisable at December 31, 2021

3,780,586 $

11.85

Weighted-average
remaining

Aggregate

contractual term intrinsic value  

(years)

6.62 $

(in millions)
—

5.70 $

5.52 $

—

—

In the years ended December 31, 2021, 2020 and 2019, the vested stock options had an aggregate grant-date fair value
of  $9  million,  $12  million  and  $10  million,  respectively.   At  December  31,  2021  and  2020,  there  were  outstanding  unvested
stock options to purchase 482,688 and 1,355,448 shares, respectively.  During the year ended December 31, 2019, we granted
stock options to purchase 1,594,528 shares with a per option weighted-average grant-date fair value of $8.35.

Performance awards

Restricted  share  units—We  grant  performance  awards  in  the  form  of  restricted  share  units  that  can  be  earned
depending on the achievement of market factors and performance targets.  The number of shares ultimately earned per unit is
quantified upon completion of

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the specified period at the ultimate determination date.  The following table summarizes unvested activity during the year ended
December 31, 2021 for performance-based units under our incentive plan:

Unvested at January 1, 2021

Granted
Vested
Forfeited

Unvested at December 31, 2021

Number
of
units

Weighted-average  
grant-date fair value  
per unit

3,560,884 $
3,025,512
(1,030,424)
(166,582)
5,389,390 $

4.40
3.70
10.77
10.79
2.59

In each of the years ended December 31, 2021, 2020 and 2019, the vested performance-based units had an aggregate
grant-date  fair  value  of  $11  million.    During  the  years  ended  December  31,  2020  and  2019,  we  granted  2,530,460  and
1,067,316 performance-based units, respectively, with a per unit weighted-average grant-date fair value of $1.80 and $10.77,
respectively.

NOTE 16—SUPPLEMENTAL BALANCE SHEET INFORMATION

Other current liabilities were comprised of the following (in millions):

Other current liabilities
Accrued employee benefits and payroll-related liabilities
Accrued interest
Accrued taxes, other than income
Finance lease liability
Operating lease liabilities
Deferred revenues
Contingent liabilities
Other

Total other current liabilities

Other long-term liabilities were comprised of the following (in millions):

Other long-term liabilities
Postemployment benefit plan obligations
Finance lease liability
Operating lease liabilities
Income taxes payable
Deferred revenues
Other

Total other long-term liabilities

December 31, 

2021

2020

178
121
52
40
8
83
60
3
545

$

$

224
128
66
37
8
133
60
3
659

December 31, 

2021

2020

128
366
109
157
265
43
1,068

$

$

272
407
114
202
323
48
1,366

  $

  $

  $

  $

NOTE 17—SUPPLEMENTAL CASH FLOW INFORMATION

The reconciling adjustments of our net cash provided by operating activities that were attributable to the net change in

other operating assets and liabilities were as follows (in millions):

Years ended December 31, 
2020

2021

2019

Changes in other operating assets and liabilities
Decrease in accounts receivable
Increase in other assets
Decrease in accounts payable and other current liabilities
Increase (decrease) in other long-term liabilities
Change in income taxes receivable / payable, net
Change in receivables from / payables to affiliates, net

- 71 -

  $

  $

137
(13)
(52)
(3)
(17)
(15)
37

$

$

$

67
(113)
(254)
2
(69)
14
(353) $

87
(30)
(21)
(34)
(303)
(10)
(311)

    
    
 
 
    
    
 
 
    
    
 
 
    
    
    
 
Table of Contents

TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

Additional cash flow information was as follows (in millions):

Years ended December 31, 
2020

2019

2021

Certain cash operating activities
Cash payments for interest
Cash payments for income taxes

Non-cash investing and financing activities
Capital additions, accrued at end of period
Issuance of debt in exchange transactions
Equity component of exchangeable debt

  $

$

(a)
(b)
(c)

$

$

429
57

28
294
—

$

$

593
70

15
925
46

648
121

48
—
—

(a) Additions to property and equipment for which we had accrued a corresponding liability in accounts payable at

(b)

(c)

the end of the period.  See Note 7—Long-Lived Assets.
In the year ended December 31, 2021, in connection with the 2021 Private Exchange, we issued $294 million
aggregate  principal  amount  of  the  4.00%  Senior  Guaranteed  Exchangeable  Bonds.    In  the  year  ended
December  31,  2020,  in  connection  with  the  2020  Exchange  Transactions,  we  issued  $687  million  and
$238  million  aggregate  principal  amount  of  the  11.50%  Senior  Guaranteed  Notes  and  the  2.50%  Senior
Guaranteed Exchangeable Bonds, respectively.  See Note 9—Debt.
In  connection  with  the  issuance  of  the  2.50%  Senior  Guaranteed  Exchangeable  Bonds,  we  recorded  the
conversion feature, measured at its estimated fair value, to additional paid-in capital.  See Note 9—Debt.

NOTE 18—FINANCIAL INSTRUMENTS

Overview—The carrying amounts and fair values of our financial instruments were as follows (in millions):

Cash and cash equivalents
Restricted cash and cash equivalents
Long-term loans receivable from unconsolidated affiliates
Total debt

Fair
value

December 31, 2021
Carrying
     amount
976
  $
436
36
7,170

976
436
33
5,661

$

December 31, 2020  
Carrying
     amount
$ 1,154
406
2
7,807

Fair
value
$ 1,154
406
2
4,820

Cash  and  cash  equivalents—Our  cash  and  cash  equivalents  are  primarily  invested  in  demand  deposits,  short-term
time deposits and money market funds.  The carrying amount of our cash and cash equivalents represents the historical cost,
plus accrued interest, which approximates fair value because of the short maturities of the instruments.

Restricted cash and cash equivalents—Our restricted cash and cash equivalents, which are subject to restrictions due
to collateral requirements, legislation, regulation or court order, are primarily invested in demand deposits and money market
funds.    The  carrying  amount  of  our  restricted  cash  and  cash  equivalents  represents  the  historical  cost,  plus  accrued  interest,
which approximates fair value because of the short maturities of the instruments.

Long-term loans receivable from unconsolidated affiliates—The carrying amount of our long-term loans receivable
from unconsolidated affiliates, recorded in other assets, represents the principal amount of the cash investment.  We estimated
the  fair  value  of  our  long-term  loans  receivable  from  unconsolidated  affiliates  using  significant  unobservable  inputs,
representative of Level 3 fair value measurements, including the terms and credit spreads for the instruments.

Total debt—The carrying amount of our total debt represents the principal amount, contractual interest payments of
previously restructured debt and unamortized discounts, premiums and issue costs.  The carrying amount and fair value of our
total debt includes amounts related to certain exchangeable debt instruments (see Note 9—Debt).  We estimated the fair value of
our total debt using significant other observable inputs, representative of Level 2 fair value measurements, including the terms
and  credit  spreads  for  the  instruments  and,  with  respect  to  the  exchangeable  debt  instruments,  the  expected  volatility  of  the
market price for our shares.

NOTE 19—RISK CONCENTRATION

Interest rate risk—We are exposed to the interest rate risk related to our fixed-rate debt when we refinance maturing
debt with new debt or when we early retire debt in open market repurchases, exchanges or other market transactions.  We are
also  exposed  to  interest  rate  risk  related  to  our  restricted  and  unrestricted  cash  equivalents,  as  the  interest  income  earned  on
these investments is based on variable or short-term interest rates, which change with market interest rates.

Currency  exchange  rate  risk—We  are  exposed  to  currency  exchange  rate  risk  primarily  related  to  employee
compensation costs and purchasing costs that are denominated in currencies other than our functional currency, the U.S. dollar.
 We use a variety of techniques to minimize the exposure to currency exchange rate risk, including the structuring of customer
contract payment terms and occasional use of forward exchange contracts.  Our primary tool to manage currency exchange rate
risk involves structuring customer contracts to provide

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Table of Contents

TRANSOCEAN LTD. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—continued

for payment in both U.S. dollars and local currency.  The payment portion denominated in local currency is based on anticipated
local currency requirements over the contract term.  Due to various factors, including customer acceptance, local banking laws,
national content requirements, other statutory requirements, local currency convertibility, local inflation and revenue efficiency,
actual local currency needs may vary from those realized in the customer contracts, resulting in partial exposure to currency
exchange rate risk.  The currency exchange effect resulting from our international operations generally has not had a material
impact on our operating results.

Credit risk—We are exposed to concentrations of credit risk primarily related to our restricted and unrestricted cash
and  cash  equivalents  and  customer  receivables,  both  current  and  long-term.    We  generally  maintain  our  restricted  and
unrestricted  cash  and  cash  equivalents  in  time  deposits  at  commercial  banks  with  high  credit  ratings  or  mutual  funds,  which
invest exclusively in high-quality money market instruments, and we limit the amount of exposure to any one institution and do
not believe we are exposed to any significant credit risk.  Regarding our customer receivables, which are dispersed in various
countries,  we  earn  our  revenues  by  providing  our  drilling  services  to  integrated  energy  companies,  government-owned  or
government-controlled energy companies and other independent energy companies.  We establish an allowance for credit losses
by  applying  an  expected  loss  rate  based  on  current  and  forecasted  future  and  historical  experience.    Although  we  have
encountered only isolated credit concerns related to independent energy companies, we occasionally require collateral or other
security to support customer receivables.  In certain instances, when we determine that collection is not reasonably assured, we
may occasionally offer extended payment terms and recognize revenues associated with the contract on a cash basis.

Labor agreements—At December 31, 2021, we had a global workforce of approximately 5,530 individuals, including
approximately 530 contractors.  Approximately 42 percent of our total workforce, working primarily in Norway, Brazil and the
U.K., are represented by, and some of our contracted labor work is subject to, collective bargaining agreements, substantially all
of which are subject to annual salary negotiation.  Negotiations over annual salary or other labor matters could result in higher
personnel  or  other  costs  or  increased  operational  restrictions  or  disruptions.   The  outcome  of  any  such  negotiation  generally
affects the market for all offshore employees, not only union members.  A failure to reach an agreement on certain key issues
could result in strikes, lockouts or other work stoppages.

NOTE 20—SUBSEQUENT EVENT

Debt exchange litigation and purported notice of default—On February 1, 2022, the U.S. Court of Appeals for the
Second Circuit dismissed as moot the appeal filed by funds managed by, or affiliated with, Whitebox following the ruling by the
Trial Court on December 17, 2020, which among other matters, granted our motion for summary judgment in connection with
the previously disclosed lawsuit filed against us in September 2020 by Whitebox.

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Table of Contents

ITEM 9. CHANGES  IN  AND  DISAGREEMENTS  WITH  ACCOUNTANTS  ON  ACCOUNTING  AND

FINANCIAL DISCLOSURE

We  have  not  had  a  change  in  or  disagreement  with  our  accountants  within  24  months  prior  to  the  date  of  our  most

recent financial statements or in any period subsequent to such date.

ITEM 9A.CONTROLS AND PROCEDURES

Disclosure  controls  and  procedures—Our  disclosure  controls  and  procedures  are  designed  to  provide  reasonable
assurance that information required to be disclosed in our reports filed or submitted under the Exchange Act is (1) accumulated
and communicated to our management, including our Chief Executive Officer, who is our principal executive officer, and our
Chief  Financial  Officer,  who  is  our  principal  financial  officer,  to  allow  timely  decisions  regarding  required  disclosure  and
(2)  recorded,  processed,  summarized  and  reported  within  the  time  periods  specified  in  the  U.S.  Securities  and  Exchange
Commission’s rules and forms.  Under the supervision and with the participation of management, including our Chief Executive
Officer and Chief Financial Officer, we performed an evaluation of the effectiveness of our disclosure controls and procedures
as of the end of the period covered by this report.  Based on that evaluation, our Chief Executive Officer and Chief Financial
Officer concluded that our disclosure controls and procedures were effective as of December 31, 2021.

Internal control over financial reporting—There has been no change to our internal control over financial reporting
during the quarter ended December 31, 2021 that has materially affected or is reasonably likely to materially affect our internal
control  over  financial  reporting.    See  “Management’s  Report  on  Internal  Control  Over  Financial  Reporting”  and  “Report  of
Independent Registered Public Accounting Firm,” included in Item 8 of this annual report.

ITEM 9B.OTHER INFORMATION

None.

ITEM 9C.DISCLOSURE REGARDING FOREIGN JURISDICTIONS THAT PREVENT INSPECTIONS

Not applicable.

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Table of Contents

PART III

ITEM 10.DIRECTORS, EXECUTIVE OFFICERS AND CORPORATE GOVERNANCE

ITEM 11.EXECUTIVE COMPENSATION

ITEM 12.SECURITY  OWNERSHIP  OF  CERTAIN  BENEFICIAL  OWNERS  AND  MANAGEMENT  AND

RELATED SHAREHOLDER MATTERS

ITEM 13.CERTAIN 

RELATIONSHIPS, 

RELATED 

TRANSACTIONS, 

AND 

DIRECTOR

INDEPENDENCE

ITEM 14.PRINCIPAL ACCOUNTANT FEES AND SERVICES

The information required by Items 10, 11, 12, 13 and 14 is incorporated herein by reference to our definitive proxy
statement  for  our  2022  annual  general  meeting  of  shareholders,  which  will  be  filed  with  the  U.S.  Securities  and  Exchange
Commission pursuant to Regulation 14A under the Securities Exchange Act of 1934 within 120 days of December 31, 2021.
 Certain information with respect to our executive officers is set forth at the end of Part I of this annual report under the caption
“Information About our Executive Officers.”

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Table of Contents

PART IV

ITEM 15.EXHIBITS AND FINANCIAL STATEMENT SCHEDULES

INDEX TO FINANCIAL STATEMENTS, FINANCIAL STATEMENT SCHEDULES AND

(A)
EXHIBITS

(1) Index to Financial Statements

Included in Part II of this report:

Management’s Report on Internal Control Over Financial Reporting

Reports of Independent Registered Public Accounting Firm (PCAOB ID 00042)
Consolidated Statements of Operations
Consolidated Statements of Comprehensive Loss
Consolidated Balance Sheets
Consolidated Statements of Equity
Consolidated Statements of Cash Flows
Notes to Consolidated Financial Statements

Page

41
42
45
46
47
48
49
50

Financial statements of unconsolidated subsidiaries are not presented herein because such subsidiaries do not meet the

significance test.

(2) Financial Statement Schedules

Transocean Ltd. and Subsidiaries
Schedule II - Valuation and Qualifying Accounts
(In millions)

Year ended December 31, 2019
Reserves and allowances deducted from asset accounts:

Allowance for excess materials and supplies
Valuation allowance on deferred tax assets

Year ended December 31, 2020
Reserves and allowances deducted from asset accounts:

Allowance for credit losses
Allowance for excess materials and supplies
Valuation allowance on deferred tax assets

Year ended December 31, 2021
Reserves and allowances deducted from asset accounts:

Allowance for credit losses
Allowance for excess materials and supplies
Valuation allowance on deferred tax assets

Additions

Balance at
beginning of
period

Charge to cost
and
expenses

Charge to
other
accounts
-describe     

Deductions
-describe     

Balance at
end of
period

$

134
681

3
37

—
—

10 (a)  $
2 (b)

127
716

  $

—  
127
716

—  
25
(31)

2 (c)
—
—

— $
9 (a)  
—

2
143
685

$

2
143
685

—
43
1,167

—
—
—

— $
3 (a)  
32 (b)

2
183
1,820

(a) Amount related to materials and supplies on rigs and related assets sold or classified as held for sale.

(b) Amount related to adjustments to other deferred tax assets with valuation allowances.

(c) Amount related to an adjustment to the allowance for credit losses with a corresponding entry to accumulated deficit associated with our
adoption of the accounting standards update that requires an entity to estimate an expected lifetime credit loss on financial assets ranging
from short-term trade accounts receivable to long-term financings without retrospective application.

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Table of Contents

(3) Exhibits

The following exhibits are filed or furnished herewith, as indicated, or incorporated by reference to the location indicated:

NUMBER DESCRIPTION

1.1

2.1

3.1

3.2

4.1

4.2

4.3

4.4

4.5

4.6

4.7

4.8

4.9

4.10

4.11

4.12

4.13

4.14

Equity  Distribution  Agreement,  dated  as  of  June  14,  2021,  by  and
between Transocean Ltd. and Jefferies LLC

Agreement  and  Plan  of  Merger,  dated  September  3,  2018,  by  and
among  Transocean  Ltd.,  Transocean  Oceanus  Holdings  Limited,
Transocean Oceanus Limited and Ocean Rig UDW Inc.
Articles of Association of Transocean Ltd.

Organizational  Regulations  of  Transocean  Ltd.,  amended,  effective
as of April 7, 2021

Description  of  Securities  Registered  Pursuant  to  Section  12  of  the
Securities Exchange Act of 1934
Indenture  dated  as  of  February  26,  2021  by  and  among
Transocean  Inc.,  the  guarantors  and  Wells  Fargo  Bank,  National
Association
Credit Agreement dated June 22, 2018, among Transocean Inc., the
lenders  parties  thereto  and  Citibank,  N.A.,  as  administrative  agent
and collateral agent.
to  Credit
Increase  of  Commitments  and  First  Amendment 
Agreement,  dated  May  13,  2019,  among  Transocean  Inc.,  the
lenders  and  issuing  banks  parties  thereto,  Citibank,  N.A.,  as
administrative  agent,  and  for  the  limited  purposes  set  forth  therein,
Transocean Ltd. and certain of its subsidiaries
Increase of Commitments, Second Amendment to Credit Agreement
and  First  Amendment  to  Guaranties,  dated  July  15,  2019,  among
Transocean  Inc.,  the  lenders  and  issuing  banks  parties  thereto,
Citibank, N.A., as administrative agent, and for the limited purposes
set forth therein, Transocean Ltd. and certain of its subsidiaries
Curative  Agreement,  dated  September  24,  2019,  between
Transocean Inc. and Citibank, N.A., as administrative agent for the
lenders  under  the  Credit  Agreement  dated  June  22,  2018,  as
amended
to  Credit
Increase  of  Commitments  and  Third  Amendment 
Agreement,  dated  December  23,  2019,  among  Transocean  Inc.,  the
lenders  and  issuing  banks  parties  thereto,  Citibank,  N.A.,  as
administrative  agent,  and  for  the  limited  purposes  set  forth  therein,
Transocean Ltd. and certain of its subsidiaries
Indenture, dated July 13, 2018, by and among Transocean Guardian
Limited, 
the  Guarantors  and  Wells  Fargo  Bank,  National
Association
Indenture,  dated  July  20,  2018,  by  and  among  Transocean
Pontus  Limited, 
the  Guarantors  and  Wells  Fargo  Bank,
National Association.
First  Supplemental  Indenture,  dated  April  15,  2019,  by  and  among
Transocean  Pontus  Limited,  Wells  Fargo  Bank,  National
Association,  as  trustee  and  collateral  agent,  and  the  Note  Parties,
supplementing the Indenture dated as of July 20, 2018
Indenture  dated  as  of  April  15,  1997  between  Transocean
Offshore  Inc.  and  Texas  Commerce  Bank  National Association,  as
trustee
First  Supplemental  Indenture  dated  as  of  April  15,  1997  between
and  Texas  Commerce  Bank
Transocean  Offshore 
National Association, as trustee, supplementing the Indenture dated
as of April 15, 1997
Second Supplemental Indenture dated as of May 14, 1999 between
Transocean  Offshore  (Texas)  Inc.,  Transocean  Offshore  Inc.  and
Chase Bank of Texas, National Association, as trustee
Fifth  Supplemental  Indenture,  dated  as  of  December  18,  2008,
among Transocean Ltd., Transocean Inc. and The Bank of New York
Mellon Trust Company, N.A., as trustee

Inc. 

- 77 -

LOCATION
Exhibit  1.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
June 15, 2021
Exhibit  2.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
September 4, 2018
Exhibit  3.1  to  Transocean  Ltd.’s  Quarterly  Report  on
Form  10-Q  (Commission  File  No.  001-38373)  for  the
quarter  ended  September  30,  2021  filed  on  November  2,
2021
Exhibit  3.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  000-53533)  filed  on
April 7, 2021
Filed herewith

Exhibit  4.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
February 26, 2021
Exhibit  4.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
June 27, 2018
Exhibit  10.1  to  Transocean  Ltd.’  s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
May 13, 2019

Exhibit  10.1  to  Transocean  Ltd.’  s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
July 15, 2019

Exhibit  10.2  to  Transocean  Ltd.’  s  Quarterly  Report  on
Form  10-Q  (Commission  File  No.  001-38373)  for  the
quarter ended September 30, 2019

Exhibit  4.6  to  Transocean  Ltd.’s  Annual  Report  on
Form  10-K  (Commission  File  No.  001-38373)  filed  on
February 18, 2020

Exhibit  4.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
July 17, 2018
Exhibit  4.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
July 24, 2018
Exhibit  4.4  to  Transocean  Ltd.’s  Quarterly  Report  on
Form  10-Q  (Commission  File  No.  001-38373)  for  the
quarter ended March 31, 2019

Exhibit 4.1 to Transocean Offshore Inc.’s Current Report
on  Form  8-K  (Commission  File  No.  001-07746)  filed  on
April 30, 1997
Exhibit 4.2 to Transocean Offshore Inc.’s Current Report
on  Form  8-K  (Commission  File  No.  001-07746)  filed  on
April 30, 1997

Exhibit  4.5  to  Transocean  Offshore  Inc.’s  Post-Effective
Amendment No. 1 to Registration Statement on Form S-3
(Registration No. 333-59001-99) filed on June 29, 1999
Exhibit  4.4  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  333-75899)  filed  on
December 19, 2008

Table of Contents

NUMBER DESCRIPTION

4.15

Form of 7.45% Notes due April 15, 2027

4.16

Form of 8.00% Debentures due April 15, 2027

4.17

4.18

4.19

4.20

4.21

4.22

4.23

Officers’ Certificate establishing the terms of the 7.50% Notes due
April 15, 2031

Officers’ Certificate establishing the terms of the 7.375% Notes due
April 15, 2018

Indenture  dated  as  of  September  1,  1997,  between  Global
Marine Inc. and Wilmington Trust Company, as Trustee, relating to
Debt Securities of Global Marine Inc.
First  Supplemental  Indenture  dated  as  of  June  23,  2000,  between
Global  Marine  Inc.  and  Wilmington  Trust  Company,  as  Trustee,
relating to Debt Securities of Global Marine Inc.
Second  Supplemental  Indenture  dated  as  of  November  20,  2001,
between  Global  Marine  Inc.  and  Wilmington  Trust  Company,  as
Trustee, relating to Debt Securities of Global Marine Inc.
Third  Supplemental  Indenture,  dated  as  of  July  29,  2019,  among
Global  Marine 
and  Wilmington
Trust  Company,  as  trustee,  relating  to  Debt  Securities  of  Global
Marine Inc.
Form of 7% Note Due 2028

Inc,  Transocean 

Inc. 

4.24

Terms of 7% Notes Due 2028

4.25

4.26

4.27

4.28

4.29

4.30

4.31

4.32

4.33

4.34

Indenture, dated as of December 11, 2007, between Transocean Inc.
and Wells Fargo Bank, National Association

Inc. 

Fargo 

Transocean 

and  Wells 

First  Supplemental  Indenture,  dated  as  of  December  11,  2007,
between 
Bank,
National Association
Third  Supplemental  Indenture,  dated  as  of  December  18,  2008,
among  Transocean  Ltd.,  Transocean  Inc.  and  Wells  Fargo  Bank,
National Association, as trustee
Fourth  Supplemental  Indenture,  dated  as  of  September  21,  2010,
among  Transocean  Ltd.,  Transocean  Inc.  and  Wells  Fargo  Bank,
National Association, as trustee
Fifth Supplemental Indenture, dated as of December 5, 2011, among
Transocean  Ltd.,  Transocean  Inc.  and  Wells  Fargo  Bank,  National
Association, as trustee
Sixth  Supplemental  Indenture,  dated  as  of  September  13,  2012,
among  Transocean  Inc.,  Transocean  Ltd.  and  Wells  Fargo  Bank,
National Association, as trustee
Indenture, dated as of July 21, 2016, by and among Transocean Inc.,
the Guarantors and Wells Fargo Bank, National Association

Indenture, dated as of October 19, 2016, by and among Transocean
Phoenix  2  Limited,  Transocean  Ltd.,  Transocean  Inc.,  Triton
Capital II GmbH and Wells Fargo Bank, National Association
First  Supplemental  Indenture,  dated  April  15,  2019,  by  and  among
Transocean  Phoenix  2  Limited,  Wells  Fargo  Bank,  National
Association,  as  trustee  and  collateral  agent,  and  the  Note  Parties
supplementing the Indenture dated as of October 19, 2016
Indenture,  dated  December  8,  2016,  by  and  among  Transocean
Proteus  Limited,  the  Guarantors  and  Wells  Fargo  Bank,  National
Association

- 78 -

LOCATION
Exhibit 4.3 to Transocean Offshore Inc.’s Current Report
on  Form  8-K  (Commission  File  No.  001-07746)  filed  on
April 30, 1997
Exhibit 4.4 to Transocean Offshore Inc.’s Current Report
on  Form  8-K  (Commission  File  No.  001-07746)  filed  on
April 30, 1997
Exhibit  4.3  to  Transocean  Sedco  Forex  Inc.’s  Current
Report  on  Form  8-K  (Commission  File  No.  333-75899)
filed on April 9, 2001
Exhibit  4.14  to  Transocean  Sedco  Forex  Inc.’s  Annual
Report on Form 10-K (Commission File No. 333-75899)
for the fiscal year ended December 31, 2001
Exhibit 4.1 of Global Marine Inc.’s Registration Statement
on Form S-4 (No. 333-39033) filed on October 30, 1997

Exhibit  4.2  of  Global  Marine  Inc.’s  Quarterly  Report  on
Form  10-Q  (Commission  File  No.  001-05471)  for  the
quarter ended June 30, 2000
Exhibit  4.2 
to  GlobalSantaFe  Corporation’s  Annual
Report on Form 10-K (Commission File No. 001-14634)
for the year ended December 31, 2004
Exhibit  4.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
July 29, 2019

Exhibit  4.2  of  Global  Marine  Inc.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-05471)  filed  on
May 22, 1998
Exhibit  4.1  of  Global  Marine  Inc.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-05471)  filed  on
May 22, 1998
Exhibit  4.36  to  Transocean  Inc.’s  Annual  Report  on
Form 10-K (Commission File No. 333-75899) for the year
ended December 31, 2007
Exhibit  4.37  to  Transocean  Inc.’s  Annual  Report  on
Form 10-K (Commission File No. 333-75899) for the year
ended December 31, 2007
Exhibit  4.3  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  333-75899)  filed  on
December 19, 2008
Exhibit  4.1  to  Transocean  Ltd.’s  Quarterly  Report  on
Form  10-Q  (Commission  File  No.  000-53533)  for  the
quarter ended September 30, 2010
Exhibit  4.3  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  000-53533)  filed  on
December 5, 2011
Exhibit  4.3  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  000-53533)  filed  on
September 13, 2012
Exhibit  4.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  000-53533)  filed  on
July 22, 2016
Exhibit  4.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  000-53533)  filed  on
October 20, 2016
Exhibit  4.2  to  Transocean  Ltd.’s  Quarterly  Report  on
Form  10-Q  (Commission  File  No.  001-38373)  for  the
quarter ended March 31, 2019

Exhibit  4.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  000-53533)  filed  on
December 8, 2016

Table of Contents

NUMBER DESCRIPTION

4.35

4.36

4.37

4.38

4.39

4.40

4.41

4.42

4.43

4.44

4.45

4.46

4.47

4.48

4.49

* 10.1

10.2

10.3

10.4

10.5

Fargo 

Proteus 

Limited,  Wells 

First  Supplemental  Indenture,  dated  April  15,  2019,  by  and  among
Transocean 
Bank,
National Association,  as  trustee  and  collateral  agent,  and  the  Note
Parties, supplementing the Indenture dated as of December 8, 2016
Indenture  dated  as  of  October  17,  2017,  by  and  among
Transocean Inc., the guarantors party thereto and Wells Fargo Bank,
National Association
Indenture,  dated  January  30,  2018,  among  Transocean  Inc.,
Transocean  Ltd.,  as  guarantor,  and  Computershare  Trust
Company  N.A.  and  Computershare  Trust  Company  of  Canada,  as
co-trustees
Form of 0.50% Exchangeable Senior Bonds due 2023

1, 

by 

and 

2019, 

dated  February 

Registration  Rights  Agreement,  dated  as  of  January  30,  2018,
among  Transocean  Ltd.,  Transocean  Inc.,  and  the  security  holders
named therein
Indenture,  dated  October  25,  2018,  among  Transocean  Inc.,  the
guarantors  party 
thereto  and  Wells  Fargo  Bank,  National
Association, as trustee
Indenture, 
among
Transocean  Poseidon  Limited,  the  Guarantors  and  Wells  Fargo
Bank, National Association, as trustee and collateral agent
Indenture,  dated  May  24,  2019,  by  and  among  Transocean
Sentry  Limited,  the  Guarantors  and  Wells  Fargo  Bank,  National
Association, as trustee and collateral agent
Indenture, dated January 17, 2020, by and among Transocean Inc.,
the  guarantors  party  thereto  and  Wells  Fargo  Bank,  National
Association
Indenture,  dated  as  of  August  14,  2020,  by  and  among
Transocean Inc., the guarantors party thereto and Wells Fargo Bank,
National Association
Amendment 
to  Registration  Rights  Agreement,  dated  as  of
August  14,  2020,  by  and  among  Transocean  Ltd.,  Transocean  Inc.
and Perestroika (Cyprus) Ltd.
Indenture,  dated  as  of  September  11,  2020,  by  and  among
Transocean Inc., the guarantors party thereto and Wells Fargo Bank,
National Association
Supplemental  Indenture,  dated  November  30,  2020,  by  and  among
Transocean  Inc.,  Transocean  Ltd.,  certain  of  Transocean  Inc.’s
subsidiaries, and Wells Fargo Bank, National Association, as trustee,
supplementing the Indenture dated as of September 11, 2020.
Supplemental  Indenture,  dated  November  30,  2020,  by  and  among
Transocean  Inc.,  Transocean  Ltd.,  certain  of  Transocean  Inc.’s
subsidiaries, and Wells Fargo Bank, National Association, as trustee,
supplementing the Indenture dated as of August 14, 2020.
Fourth Amendment to Credit Agreement, dated November 30, 2020,
among  Transocean  Inc.,  the  lenders  and  issuing  banks  parties
thereto, Citibank, N.A., as administrative agent, and for the limited
purposes set forth therein, certain of Transocean Inc.’s subsidiaries.
Amended and Restated 2015 Transocean Ltd. Long-Term Incentive
Plan

Shipyard Credit Agreement for Deepwater Atlas, dated as of June 5,
2021,  by  and  between  Jurong  Shipyard  Pte.  Ltd.  and  Transocean
Offshore Deepwater Holdings Limited
Shipyard Credit Agreement for Deepwater Titan, dated as of June 5,
2021,  by  and  between  Jurong  Shipyard  Pte.  Ltd.  and  Transocean
Offshore Deepwater Holdings Limited
Form  of  Voting  and  Support  Agreement,  by  and  among
Transocean Ltd. and certain shareholders of Ocean Rig UDW Inc.

Form of Voting and Support Agreement, by and among Ocean Rig
UDW Inc. and certain shareholders of Transocean Ltd.

* 10.6

Long-Term  Incentive  Plan  of  Transocean  Ltd.  (as  amended  and
restated as of February 12, 2009)

- 79 -

LOCATION
Exhibit  4.3  to  Transocean  Ltd.’s  Quarterly  Report  on
Form  10-Q  (Commission  File  No.  001-38373)  for  the
quarter ended March 31, 2019

Exhibit  4.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  000-53533)  filed  on
October 17, 2017
Exhibit  4.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
January 30, 2018

Exhibit  A  of  Exhibit  4.1  to  Transocean  Ltd.’s  Current
Report  on  Form  8-K  (Commission  File  No.  001-38373)
filed on January 30, 2018
Exhibit  4.3  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
January 30, 2018
Exhibit  4.32  to  Transocean  Ltd.’s  Annual  Report  on
Form  10-K  (Commission  File  No.  001-38373)  filed  on
February 19, 2019
Exhibit  4.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
February 1, 2019
Exhibit  4.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
May 29, 2019
Exhibit  4.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
January 17, 2020
Exhibit  4.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
August 14, 2020
Exhibit  4.2  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
August 14, 2020
Exhibit  4.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
September 11, 2020
Exhibit  4.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
December 1, 2020

Exhibit  4.2  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
December 1, 2020

Exhibit  10.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
December 1, 2020.

Exhibit  10.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
June 1, 2021
Exhibit  10.2  to  Transocean  Ltd.’s  Quarterly  Report  on
Form  10-Q  (Commission  File  No.  001-38373)  for  the
quarter ended June 30, 2021 filed on August 3, 2021
Exhibit  10.3  to  Transocean  Ltd.’s  Quarterly  Report  on
Form  10-Q  (Commission  File  No.  001-38373)  for  the
quarter ended June 30, 2021 filed on August 3, 2021
Exhibit  10.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
September 4, 2018
Exhibit  10.2  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  001-38373)  filed  on
September 4, 2018.
Exhibit  10.5  to  Transocean  Ltd.’s  Annual  Report  on
Form 10-K (Commission File No. 000-53533) for the year
ended December 31, 2008

Table of Contents

NUMBER DESCRIPTION
* 10.7

First  Amendment  to  Long-Term  Incentive  Plan  of  Transocean  Ltd.
(as amended and restated as of February 12, 2009)

* 10.8

Deferred  Compensation  Plan  of  Transocean  Offshore  Inc.,  as
amended and restated effective January 1, 2000

* 10.9

effective 

GlobalSantaFe Corporation Key Employee Deferred Compensation
Plan 
to
GlobalSantaFe Corporation Key Employee Deferred Compensation
Plan effective November 20, 2001

and  Amendment 

January 

2001 

1, 

* 10.10 Amendment to Transocean Inc. Deferred Compensation Plan

* 10.11

Form  of  2004  Performance-Based  Nonqualified  Share  Option
Award Letter

* 10.12

Form of 2004 Director Deferred Unit Award

* 10.13

Form of 2008 Director Deferred Unit Award

* 10.14

Form of 2009 Director Deferred Unit Award

* 10.15

Terms and Conditions of 2013 Director Deferred Unit Award

* 10.16

Terms and Conditions of 2014 Director Deferred Unit Award

LOCATION
Exhibit  10.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  000-53533)  filed  on
May 22, 2013
Exhibit  10.10  to  Transocean  Sedco  Forex  Inc.’s  Annual
Report on Form 10-K (Commission File No. 333-75899)
for the year ended December 31, 1999
Exhibit  10.33  to  the  GlobalSantaFe  Corporation  Annual
Report on Form 10-K (Commission File No. 001-14634)
for the year ended December 31, 2004

Exhibit  10.1  to  Transocean  Inc.’s  Current  Report  on
Form  8-K  (Commission  File  No.  333-75899)  filed  on
December 29, 2005
Exhibit  10.2  to  Transocean  Inc.’s  Current  Report  on
Form  8-K  (Commission  File  No.  333-75899)  filed  on
February 15, 2005
Exhibit  10.4  to  Transocean  Inc.’s  Current  Report  on
Form  8-K  (Commission  File  No.  333-75899)  filed  on
February 15, 2005
Exhibit  10.20  to  Transocean  Ltd.’s  Annual  Report  on
Form 10-K (Commission File No. 000-53533) for the year
ended December 31, 2008
Exhibit  10.19  to  Transocean  Ltd.’s  Annual  Report  on
Form 10-K (Commission File No. 000-53533) for the year
ended December 31, 2009
Exhibit  10.14  to  Transocean  Ltd.’s  Annual  Report  on
Form 10-K (Commission File No. 000-53533) for the year
ended December 31, 2015
Exhibit  10.15  to  Transocean  Ltd.’s  Annual  Report  on
Form 10-K (Commission File No. 000-53533) for the year
ended December 31, 2015

* 10.17

* 10.18

* 10.19

10.20

* 10.21

* 10.22

* 10.23

10.24

Terms and Conditions of 2014 Executive Equity Award

Terms and Conditions of 2015 Executive Equity Award

Terms and Conditions of the July 2008 Nonqualified Share Option
Award

Terms and Conditions of 2015 Director Restricted Share Unit Award Exhibit  10.16  to  Transocean  Ltd.’s  Annual  Report  on
Form 10-K (Commission File No. 000-53533) for the year
ended December 31, 2015
Exhibit  10.19  to  Transocean  Ltd.’s  Annual  Report  on
Form 10-K (Commission File No. 000-53533) for the year
ended December 31, 2015
Exhibit  10.20  to  Transocean  Ltd.’s  Annual  Report  on
Form 10-K (Commission File No. 000-53533) for the year
ended December 31, 2015
Exhibit  10.2  to  Transocean  Inc.’s  Annual  Report  on
Form  10-Q  (Commission  File  No.  333-75899)  for  the
quarter ended June 30, 2008
Exhibit  10.30  to  Transocean  Ltd.’s  Annual  Report  on
Form 10-K (Commission File No. 000-53533) for the year
ended December 31, 2008
Exhibit  10.28  to  Transocean  Ltd.’s  Annual  Report  on
Form 10-K (Commission File No. 000-53533) for the year
ended December 31, 2011
Exhibit  10.30  to  Transocean  Ltd.’s  Annual  Report  on
Form 10-K (Commission File No. 000-53533) for the year
ended December 31, 2012
Exhibit  10.1  to  Transocean  Inc.’s  Current  Report  on
Form  8-K  (Commission  File  No.  333-75899)  filed  on
December 3, 2007

Form  of  Novation  Agreement  dated  as  of  November  27,  2007  by
and  among  GlobalSantaFe  Corporation,  Transocean  Offshore
Deepwater Drilling Inc. and certain executives

Terms  and  Conditions  of  the  February  2012  Long  Term  Incentive
Plan Award

Terms  and  Conditions  of  the  February  2009  Nonqualified  Share
Option Award

Transocean Ltd. Incentive Recoupment Policy

* 10.25 Global Marine Inc. 1990 Non-Employee Director Stock Option Plan Exhibit  10.18  of  Global  Marine  Inc.’s  Annual  Report  on
Form 10-K (Commission File No. 001-05471) for the year
ended December 31, 1991
Exhibit 10.1 of Global Marine Inc.’s Quarterly Report on
Form  10-Q  (Commission  File  No.  001-05471)  for  the
quarter ended June 30, 1995

First  Amendment  to  Global  Marine  Inc.  1990  Non-Employee
Director Stock Option Plan

* 10.26

- 80 -

Table of Contents

NUMBER DESCRIPTION
* 10.27

Second  Amendment  to  Global  Marine  Inc.  1990  Non-Employee
Director Stock Option Plan

* 10.28

1997 Long-Term Incentive Plan

* 10.29 Amendment to 1997 Long Term Incentive Compensation Plan

* 10.30 Amendment to 1997 Long Term Incentive Plan, dated December 1,

1999

* 10.31 GlobalSantaFe Corporation 1998 Stock Option and Incentive Plan

* 10.32

First Amendment to GlobalSantaFe Corporation 1998 Stock Option
and Incentive Plan

* 10.33 GlobalSantaFe  Corporation  2001  Non-Employee  Director  Stock

Option and Incentive Plan

* 10.34 GlobalSantaFe Corporation 2001 Long-Term Incentive Plan

* 10.35 GlobalSantaFe  2003  Long-Term  Incentive  Plan  (as  Amended  and

Restated Effective June 7, 2005)

* 10.36

Transocean  Ltd.  Pension  Equalization  Plan,  as  amended  and
restated, effective January 1, 2009

* 10.37

Transocean U.S. Supplemental Retirement Benefit Plan, as amended
and restated, effective as of November 27, 2007

* 10.38 GlobalSantaFe  Corporation  Supplemental  Executive  Retirement

Plan

* 10.39

Transocean  U.S.  Supplemental  Savings  Plan,  as  amended  and
restated, effective as of January 1, 2009

10.40

Indemnification  Agreement  entered 
Form  of 
Transocean Ltd. and each of its Directors and Executive Officers

into  between

* 10.41

Form of Assignment Memorandum for Executive Officers

10.42 Drilling  Contract  between  Vastar  Resources,  Inc.  and  R&B  Falcon
to

respect 

Drilling  Co.  dated  December  9,  1998  with 
Deepwater Horizon, as amended
Executive Severance Benefit Policy

* 10.43

10.44

Term  Sheet  Agreement  for  a  Transocean  and  PSC/DHEPDS
Settlement,  dated  May  20,  2015, 
among  Triton  Asset
Leasing  GmbH,  Transocean  Deepwater  Inc.,  Transocean  Offshore
Deepwater  Drilling  Inc.,  Transocean  Holdings  LLC,  the  Plaintiffs
Steering  Committee  in  MDL  2179,  and  the  Deepwater  Horizon
Economic and Property Damages Settlement Class

LOCATION
Exhibit  10.37  of  Global  Marine  Inc.’s  Annual  Report  on
Form 10-K (Commission File No. 001-05471) for the year
ended December 31, 1996
GlobalSantaFe  Corporation’s  Registration  Statement  on
Form S-8 (No. 333-7070) filed June 13, 1997
Exhibit  10.25  of  GlobalSantaFe  Corporation’s  Annual
Report  on  Form  20-F  (Commission  File  No.  001-14634)
for the year ended December 31, 1998
Exhibit  10.33  of  GlobalSantaFe  Corporation’s  Annual
Report  on  Form  20-F  (Commission  File  No.  001-14634)
for the year ended December 31, 1999
Exhibit 10.1 of Global Marine Inc.’s Quarterly Report on
Form  10-Q  (Commission  File  No.  001-05471)  for  the
quarter ended March 31, 1998
Exhibit 10.2 of Global Marine Inc.’s Quarterly Report on
Form  10-Q  (Commission  File  No.  001-05471)  for  the
quarter ended June 30, 2000
Exhibit  4.8  of  GlobalSantaFe  Corporation’s  Registration
Statement  on  Form  S-8  (No.  333-73878)  filed  on
November 21, 2001
Exhibit A to GlobalSantaFe Corporation’s definitive proxy
statement  (Commission  File  No.  001-14634)  filed  on
March 21, 2001
Exhibit  10.4  to  GlobalSantaFe  Corporation’s  Quarterly
Report on Form 10-Q (Commission File No. 001-14634)
for the quarter ended June 30, 2005
Exhibit  10.41  to  Transocean  Ltd.’s  Annual  Report  on
Form 10-K (Commission File No. 000-53533) for the year
ended December 31, 2008
Exhibit  10.11  to  Transocean  Inc.’s  Current  Report  on
Form  8-K  (Commission  File  No.  333-75899)  filed  on
December 3, 2007
Exhibit  10.1  to  the  GlobalSantaFe  Corporation  Quarterly
Report on Form 10-Q (Commission File No. 001-14634)
for the quarter ended September 30, 2002
Exhibit  10.44  to  Transocean  Ltd.’s  Annual  Report  on
Form 10-K (Commission File No. 000-53533) for the year
ended December 31, 2008
Exhibit  10.1  to  Transocean  Inc.’s  Current  Report  on
Form  8-K  (Commission  File  No.  333-75899)  filed  on
October 10, 2008
Exhibit  10.6  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  000-53533)  filed  on
December 19, 2008
Exhibit  10.1  to  Transocean  Ltd.’s  Quarterly  Report  on
Form  10-Q  (Commission  File  No.  000-53533)  for  the
quarterly period ended June 30, 2010
Exhibit  10.1  to  Transocean  Ltd.’s  Current  Report  on
Form  8-K  (Commission  File  No.  000-53533)  filed  on
February 23, 2012
Exhibit  10.3  to  Transocean  Ltd.’s  Quarterly  Report  on
Form  10-Q  (Commission  File  No.  000-53533)  for  the
quarter ended June 30, 2015

10.45 Confidential  Settlement  Agreement,  Mutual  Releases  and
Agreement  to  Indemnify,  dated  May  20,  2015,  among  Transocean
Offshore  Deepwater  Drilling  Inc.,  Transocean  Deepwater  Inc.,
Transocean  Holdings  LLC,  Triton  Asset  Leasing  GmbH,  BP
Exploration and Production Inc. and BP America Production Co.

Exhibit  10.6  to  Transocean  Ltd.’s  Quarterly  Report  on
Form  10-Q  (Commission  File  No.  000-53533)  for  the
quarter ended June 30, 2015

- 81 -

Table of Contents

NUMBER DESCRIPTION

10.46

* 10.47

Transocean  Punitive  Damages  and  Assigned  Claims  Settlement
Agreement,  dated  May  29,  2015,  among  Transocean  Offshore
Deepwater  Drilling  Inc.,  Transocean  Deepwater  Inc.,  Transocean
Holdings LLC, Triton Asset Leasing GmbH, the Plaintiffs Steering
Committee  in  MDL  2179,  and  the  Deepwater  Horizon  Economic
and Property Damages Settlement Class
Employment  Agreement  with  Jeremy  D.  Thigpen  effective
September 1, 2016

* 10.48

Employment Agreement with Mark L. Mey effective September 1,
2016

* 10.49 Amended and Restated Performance Award and Cash Bonus Plan of

Transocean Ltd.

* 10.50

Terms and Conditions of 2020 Executive Equity Awards

* 10.51

Terms  and  Conditions  of  2020  Director  Restricted  Share  Unit
Award

* 10.52
* 10.53

Terms and Conditions of 2022 Executive Equity Awards

Employment  Agreement  with  Keelan  Adamson 
February 16, 2022

effective

21

23.1

24
31.1

31.2

32.1

32.2

101

104

Subsidiaries of Transocean Ltd.

Consent of Ernst & Young LLP

Powers of Attorney
Certification of Chief Executive Officer pursuant to Section 302 of
the Sarbanes-Oxley Act of 2002
Certification  of  Chief  Financial  Officer  pursuant  to  Section  302  of
the Sarbanes-Oxley Act of 2002
Certification of Chief Executive Officer pursuant to Section 906 of
the Sarbanes-Oxley Act of 2002
Certification  of  Chief  Financial  Officer  pursuant  to  Section  906  of
the Sarbanes-Oxley Act of 2002
Interactive  data  files  pursuant  to  Rule  405  of  Regulation  S-T
formatted in Inline Extensible Business Reporting Language: (i) our
consolidated  balance  sheets  as  of  December  31,  2021  and
December  31,  2020;  (ii)  our  consolidated  statements  of  operations
for  the  years  ended  December  31,  2021,  2020  and  2019;  (iii)  our
consolidated  statements  of  comprehensive  loss  for  the  years  ended
December  31,  2021,  2020  and  2019;  (iv)  our  consolidated
statements of equity for the years ended December 31, 2021, 2020
and  2019;  (v)  our  consolidated  statements  of  cash  flows  for  the
years ended December 31, 2021, 2020 and 2019; and (vi) the notes
to consolidated financial statements
The cover page from our annual report on Form 10-K for the year
ended December 31, 2021, formatted in Inline Extensible Business
Reporting Language

*

Compensatory plan or arrangement

LOCATION
Exhibit  10.7  to  Transocean  Ltd.’s  Quarterly  Report  on
Form  10-Q  (Commission  File  No.  000-53533)  for  the
quarter ended June 30, 2015

Exhibit  10.1  to  Transocean  Ltd.’s  Quarterly  Report  on
Form  10-Q  (Commission  File  No.  000-53533)  for  the
quarter ended September 30, 2016
Exhibit  10.2  to  Transocean  Ltd.’s  Quarterly  Report  on
Form  10-Q  (Commission  File  No.  000-53533)  for  the
quarter ended September 30, 2016
Exhibit  10.48  to  Transocean  Ltd.’s  Annual  Report  on
Form 10-K (Commission File No. 001-38373) for the year
ended December 31, 2020
Exhibit  10.2  to  Transocean  Ltd.’s  Quarterly  Report  on
Form  10-Q  (Commission  File  No.  001-38373)  for  the
quarter ended June 30, 2020
Exhibit  10.3  to  Transocean  Ltd.’s  Quarterly  Report  on
Form  10-Q  (Commission  File  No.  001-38373)  for  the
quarter ended June 30, 2020
Filed Herewith
Exhibit 10.1 to Transocean Ltd.’s Current Report on
Form  8-K  (Commission  File  No.  001-38373)  filed
on February 17, 2022
Filed herewith

Filed herewith

Filed herewith
Filed herewith

Filed herewith

Furnished herewith

Furnished herewith

Filed herewith

Filed herewith

Exhibits  listed  above  as  previously  having  been  filed  with  the  U.S.  Securities  and  Exchange  Commission  are
incorporated herein by reference pursuant to Rule 12b-32 under the Securities Exchange Act of 1934 and made a part hereof
with the same effect as if filed herewith.

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Table of Contents

Certain instruments relating to our long-term debt and our subsidiaries have not been filed as exhibits since the total
amount of securities authorized under any such instrument does not exceed 10 percent of our total assets and our subsidiaries on
a consolidated basis.  We agree to furnish a copy of each such instrument to the SEC upon request.

Certain agreements filed as exhibits to this Report may contain representations and warranties by the parties to such
agreements.  These representations and warranties have been made solely for the benefit of the parties to such agreements and
(1) may be intended not as statements of fact, but rather as a way of allocating the risk to one of the parties if those statements
prove to be inaccurate, (2) may have been qualified by certain disclosures that were made to other parties in connection with the
negotiation  of  such  agreements,  which  disclosures  are  not  reflected  in  such  agreements,  and  (3)  may  apply  standards  of
materiality in a way that is different from what may be viewed as material to investors.

SIGNATURES

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly

caused this report to be signed on its behalf by the undersigned; thereunto duly authorized, on February 23, 2022.

TRANSOCEAN LTD.

By:

  /s/ Mark L. Mey
Mark L. Mey
Executive Vice President and Chief Financial Officer
(Principal Financial Officer)

By:

  /s/ David Tonnel
David Tonnel
Senior Vice President and Chief Accounting Officer
(Principal Accounting Officer)

- 83 -

Table of Contents

Pursuant to the requirements of the Securities Exchange Act of 1934, this report has been signed below by the following
persons on behalf of the registrant in the capacities indicated on February 23, 2022.

Signature

*

Chadwick C. Deaton

/s/ Jeremy D. Thigpen

Jeremy D. Thigpen

/s/ Mark L. Mey

Mark L. Mey

/s/ David Tonnel

David Tonnel

*

Glyn A. Barker

*

Vanessa C.L. Chang

*

Frederico F. Curado

*

Vincent J. Intrieri

*

Samuel J. Merksamer

*

Frederik W. Mohn

*

Edward R. Muller

*

Margareth Øvrum

*

Diane de Saint Victor

By: /s/ David Tonnel

(Attorney-in-Fact)

Title

Chairman
of the Board of Directors

Chief Executive Officer
(Principal Executive Officer)

Executive Vice President and
Chief Financial Officer
(Principal Financial Officer)

Senior Vice President and
Chief Accounting Officer
(Principal Accounting
Officer)

Director

Director

Director

Director

Director

Director

Director

Director

Director

- 84 -

Table of Contents

- 85 -

Exhibit 10.52

Transocean Ltd. 2015 Long-Term Incentive Plan
(As Amended and Restated Effective May 27, 2021)
Appendix A to Award Letter

Terms and Conditions of Awards
February 10, 2022

To  the  extent  you  are  granted  an  award  of  (1)  Performance  Units  and  (2)  Restricted
Share Units (the award of the Performance Units and Restricted Share Units together,
the “Awards”) under the Transocean Ltd. 2015 Long-Term Incentive Plan, as amended
and  restated  effective  May  27,  2021  (the  “Plan”)  effective  as  of  the  date  indicated
above (the “Grant Date”), the target number of Performance Units and the number of
shares of Restricted Share Units subject to such grant is set forth in an award letter to
you  (the  “Award  Letter”).   Any  such  Award  is  subject  to  the  terms  and  conditions  set
forth in the Plan, the Prospectus for the Plan, any rules and regulations adopted by the
Committee, and the additional terms and conditions set forth in this Appendix A which
forms а part of your Award Letter.  Any terms used in the Award Letter or this Appendix
A  and  not  defined  herein  have  the  meanings  set  forth  in  the  Plan.    The  terms  and
provisions  of  your  Award  are  governed  by  the  terms  of  the  Plan  as  effective  May  27,
2021, and amended from time to time thereafter.  In the event there is an inconsistency
between the terms of the Plan and the Award Letter, the terms of the Plan will control.

Section I.

PERFORMANCE UNITS

1.

Determination of Earned Performance Units

(a)

Total Target Performance Unit Grant

For  purposes  of  the  Award  Letter  (including  this  Appendix  A),  the  term
“Total  Target  Performance  Units”  shall  mean  the  total  number  of  target
Shares (or other consideration) that may be issued to you in respect of
the achievement of certain performance standards as described herein,
subject to the terms and conditions hereof.

(b)

Earned Performance Units

The exact number of Performance Units that will actually be earned by
and issued to you and subject to the vesting described in Section I.2 (the
“Earned Performance Units”) will be based upon the achievement by the
Company  of  the  performance  standard,  as  described  in  this  Section
I.1(b).    The  performance  standard  shall  be  measured  for  (1)  the  three
calendar year periods ending December 31, 2022, December 31, 2023
and  December  31,  2024  (each  a  “Calendar  Performance  Period”),  and
(2)  the  cumulative  period  beginning  January  1,  2022  and  ending
December 31, 2024 (the “Cumulative Performance Period”).  

After the conclusion of each of the Calendar Performance Periods, and
at the conclusion of the Cumulative Performance Period, the Committee
will  make  a  determination  as  to  the  number  of  Earned  Performance
Units based on the Company’s relative performance on total shareholder
return (“TSR”) as

Appendix A

to  any  adjustment 

compared  against  a  peer  group  (as  identified  in  Exhibit  A)  over  the
respective  Calendar  Performance  Period  and 
the  Cumulative
Performance  Period,  and  at  the  conclusion  of  each  Calendar  and
the  Committee  will  make  a
Cumulative  Performance  Period 
determination  as 
the  number  of  Earned
Performance  Units  based  on  the  Company’s  absolute  performance  on
TSR.    The  determination  by  the  Committee  with  respect  to  the
achievement of absolute and relative TSR will be made in the first sixty
days  following  the  end  of  the  respective  Calendar  and  Cumulative
Performance  Period  after  all  necessary  Company  and  peer  information
is available.  The specific date on which such determination is formally
made  and  approved  by 
the
“Determination  Date”.   After  the  Determination  Date,  the  Company  will
notify you of the number of Earned Performance Units, if any.

the  Committee 

is  referred 

to  as 

to 

More  detailed  definitions  for  TSR  and  the  methodology  for  determining
the Earned Performance Units are incorporated herein as Exhibit A.

(c)

Committee Determinations

The Committee shall have absolute discretion to determine the number
of Earned Performance Units to which you are entitled, if any, including
without limitation such adjustments as may be necessary in the opinion
of  the  Committee  to  account  for  changes  since  the  date  of  the  Award
Letter.    The  Committee’s  determination  shall  be  final,  conclusive  and
binding upon you.  You shall not have any right or claim with respect to
any  units  other  than  Earned  Performance  Units  to  which  you  become
entitled in accordance with this Appendix A.

2.

Vesting

(a)

(b)

Unless  vested  on  an  earlier  date  as  provided  in  this  Appendix  A,  the
Earned  Performance  Units  will  be  vested  on  December  31,  2024,
subject to your continued employment through that date.

In certain circumstances more particularly described in Sections I.5 and
I.6 below, your Earned Performance Units may vest before the date set
forth  in  Section  I.2(a).    In  addition,  the  Committee  may  accelerate  the
vesting of all or a portion of your Earned Performance Units at any time
in its discretion.

(c)

You do not need to pay any purchase price for the Earned Performance
Units unless otherwise required in accordance with applicable law.

3.

Restrictions

Until  and  unless  you  vest  in  your  Earned  Performance  Units  and  receive  a
distribution of Shares, you do not own any of the Shares potentially subject to
this performance award and may not attempt to sell, transfer, assign or pledge
any such Shares.  After the Cumulative Performance Period has ended and all
Earned  Performance  Units  are  determined,  the  net  Shares  (total  Shares
distributable in respect of vested Earned Performance Units minus any Shares
retained  by  the  Company  in  accordance  with  the  policies  and  requirements
described in Section IV.4) will be delivered on March 15,

Appendix A

-2-

2025 in street name to your brokerage account (or, in the event of your death, to
a  brokerage  account  in  the  name  of  your  beneficiary  under  the  Plan)  with  the
broker  retained  by  the  Company  for  such  purpose  (the  “Broker”).   Any  Shares
distributed  to  you  in  respect  of  vested  Earned  Performance  Units  will  be
registered in your name and will not be subject to any restrictions.

4.

Dividend Equivalents, Dividends and Voting

(a)

(b)

(c)

Vested  Earned  Performance  Units.    In  the  event  that  dividends  are
paid with respect to Shares such that the applicable record date for such
dividends  occurs  during  the  period  beginning  on  the  Grant  Date  and
ending on the date you receive a distribution of Shares in satisfaction of
your vested Earned Performance Units, you will be entitled to receive a
cash payment equal to the amount of the dividend paid per Share as of
each  such  dividend  payment  date  multiplied  by  the  number  of  vested
Earned Performance Units (the “Earned Dividend Equivalent”).  You will
have  no  right  to  receive  any  payment  of  dividend  equivalents  with
respect  to  Performance  Units  that  do  not  become  vested  Earned
Performance Units.  All Earned Dividend Equivalents (if any) will be paid
in cash on the date of the regularly scheduled payroll next following the
date  of  distribution  of  Shares  with  respect  to  your  vested  Earned
Performance  Units,  or  as  soon  as  administratively  practicable  following
such  date  and  shall  be  subject  to  all  applicable  withholding  taxes.    For
any  non-cash  dividends,  the  Committee  may  determine  in  its  sole
discretion the cash value to be so paid to you in respect of such vested
Earned Performance Units or, if applicable, the adjustment to be applied
pursuant to Section 15 of the Plan.

Voting Shares.    You  will  have  the  right  to  vote  your  Shares  that  have
been  distributed  in  respect  of  any  vested  Earned  Performance  Units.
There are no voting rights associated with Performance Units (including
Earned Performance Units).

No Other Rights.  You shall have no other dividend equivalent, dividend
or voting rights with respect to any Performance Unit.

5.

Termination of Employment

(a)

Termination prior to the end of the Cumulative Performance Period

The terms set out in subsections (i)–(iii) below of this Section I.5(a) shall
apply to the vesting and settlement of Earned Performance Units in the
event  of  your  termination  of  employment  prior  to  the  last  day  of  the
Cumulative Performance Period.

(i)

Death or Disability.  If your employment is terminated by reason
of  death  or  Disability,  you  will  be  entitled  to  earn  a  Pro-Rata
Earned Award.  Distribution under Section I.3 in satisfaction of all
such  Earned  Performance  Units  shall  be  made  on  March  15,
2025.

(ii)

Involuntary Termination or Retirement.  If your employment is
terminated in an Involuntary Termination or by reason of you

Appendix A

-3-

becoming  a  Retiree,  you  will  be  entitled  to  earn  a  Pro-Rata
Earned Award.  Distribution under Section I.3 in satisfaction of all
such  Earned  Performance  Units  shall  be  made  on  March  15,
2025.

(iii)

Other  Termination  of  Employment.    If  your  employment  is
terminated  prior  to  the  end  of  the  Cumulative  Performance
Period for any reason other than those set forth in Section I.5(a)
(i),  I.5(a)(ii)  and  I.6(b),  you  will  not  be  entitled  to  any  Earned
Performance Units.

(b)

Adjustments by the Committee

The Committee may, in its sole discretion, accelerate the vesting of your
right  to  receive  all  or  any  portion  of  any  Earned  Performance  Units,
distributed on the distribution date under Section I.3.

(c)

Forfeiture of Performance Units

In addition to forfeitures of Performance Units pursuant to Section I.5(a)
above,  if  you  violate  or  fail  to  comply  with  any  of  the  covenants  or
obligations  applicable  to  you  under  the  Executive  Severance  Benefit
Policy,  you  shall  immediately  forfeit  any  Performance  Units,  whether  or
not earned.

6.

Change of Control

(a)

Change of Control

Upon the occurrence of a Change of Control, if you are employed by the
Company on the date of such Change of Control and the Determination
Date  with  respect  to  the  Cumulative  Performance  Period  or  any
Calendar  Performance  Period  has  not  occurred,  the  number  of  Earned
Performance  Units  to  which  you  are  entitled  shall  be  equal  to  the  Total
Target  Performance  Units  allocable  to  those  periods,  subject  to  the
vesting provisions described in the Award Letter and Section I.2, I.5, and
I.6(b).

The Shares (or other consideration) shall be issued in satisfaction of the
Earned Performance Units on the distribution date under Section I.3.

(b)

Change of Control Termination

Notwithstanding the provisions of the Award Letter or Sections I.2, I.5 or
I.6(a),  all  of  your  Earned  Performance  Units  (as  described  in  Section
I.6(a)) will vest immediately upon a Change of Control Termination and
the Shares (or other consideration) shall be issued in satisfaction of the
Earned Performance Units thirty days after the date of such Change of
Control Termination.

Appendix A

-4-

Section II.RESTRICTED SHARE UNITS

1.

Vesting and Restricted Share Units

(a)

Unless  vested  on  an  earlier  date  as  provided  in  this  Appendix  A,  the
Restricted  Share  Units  granted  pursuant  to  your  Award  Letter  will  fully
vest  in  installments  in  accordance  with  the  following  vesting  schedule
(each  date  below,  an  “RSU  Vesting  Date”)  provided  that  you  remain
continuously employed through the applicable RSU Vesting Date:

RSU Vesting
Date

March 1, 2023
March 1, 2024
March 1, 2025

Portion of
Restricted
Share Units
Vesting
1/3
1/3
1/3

To the extent that the vesting schedule above would result in vesting of a
fractional  Restricted  Share  Unit,  such  fractional  Restricted  Share  Unit
shall be rounded to a whole number as determined by the Committee.

(b)

In certain circumstances described in Section II.4 below, your Restricted
Share Units may fully vest before the final scheduled RSU Vesting Date.
 In addition, the Committee may accelerate the vesting of all or a portion
of your Restricted Share Units at any time in its discretion, subject to the
provisions of Section II.4(d).  The date of any accelerated vesting under
Section  II.4  below  will  be  a  RSU  Vesting  Date  for  purposes  of  this
Appendix A.

(c)

You  do  not  need  to  pay  any  purchase  price  for  the  Restricted  Share
Units unless otherwise required in accordance with applicable law.

2.

Restrictions on the Restricted Share Units

Until  and  unless  you  vest  in  your  Restricted  Share  Units  and  receive  a
distribution  of  Shares,  you  may  not  attempt  to  sell,  transfer,  assign  or  pledge
them.  Until the date on which you receive a distribution of the Shares in respect
of  any  vested  Restricted  Share  Units  awarded  hereunder,  your  award  of
Restricted Share Units will be evidenced by credit to a book entry account.

When  Restricted  Share  Units  vest  and  become  payable,  the  net  Shares  (total
Shares  distributable  in  respect  of  vested  Restricted  Share  Units  minus  any
Shares  retained  by  the  Company  in  accordance  with  the  policies  and
requirements  described  in  Section  IV.4),  will  be  delivered  to  you  within  sixty
days after the RSU Vesting Date in street name to your brokerage account (or,
in  the  event  of  your  death,  to  a  brokerage  account  in  the  name  of  your
beneficiary  under  the  Plan)  with  the  Broker.   Any  Shares  distributed  to  you  in
respect of vested Restricted Share Units will be registered in your name and will
not be subject to any restrictions.  There will be some delay between the RSU
Vesting  Date  and  the  date  your  Shares  become  available  to  you  due  to
administrative reasons.

Appendix A

-5-

3.

Dividend Equivalents and Voting

(a)

Dividend Equivalents

In the event that dividends are paid with respect to Shares such that the
applicable record date occurs during the period beginning on the Grant
Date  and  ending  on  the  date  you  receive  a  distribution  of  Shares  in
satisfaction of your vested Restricted Share Units, you will be entitled to
receive  a  cash  payment  equal  to  the  amount  of  the  dividend  paid  per
Share  as  of  such  dividend  payment  date  multiplied  by  the  number  of
vested  Restricted  Share  Units  (the  “Dividend  Equivalent”).    Dividend
Equivalents (if any) payable with respect to your vested Restricted Share
Units will be paid in cash on the date of the regularly scheduled payroll
next following the applicable Vesting Date, or as soon as administratively
practicable  following  such  date,  and  shall  be  subject  to  all  applicable
withholding  taxes.    For  any  non-cash  dividends,  the  Committee  may
determine  in  its  sole  discretion  the  cash  value  to  be  so  paid  to  you  in
respect  of  such  Restricted  Share  Units  or,  if  applicable,  the  adjustment
to be applied pursuant to Section 15 of the Plan.

(b)

Voting Shares

You will have the right to vote your Shares that have been distributed in
respect of any vested Restricted Share Units.  There are no voting rights
associated with Restricted Share Units.

(c)

No Other Rights

You  shall  have  no  other  dividend  equivalent,  dividend  or  voting  rights
with respect to any Restricted Share Unit.

4.

Termination of Employment

The  following  rules  apply  to  the  vesting  of  your  Restricted  Share  Units  in  the
event of your termination of employment.

(a)

(b)

Death  or  Disability.    If  your  employment  is  terminated  by  reason  of
death  or  Disability,  all  of  your  Restricted  Share  Units  will  vest  on  your
date of termination.  If you are Retirement Eligible and you experience a
Disability  that  satisfies  the  requirements  of  U.S.  Treasury  Regulation
Section 1.409A-3(i)(4) prior to the termination of your employment, all of
your Restricted Share Units will vest on the date of such Disability.

Involuntary  Termination  or  Retirement.    If  your  employment  is
terminated in an Involuntary Termination or by reason of you becoming a
Retiree,  a  pro  rata  portion  of  your  Restricted  Share  Units  will  vest  on
your  date  of  termination;  such  pro  rata  portion  shall  be  determined  by
multiplying  the  number  of  Restricted  Share  Units  granted  to  you  and
remaining  outstanding  and  unvested  at  the  time  your  employment  is
terminated  by  a  fraction,  the  numerator  of  which  is  the  number  of
calendar  days  you  were  employed  between  the  Grant  Date  and  your
date of termination and the denominator

Appendix A

-6-

(c)

(d)

of which is the number of calendar days between the Grant Date and the
final scheduled RSU Vesting Date.

Other Termination of Employment.  If your employment terminates for
any reason other than those set forth in Sections II.4(a), II.4(b) and II.5,
any of your Restricted Share Units which have not vested prior to your
termination of employment will be forfeited.

Adjustments  by  the  Committee.    The  Committee  may,  in  its  sole
discretion, accelerate the vesting of all or any portion of your Restricted
Share  Units;  provided,  however,  that  no  acceleration  of  delivery  of
Shares  shall  be  made  in  a  manner  that  is  not  in  compliance  with,  or
exempt from, any applicable requirements of Code Section 409A.

5.

Change of Control.  

Notwithstanding the provisions of the Award Letter or Sections II.1 or II.4, all of
your  Restricted  Share  Units  will  vest  immediately  upon  a  Change  of  Control
Termination.

Section III.Miscellaneous

The terms and provisions of this Section III apply to all Awards.  

1.

Definitions

(a)

(b)

(c)

“Cause”  means  (1)  your  willful  and  continued  failure  to  substantially
perform  your  duties  with  the  Company  (other  than  any  such  failure
resulting from your incapacity due to physical or mental illness), (2) your
willful  engagement  in  conduct  which  is  demonstrably  and  materially
injurious to the Company or its Subsidiaries, monetarily or otherwise, (3)
your willful, material breach of any written policy of the Company or any
written  agreement  between  you  and  the  Company  or  any  of  its
Subsidiaries,  including,  but  not  limited  to,  the  Company’s  Code  of
Integrity, human resource or legal compliance and ethics policies or any
felony  or  a
employment  agreement,  (4)  your 
misdemeanor involving fraud, dishonesty or moral turpitude, or (5) such
other events, acts or omissions as shall be determined in good faith.  For
purposes of clauses (1), (2) and (3) of this definition, no act, or failure to
act, on your part shall be deemed “willful” unless done, or omitted to be
done,  by  you  not  in  good  faith  and  without  reasonable  belief  that  your
act, or failure to act, was in the best interest of the Company.

indictment  of  a 

“Change  of  Control  Termination”  means  and  occurs  on  the  date  of
your  termination  of  employment  by  the  Company  or  any  Subsidiary  for
any reason other than Cause within two years after the date of a Change
of Control.

“Disability”  means  (1)  you  qualify  for  disability  benefits  under  a  long
term  disability  plan  sponsored  by  the  Company  or  (2)  if  you  are  not
covered  by  any  such  long  term  disability  plan,  the  Chief  Executive
Officer of the Company, or in the case of the termination of employment
of  the  Chief  Executive  Officer  of  the  Company,  the  Committee,  has
determined that you are disabled.

Appendix A

-7-

(d)

(e)

(f)

(g)

(h)

“Good  Reason”  means  (1) 
the  diminution  of  your  duties  or
responsibilities,  or  a  demotion  of  your  position,  to  such  an  extent  or  in
such a manner as to relegate you to a position not substantially similar
to that which you held prior to such change or (2) a material reduction in
your  base  salary  or  annual  incentive  plan  opportunities  other  than  in
connection  with  such  reductions  that  are  applicable  to  the  Company’s
executives as a group.  You shall not be considered to have terminated
for  Good  Reason  unless  you  notify  the  Company  in  writing  within  30
days  of  the  date  the  event  giving  rise  to  Good  Reason  occurs,  the
Company  does  not  cure  such  condition  within  30  days  of  such  notice
and you terminate your employment no later than 90 days after the date
the event giving rise to Good Reason occurred.

“Involuntary Termination” means the termination of your employment
(i) by the Company without Cause or (ii) by you for Good Reason.

With  respect  to  an  award  of  Performance  Units,  “Pro-Rata  Earned
Award” is determined by multiplying the number of Earned Performance
Units  which  would  have  otherwise  been  earned  for  each  of  the  three
Calendar Performance Periods and the Cumulative Performance Period
had your employment not been terminated by a fraction, the numerator
of which is the number of calendar days you were employed during the
period  beginning  January  1,  2022  and  ending  December  31,  2024  and
the  denominator  of  which  is  the  total  number  of  calendar  days  in  the
period beginning January 1, 2022 and ending December 31, 2024.

You  are  a  “Retiree”  if  your  separation  from  service  occurs  for  any
reason  other  than  Cause,  Involuntary  Termination,  Change  in  Control
Termination,  death  or  Disability  after  (a)  attainment  of  age  62  and  (b)
completion  of  at  least  five  years  of  service  with  the  Company  or  its
Subsidiaries.

With  respect  to  an  award  of  Restricted  Share  Units,  “Retirement
Eligible”  means,  and  will  apply  if,  your  final  RSU  Vesting  Date  is
scheduled to occur after the calendar year in which you will complete at
least five years of service with the Company or its Subsidiaries and will
attain at least age 62.

2.

Award Determinations

The Chief Executive Officer of the Company, or in the case of the termination of
employment  of  the  Chief  Executive  Officer  of  the  Company,  the  Committee,
shall  have  absolute  discretion  to  determine  the  date  and  circumstances  of
termination  of  your  employment  or  separation  from  service,  including  without
limitation whether as a result of Disability, Involuntary Termination, Cause, Good
Reason  or  any  other  reason  and  whether  you  are  a  Retiree,  and  such
determination shall be final, conclusive and binding upon you.

3.

Section 280G Limitation

Notwithstanding anything in the Award Letter (including this Appendix A) to the
contrary, if all or any portion of the benefits provided hereunder, either alone or
together with other payments and benefits received or to be received from the

Appendix A

-8-

Company or any affiliate or successor, would constitute a “parachute payment”,
as  such  term  is  defined  in  Code  Section  280G(b)(2),  the  aggregate  of  the
amounts  constituting  the  parachute  payment  shall  be  reduced  to  the  extent
necessary so that no portion thereof shall be subject to the excise tax imposed
by Code Section 4999, but only if, by reason of such reduction, the net after-tax
benefit  shall  exceed  the  net  after-tax  benefit  if  such  reduction  were  not  made.
  “Net  after-tax  benefit”  for  these  purposes  shall  mean  the  sum  of  (w)  the  total
amount  payable  under  this  Award,  plus  (x)  all  other  payments  and  benefits
which  you  receive  or  are  then  entitled  to  receive  from  the  Company  or  an
Affiliate  that,  alone  or  in  combination  with  the  amounts  payable  under  the
Award,  would  constitute  a  “parachute  payment”  within  the  meaning  of  Code
Section 280G, less (y) the amount of federal income taxes payable with respect
to the foregoing calculated at the maximum marginal income tax rate for each
year in which the foregoing shall be paid (based upon the rate in effect for such
year as set forth in the Code at the time of the payment under the Plan), less
(z)  the  amount  of  excise  taxes  imposed  with  respect  to  the  payments  and
benefits described in (w) and (x) above by Code Section 4999.  Such reduction
shall be made to those amounts that provide you with the best economic benefit
(and  to  the  extent  any  payments  are  economically  equivalent,  each  shall  be
reduced  pro  rata),  which  may  include,  without  limitation  and  to  the  extent
necessary, a reduction to the Awards or vesting of the Awards in order that this
limitation  not  be  exceeded;  provided,  however,  that  this  Section  IV.3  shall  be
superseded in its entirety by (i) any contrary treatment of parachute payments to
which you have agreed in writing prior to the Change of Control pursuant to any
other  plan,  program  or  agreement,  or  (ii)  any  more  favorable  treatment  of  the
excise  tax  on  parachute  payments  extended  to  you  by  the  Company  or  its
affiliates pursuant to any other plan, program or agreement.

4.

Tax Consequences and Withholding

(a)

(b)

You  should  consult  the  Plan  Prospectus  for  a  general  summary  of  the
Swiss  federal  income  tax  consequences  to  you  and,  if  applicable,  the
U.S. tax consequences to you, upon the grant, vesting or distribution to
you of the Awards based on currently applicable provisions of the Code,
related regulations and Swiss tax rules. The summary does not discuss
state and local tax laws or the laws of any other jurisdictions, which may
differ  from  the  U.S.  federal  tax  law  and  Swiss  tax  rules.  For  these
reasons,  you  are  urged  to  consult  your  own  tax  advisor  regarding  the
application of the tax laws to your particular situation.

With  respect  to  Awards  of  Performance  Units  under  Section  I  and
Restricted  Share  Units  under  Section  II,  the  Company  shall  reduce  the
number  of  Shares  otherwise  deliverable  to  you  with  respect  to  your
Earned  Performance  Units  or  Restricted  Share  Units  by  a  number  of
Shares having a value approximately equal to the amount required to be
withheld  under  the  Company’s  policies  and  procedures  or  applicable
law.  Further, any dividend equivalents paid to you in respect of Earned
Performance Units or Restricted Share Units pursuant to Section I.4 or
II.3,  respectively,  will  be  subject  to  tax  withholding,  as  appropriate,  as
additional compensation.

Appendix A

-9-

(c)

(d)

You  may  not  elect  to  have  the  Broker  withhold  Shares  having  a  value
less  than  the  minimum  statutory  withholding  tax  liability  or,  if  you  are
serving as an expatriate employee, the “standard deduction” withheld in
accordance  with  the  Company’s  policies  and  procedures.  If  you  fail  to
satisfy such withholding obligation in a time and manner satisfactory to
the Company, the Company shall have the right to withhold the required
amount from your salary or other amounts payable to you.

In  addition  to  the  previous  withholding  requirements,  any  award  under
the  Plan  is  also  subject  to  all  applicable  withholding  policies  of  the
Company as may be in effect from time to time, at the sole discretion of
the  Company.    Without  limiting  the  generality  of  the  foregoing,  the
Company  expressly  has  the  right  to  collect  or  cause  to  be  collected,
pursuant  to  any  tax  equalization  or  other  plan  or  policy,  as  any  such
policies  or  plans  may  be  in  effect  from  time  to  time  (irrespective  of
whether  such  withholding  correlates  to  the  applicable  tax  withholding
requirement with respect to your award) proceeds of the sale of Shares
acquired upon vesting of the applicable award through a sale arranged
by the Company or Broker on your behalf pursuant to this authorization
without further consent.  Awards are further subject to any tax and other
reporting requirement that may be applicable in any pertinent jurisdiction
including any obligation to report awards (whether related to the granting
or  vesting  thereof  or  exercise  of  rights  thereunder)  to  any  taxing
authority or other pertinent third party.

5.

Restrictions on Resale

Other  than  the  restrictions  referenced  in  Sections  I.3  and  II.2,  there  are  no
restrictions  imposed  by  the  Plan  on  the  resale  of  Shares  acquired  under  the
Plan.    However,  under  the  provisions  of  the  Securities  Act  and  the  rules  and
regulations  of  the  SEC,  resales  of  Shares  acquired  under  the  Plan  by  certain
officers and directors of the Company who may be deemed to be “affiliates” of
the  Company  must  be  made  pursuant  to  an  appropriate  effective  registration
statement  filed  with  the  SEC,  pursuant  to  the  provisions  of  Rule  144  issued
under  the  Securities  Act,  or  pursuant  to  another  exemption  from  registration
provided in the Securities Act.  At the present time, the Company does not have
a currently effective registration statement pursuant to which such resales may
be  made  by  affiliates.    There  are  no  restrictions  imposed  by  the  SEC  on  the
resale  of  Shares  acquired  under  the  Plan  by  persons  who  are  not  affiliates  of
the  Company;  provided,  however,  that  all  employees  are  subject  to  the
Company’s policies against insider trading, and restrictions against resale may
be  imposed  by  the  Company  from  time-to-time  as  may  be  necessary  under
applicable law.

6.

Beneficiary

You  may  designate  a  beneficiary  to  receive  any  portion  of  your  Performance
Units and Restricted Share Units that become due to you after your death, and
you  may  change  your  beneficiary  from  time  to  time.    Beneficiary  designations
should be filed with the Broker with respect to Performance Units and Restricted
Share Units.   The beneficiary if you fail to file a designation with the Broker for
the Performance Units and the Restricted Share Units, will be (1) the beneficiary
you designated under any group life

Appendix A

-10-

insurance plan maintained by the Company or its Subsidiaries that provides the
largest  death  benefit,  which  will  constitute  the  designated  beneficiary  for
purposes  of  this  Section  IV.6,  or,  if  none,  (2)  the  executor  or  administrator  of
your estate.

7.

Effect on Other Benefits

Income  recognized  by  you  as  a  result  of  the  grant,  vesting,  exercise  or
distribution of Shares with respect to Awards will not be included in the formula
for  calculating  benefits  under  any  of  the  Company’s  retirement  and  disability
plans or any other benefit plans.

8.

Code Section 409A Compliance

(a)

(b)

The  award  of  Performance  Units  under  Section  I  is  intended  to  be
exempt  from  or  to  comply  with  the  provisions  of  Section  409A  and,
wherever  possible,  shall  be  consistent  therewith.    No  action  taken  to
comply with Section 409A shall be deemed to impair a benefit under the
Award Letter or this Appendix A.

interpreted  consistent 

The award of Restricted Share Units under Section II is intended to be
exempt  from  or  to  comply  with  the  provisions  of  Section  409A  and,
wherever  possible,  shall  be 
therewith.
 Specifically, (1) if you are not Retirement Eligible, the time of payment
specified in Sections II.2 and II.4 is exempt from Code Section 409A as
a  short  term  deferral  in  compliance  with  U.S.  Treasury  Regulation
Section 1.409A-1(b)(4), and (2) if you are Retirement Eligible the time of
payment  specified  with  respect  to  Section  II.4(b)  is  compliant  with  U.S.
Treasury Regulation Section 1.409A-3(a)(1) and is compliant with Code
Section 409A as being paid pursuant to a permissible payment date of
separation from service under U.S. Treasury Regulation Section 1.409A-
1(h) and the time of payment specified in Section II.4(a) with respect to
Disability  is  compliant  with  U.S.  Treasury  Regulation  Section  1.409A-
3(a)(2) and is compliant with Code Section 409A as being paid pursuant
to  the  permissible  payment  event  of  disability  under  U.S.  Treasury
Regulation  Section  1.409A-3(i)(4).    If  you  are  Retirement  Eligible,  you
will  not  be  considered  to  have  a  termination  from  employment  unless
such termination meets the requirements for a “separation from service”
within  the  meaning  of  U.S.  Treasury  Regulation  Section  1.409A-1(h),  if
applicable.    If  you  are  a  “specified  employee”  on  the  date  of  your
“separation from service” within the meaning of Code Section 409A, the
time of payment otherwise specified in the Award Letter or this Appendix
A  will  be  deferred  to  the  extent  required  by  Code  Section  409A.    No
action  taken  to  comply  with  Code  Section  409A  shall  be  deemed  to
impair a benefit under the Award Letter or this Appendix A.

Appendix A

-11-

Exhibit “A” to Performance Unit Award

A. Weighting of Total Target Performance Units

Total Earned Performance Units will be based on achievement of relative TSR performance,
subject  to  an  adjustment  based  on  the  Company’s  absolute  TSR.    Your  total  Earned
Performance  Units,  if  any,  will  be  the  number  of  Target  Performance  Units  that  become
Earned Performance Units, with 20% of the Total Target Performance Units weighted to each
of  the  Calendar  Performance  Periods,  and  40%  of  the  Total  Target  Performance  Units
weighted  to  the  Cumulative  Performance  Period.    The  maximum  number  of  Earned
Performance  Units  that  you  may  receive  is  200%  of  the  Total  Target  Performance  Units
described  in  your  Award  Letter.    If  any  calculation  with  respect  to  the  Earned  Performance
Units  would  result  in  a  fractional  share,  the  numbers  of  Earned  Performance  Units  shall  be
rounded down to the nearest whole share.

B. Committee Methodology for TSR

The  Committee  will  make  a  determination  on  the  Determination  Date  with  respect  to  the
achievement of TSR (as defined under Section C below) by the Company and the members of
its peer group (as described under Section C below) and the number of Target Performance
Units,  if  any,  that  become  Earned  Performance  Units  based  on  achievement  of  Relative
Performance and Threshold Performance (as those terms are defined below).

“Relative  Performance”  shall  be  determined  by  ranking  the  Company,  along  with  the  other
companies  in  its  peer  group,  from  best  to  worst  based  on  TSR,  and  then  determining  the
percentile ranking to assess the number of Earned Performance Units as described below.

If,  during  the  applicable  Calendar  or  Cumulative  Performance  Period,  (i)  any  peer  group
company files for or is the subject of any bankruptcy, insolvency or liquidation proceeding, (ii)
any peer group company continues to exist but is no longer publicly traded on an established
securities market as a result of a de-listing event (other than due to an acquisition), or (iii) any
other  corporate  financial  restructuring  event,  condition  or  circumstance  exists  that,  in  the
determination of the Committee, causes a peer performance to no longer be appropriate for a
TSR  comparison,  such  peer  group  company  will  remain  in  the  peer  group  positioned  below
the  lowest  performing  member  of  the  peer  group  in  chronological  order  by  the  date  of  such
bankruptcy, insolvency, liquidation, de-listing or other event, condition or circumstance for the
applicable period.  In the event that a peer group company is subject to a transaction in which
more  than  50%  of  the  value  of  the  company’s  outstanding  shares  immediately  prior  to  the
transaction are acquired by another person or entity, such company shall be removed from the
peer group company listing for the applicable period in which the transaction occurred.  

The  Company’s  percentile  ranking  in  its  peer  group  shall  determine  the  number  of  TSR
Performance  Units  that  become  Earned  Performance  Units  due  to  Relative  Performance
based on the following schedule:

Transocean Percentile

90th Percentile or Greater

50th Percentile

25th Percentile

Less than 25th Percentile

Percentage of TSR Performance Units Becoming
Earned Performance Units (“Relative
Performance”)

200%

100%

50%

0%

Appendix A

-12-

For any achievement of a percentile ranking between the percentiles set forth in the schedule
above, the number of Total Performance Units that become Earned Performance Units due to
Relative  Performance  will  be  determined  by  linear  interpolation  between  the  percentages
assigned in the schedule above.

If  the  Company’s  absolute  TSR  is  less  than  -15%  in  any  of  the  Calendar  or  Cumulative
Performance  Periods,  then  no    more  than  100%  of  your  Performance  Units  will  become
Earned Performance Units in the relevant period.  

If  the  Company’s  absolute  TSR  is  greater  than  15%  in  any  of  the  Calendar  or  Cumulative
Performance  Periods  (“Threshold  Performance”),  a  minimum  of  50%  of  your  Performance
Units  will  become  Earned  Performance  Units  in  the  relevant  period.  If  the  Threshold
Performance  is  achieved,  the  total  number  of  Earned  Performance  Units  can  be  increased,
but  not  decreased,  based  on  achievement  of  Relative  Performance  for  the  Calendar
Performance Periods and the Cumulative Performance Period.

Notwithstanding the foregoing, a “Price Cap” will apply such that if the Fair Market Value of a
Share  exceeds  $20,  subject  to  adjustment  pursuant  to  Section  15  of  the  Plan,  on  the
applicable Determination Date at the end of the Cumulative Performance Period, the number
of  Performance  Units  that  would  have  become  Earned  Performance  Units  due  to  either  the
Relative Performance or Threshold Performance will be reduced by multiplying such number
of  Earned  Performance  Units  by  a  fraction,  the  numerator  of  which  is  $20,  subject  to
adjustment  pursuant  to  Section  15  of  the  Plan,  and  the  denominator  of  which  is  the  Fair
Market  Value  of  a  Share  on  the  Determination  Date.    If  the  Price  Cap  applies,  delivery  of  a
number of Shares equal to such reduced number of Earned Performance Units will be in full
satisfaction of the Performance Units.  As an example of the application of the Price Cap, if
100 Performance Units would become Earned Performance Units based on the schedule due
to  Relative  Performance  and  the  Fair  Market  Value  of  a  Share  is  $25  on  the  Determination
Date, 80 Shares will be delivered in settlement of the Performance Units (100 x 20/25).

C. Definition of Total Shareholder Return

Total Shareholder Return (“TSR”) through the Calendar or Cumulative Performance Period is
based on the comparison of the average closing share price for the thirty (30) business days
prior to start of the applicable Calendar or Cumulative Performance Period and the average
closing share price for the last thirty (30) business days in the applicable Performance Period,
adjusted for dividends.  The same calculation is conducted for the Company and each of the
companies in the peer group.

D. Peer Group

The peer group shall consist of:

Aker Solutions ASA

Helmerich & Payne, Inc.

Nabors Industries Ltd.
NOV, Inc.
Noble Corporation plc
Oceaneering  International,
Inc.
Odfjell Drilling Ltd.

Energy,

Oil  States  International,
Inc.
Patterson-UTI 
Inc.
Saipem S.p.A.
Subsea 7 S.A.
TechnipFMC plc
Tidewater Inc.

Valaris plc

Appendix A

-13-

NOTE:  The Committee has the sole authority to interpret the terms of this Exhibit
A, including the formula for TSR.  The Committee’s determination of all matters
in connection with the award will be final and binding.

Appendix A

-14-

Exhibit 21

SUBSIDIARIES OF TRANSOCEAN LTD.

(as of December 31, 2021)

Entity

Jurisdiction

15375 Memorial Corporation
Agon Shipping Inc.
Aguas Profundas, Limitada
Angola Deepwater Drilling Company (Offshore
Services) Ltd
AngoSantaFe - Prestacao de Servicos Petroliferos,
Limitada
Arcade Drilling AS
Asie Sonat Offshore Sdn. Bhd.
Barents Rigco Limited
Blegra Asset Management Limited
Blegra Financing Limited
Caledonia Offshore Drilling Services Limited
Challenger Minerals Inc.
Covent Garden - Serviços e Marketing, Sociedade
Unipessoal Lda
Deepwater Drilling (Transocean Ghana) Limited
Deepwater Drilling North Africa LLC - Free Zone
Deepwater Pacific 1 Inc.
Deepwater Supply Inc.
Drillship Alonissos Owners Inc.
Drillship Hydra Owners Inc.
Drillship Kithira Owners Inc.
Drillship Kythnos Owners Inc.
Drillship Paros Owners Inc.
Drillship Skiathos Owners Inc.
Drillship Skopelos Owners Inc.
Drillship Skyros Owners Inc.
Eastern Med Consultants Inc.
Entities Holdings, Inc.
Global Marine Inc.
Global Offshore Drilling Limited
GlobalSantaFe (Labuan) Inc.
GlobalSantaFe B.V.
GlobalSantaFe C.R. Luigs Limited
GlobalSantaFe Denmark Holdings ApS
GlobalSantaFe Drilling (N.A.) N.V.
GlobalSantaFe Drilling Company
GlobalSantaFe Drilling Company (North Sea) Limited
GlobalSantaFe Drilling Company (Overseas) Limited
GlobalSantaFe Drilling Mexico, S. de R.L. de C.V.

Delaware
Marshall Islands
Angola

Cayman Islands

Angola
Norway
Malaysia
Cayman Islands
Cyprus
Cyprus
England & Wales
California

Portugal
Ghana
Egypt
Cayman Islands
Delaware
Marshall Islands
Marshall Islands
Marshall Islands
Marshall Islands
Marshall Islands
Marshall Islands
Marshall Islands
Marshall Islands
Marshall Islands
Delaware
Delaware
Nigeria
Malaysia
Netherlands
England & Wales
Denmark
Netherlands Antilles
Delaware
England & Wales
England & Wales
Mexico

Exhibit 21

GlobalSantaFe Drilling Operations Inc.
GlobalSantaFe Drilling Services (North Sea) Limited
GlobalSantaFe Drilling Trinidad LLC
GlobalSantaFe Drilling Venezuela, C.A.
GlobalSantaFe Financial Services (Luxembourg) S.a.r.l.
GlobalSantaFe Group Financing Limited Liability
Company
GlobalSantaFe Holding Company (North Sea) Limited
GlobalSantaFe Hungary Services Limited Liability
Company
GlobalSantaFe International Drilling Corporation
GlobalSantaFe International Drilling Inc.
GlobalSantaFe International Services Inc.
GlobalSantaFe Nederland B.V.
GlobalSantaFe Offshore Services Inc.
GlobalSantaFe Operations (Mexico) LLC
GlobalSantaFe Saudi Arabia Ltd.
GlobalSantaFe Services (BVI) Inc.
GlobalSantaFe Services Netherlands B.V.
GlobalSantaFe Servicios de Venezuela, C.A.
GlobalSantaFe South America LLC
GlobalSantaFe Tampico, S. de R.L. de C.V.
GlobalSantaFe Techserv (North Sea) Limited
GlobalSantaFe U.S. Holdings Inc.
GSF Leasing Services GmbH
Indigo Drilling Limited
Inteliwell JV GP Limited
Inteliwell JV, LP
Kalambo Operations Inc.
Ocean Rig 1 Inc
Ocean Rig 2 Inc.
Ocean Rig Canada Inc.
Ocean Rig Cuanza Operations Inc.
Ocean Rig Cubango Operations Inc.
Ocean Rig Deepwater Drilling Limited
Ocean Rig Investments Inc.
Ocean Rig Management Inc.
Ocean Rig Operations Inc.
Ocean Rig UDW Inc.
Ocean Rig UDW LLC
OCR Falklands Drilling Inc.
Offshore Ghana Transocean Limited
Offshore Rig Operations AS
Olympia Rig Angola Holding, S.A.
Olympia Rig Angola, Limitada

Cayman Islands
England & Wales
Delaware
Venezuela
Luxembourg

Hungary
England & Wales

Hungary
Bahamas
Cayman Islands
Cayman Islands
Netherlands
Cayman Islands
Delaware
Cayman Islands
Cayman Islands
Netherlands
Venezuela
Delaware
Mexico
England & Wales
Delaware
Switzerland
Nigeria
Cayman Islands
Cayman Islands
Marshall Islands
Marshall Islands
Marshall Islands
Nova Scotia
Marshall Islands
Marshall Islands
Nigeria
Marshall Islands
Marshall Islands
Marshall Islands
Cayman Islands
Delaware
Marshall Islands
Ghana
Norway
Angola
Angola

Exhibit 21

OR Norge Operations Inc.
Orion Holdings (Cayman) Limited
Orion RigCo (Cayman) Limited
P.T. Santa Fe Supraco Indonesia
Platform Capital N.V.
Platform Financial N.V.
Primelead Limited
PT. Transocean Indonesia
R&B Falcon (A) Pty Ltd
R&B Falcon (Caledonia) Limited
R&B Falcon (M) Sdn. Bhd.
R&B Falcon (U.K.) Limited
R&B Falcon B.V.
R&B Falcon Deepwater (UK) Limited
R&B Falcon Drilling Co. LLC
R&B Falcon Exploration Co., LLC
R&B Falcon International Energy Services B.V.
Ranger Insurance Limited
RBF Rig Corporation, LLC
Reading & Bates Coal Co., LLC
Safemal Drilling Sdn. Bhd.
Santa Fe Braun Inc.
Santa Fe Construction Company
Santa Fe Drilling Company of Venezuela, C.A.
Saudi Drilling Company Limited
SDS Offshore Limited
Sedco Forex International, Inc.
Services Petroliers Transocean
Servicios Petroleros Santa Fe, S.A.
Ship Investment Ocean Holdings Inc.
Songa Offshore Delta Limited
Songa Offshore Drilling Limited
Songa Offshore Enabler Limited
Songa Offshore Encourage Limited
Songa Offshore Endurance Limited
Songa Offshore Equinox Limited
Songa Offshore Equipment Rental Limited
Songa Offshore Malaysia Sdn. Bhd.
Songa Offshore Management Limited
Songa Offshore Pte. Ltd.
Songa Offshore Rig 2 AS
Songa Offshore Rig 3 AS
Songa Offshore Saturn Limited

Marshall Islands
Cayman Islands
Cayman Islands
Indonesia
Netherlands Antilles
Netherlands Antilles
Cyprus
Indonesia
Western Australia
England & Wales
Malaysia
England & Wales
Netherlands
England & Wales
Delaware
Oklahoma
Netherlands
Cayman Islands
Delaware
Nevada
Malaysia
Delaware
Delaware
California
Saudi Arabia
England & Wales
Cayman Islands
France
Venezuela
Marshall Islands
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Cyprus
Malaysia
Cyprus
Singapore
Norway
Norway
Cyprus

Exhibit 21

Songa Offshore SE
Songa Offshore T & P Cyprus Limited
Songa Saturn Chartering Pte. Ltd.
Spitsbergen Rigco Limited
Sub-Saharan Drilling Inc.
T. I. International Mexico, S. de R.L. de C.V.
TILAM Holdings Limited
Transocean Africa Drilling Limited
Transocean Asia Services Sdn Bhd
Transocean Asset Holdings 1 Limited
Transocean Asset Holdings 2 Limited
Transocean Asset Holdings 3 Limited
Transocean Atlas Limited
Transocean Barents ASA
Transocean Brasil Ltda.
Transocean Britannia Limited
Transocean Canada Drilling Services Ltd.
Transocean Conqueror Limited
Transocean Conqueror Opco LLC
Transocean Corporate Services Limited
Transocean Cyprus Capital Management Public Limited
Transocean Cyprus Drilling Operations Public Limited
Transocean Deepwater Drilling Services Limited
Transocean Deepwater Holdings Limited
Transocean Deepwater Inc.
Transocean Deepwater Mauritius
Transocean Deepwater Nautilus Limited
Transocean Deepwater Seafarer Services Limited
Transocean Discoverer 534 LLC
Transocean Drilling Enterprises S.a.r.l.
Transocean Drilling Israel Ltd.
Transocean Drilling Limited
Transocean Drilling Namibia Inc.
Transocean Drilling Offshore S.a.r.l.
Transocean Drilling Sdn. Bhd.
Transocean Drilling Services (India) Private Limited
Transocean Drilling U.K. Limited
Transocean Eastern Pte. Ltd.
Transocean Employee Support Fund
Transocean Enabler Limited
Transocean Enabler Rigco Limited
Transocean Encourage Limited
Transocean Encourage Rigco Limited

Cyprus
Cyprus
Singapore
Cayman Islands
Marshall Islands
Mexico
Cayman Islands
Cayman Islands
Malaysia
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands
Norway
Brazil
Cayman Islands
Nova Scotia
Cayman Islands
Delaware
Cayman Islands
Cyprus
Cyprus
Cayman Islands
Cayman Islands
Delaware
Mauritius
Cayman Islands
Cayman Islands
Delaware
Luxembourg
Cayman Islands
Scotland
Cayman Islands
Luxembourg
Malaysia
India
Scotland
Singapore
Texas
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands

Exhibit 21

Transocean Endurance Limited
Transocean Endurance Rigco Limited
Transocean Entities Holdings GmbH
Transocean Equinox Limited
Transocean Equinox Rigco Limited
Transocean Finance Limited
Transocean Financing (Cayman) Limited
Transocean Financing GmbH
Transocean Guardian Limited
Transocean Holdings 1 Limited
Transocean Holdings 2 Limited
Transocean Holdings 3 Limited
Transocean Holdings LLC
Transocean Hungary Holdings LLC
Transocean Hungary Investments LLC
Transocean Hungary Ventures LLC
Transocean Inc.
Transocean Innovation Labs Ltd.
Transocean International Holdings Limited
Transocean International Resources, Limited
Transocean Investimentos Ltda.
Transocean Investments Holdings LLC
Transocean Investments S.a.r.l.
Transocean Ltd.
Transocean Management Services GmbH
Transocean Minerals Holdings Limited
Transocean Nautilus Limited
Transocean North Sea Limited
Transocean Norway Operations AS
Transocean Offshore (North Sea) Ltd.
Transocean Offshore Canada Services Ltd.
Transocean Offshore Deepwater Drilling Inc.
Transocean Offshore Deepwater Holdings Limited
Transocean Offshore Drilling Limited
Transocean Offshore Gulf of Guinea II Limited
Transocean Offshore Gulf of Guinea VI Limited
Transocean Offshore Gulf of Guinea VII Limited
Transocean Offshore Gulf of Guinea XII Limited
Transocean Offshore Gulf of Guinea XIII Limited
Transocean Offshore Holdings Limited
Transocean Offshore International Limited
Transocean Offshore International Ventures Limited
Transocean Offshore Limited

Cayman Islands
Cayman Islands
Switzerland
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands
Switzerland
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands
Delaware
Hungary
Hungary
Hungary
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands
Brazil
Delaware
Luxembourg
Switzerland
Switzerland
Cayman Islands
Cayman Islands
Bahamas
Norway
Cayman Islands
Nova Scotia
Delaware
Cayman Islands
England & Wales
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands
Delaware

Exhibit 21

Transocean Offshore PR Limited
Transocean Offshore USA Inc.
Transocean Onshore Support Services Limited
Transocean Orion Limited
Transocean Phoenix 2 Limited
Transocean Phoenix 2 Opco LLC
Transocean Pontus Limited
Transocean Pontus Opco, Inc.
Transocean Poseidon Limited
Transocean Poseidon Opco, Inc.
Transocean Proteus Limited
Transocean Proteus Opco LLC
Transocean Quantum Holdings Limited
Transocean Quantum Management Limited
Transocean Quantum Rig Holdings Limited
Transocean Quantum Sentry Holdings Limited
Transocean Rig 140 Limited
Transocean Rig Management Limited
Transocean Sedco Forex Ventures Limited
Transocean Sentry Limited
Transocean Services (India) Private Limited
Transocean Services AS
Transocean Services UK Limited
Transocean Skyros Limited
Transocean Spitsbergen ASA
Transocean SPSF Holdings Limited
Transocean Sub Asset Holdings 1 Limited
Transocean Sub Asset Holdings 2 Limited
Transocean Sub Asset Holdings 3 Limited
Transocean Support Services Limited
Transocean Support Services Nigeria Limited
Transocean Support Services Private Limited
Transocean Technical Services Egypt LLC
Transocean U.S. Holdings LLC
Transocean UK Limited
Transocean Voyager 1 Limited
Transocean Voyager 2 Limited
Transocean West Africa Holdings Limited
Transocean Worldwide Inc.
Triton Asset Leasing GmbH
Triton Capital I GmbH
Triton Capital II GmbH
Triton Capital Mexico GmbH

Cayman Islands
Delaware
Scotland
Cayman Islands
Cayman Islands
Delaware
Cayman Islands
Delaware
Cayman Islands
Delaware
Cayman Islands
Delaware
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands
India
Norway
England & Wales
Cayman Islands
Norway
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands
Nigeria
India
Egypt
Delaware
Luxembourg
Cayman Islands
Cayman Islands
Cayman Islands
Cayman Islands
Switzerland
Switzerland
Switzerland
Switzerland

Exhibit 21

Triton Conqueror GmbH
Triton Corcovado LLC
Triton Financing LLC
Triton Gemini GmbH
Triton Holdings Limited
Triton Hungary Asset Management LLC
Triton Hungary Investments 1 Limited Liability
Company
Triton Industries, Inc.
Triton KG2 GmbH
Triton Management Services LLC
Triton Mykonos LLC
Triton Nautilus Asset Leasing GmbH
Triton Nautilus Asset Management LLC
Triton Offshore Leasing Services Limited
Triton Pacific Limited
Triton Poseidon GmbH
Triton Voyager Asset Leasing GmbH
TRM Holdings Limited
TSSA - Servicos de Apoio, Lda.
Wilrig Offshore (UK) Limited

Switzerland
Hungary
Hungary
Switzerland
British Virgin Islands
Hungary

Hungary
Cayman Islands
Switzerland
Hungary
Hungary
Switzerland
Hungary
Malaysia
England & Wales
Switzerland
Switzerland
Cayman Islands
Angola
England & Wales

Exhibit 23.1

Consent of Independent Registered Public Accounting Firm

We consent to the incorporation by reference in the following Registration Statements of Transocean Ltd. and subsidiaries:           

(1) Registration Statement (Form S-4 No. 333-46374-99) as amended by Post-Effective Amendments on Form S-8 and Form S-3,

(2) Registration Statement (Form S-4 No. 333-54668-99) as amended by Post-Effective Amendments on Form S-8 and Form S-3,

(3) Registration Statement (Form S-8 No. 033-64776-99) as amended by Post-Effective Amendments on Form S-8,

(4) Registration Statement (Form S-8 No. 333-12475-99) as amended by Post-Effective Amendments on Form S-8,

(5) Registration Statement (Form S-8 No. 333-58211-99) as amended by Post-Effective Amendments on Form S-8,

(6) Registration Statement (Form S-8 No. 333-58203-99) as amended by Post-Effective Amendments on Form S-8,

(7) Registration Statement (Form S-8 No. 333-94543-99) as amended by Post-Effective Amendment on Form S-8,

(8) Registration Statement (Form S-8 No. 333-94569-99) as amended by Post-Effective Amendment on Form S-8,

(9) Registration Statement (Form S-8 No. 333-94551-99) as amended by Post-Effective Amendment on Form S-8,

(10) Registration Statement (Form S-8 No. 333-75532-99) as amended by Post-Effective Amendment on Form S-8,

(11) Registration Statement (Form S-8 No. 333-75540-99) as amended by Post-Effective Amendment on Form S-8,

(12) Registration Statement (Form S-8 No. 333-106026-99) as amended by Post-Effective Amendment on Form S-8,

(13) Registration Statement (Form S-8 No. 333-115456-99) as amended by Post-Effective Amendment on Form S-8,

(14) Registration Statement (Form S-8 No. 333-130282-99) as amended by Post-Effective Amendment on Form S-8,

(15) Registration Statement (Form S-8 No. 333-147669-99) as amended by Post-Effective Amendment on Form S-8,

(16) Registration Statement (Form S-8 No. 333-163320),

(17) Registration Statement (Form S-8 No. 333-204359),

(18) Registration Statement (Form S-4 No. 333-213146) as supplemented by Registration Statement (Form S-4 No. 333-214768),

(19) Registration Statement (Form S-4 No. 333-220791),

(20) Registration Statement (Form S-4 No. 333-222894),

(21) Registration Statement (Form S-3 No. 333-222895),

(22) Registration Statement (Form S-3 No. 333-222896),

(23) Registration Statement (Form S-4 No. 333-227487),

(24) Registration Statement (Form S-8 No. 333-227750),

(25) Registration Statement (Form S-8 No. 333-238091),

(26) Registration Statement (Form S-3 No. 333-248616);

(27) Registration Statement (Form S-3 No. 333-257093); and

(28) Registration Statement (Form S-8 No. 333-257804);

of our reports dated February 23, 2022, with respect to the consolidated financial statements of Transocean Ltd. and subsidiaries and the
effectiveness of internal control over financial reporting of Transocean Ltd. and subsidiaries included in this Annual Report (Form 10-K) of
Transocean Ltd. for the year ended December 31, 2021.

Houston, Texas
February 23, 2022

/s/ Ernst & Young LLP

Exhibit 24

TRANSOCEAN LTD.

Power of Attorney

WHEREAS,  TRANSOCEAN  LTD.,  a  Swiss  company  (the  “Company”),  intends  to  file  with  the

Securities and Exchange Commission (the “Commission”) pursuant to the Securities Exchange Act

of 1934, as amended, and the rules and regulations of the Commission promulgated thereunder, an

Annual  Report  on  Form  10-K  for  the  fiscal  year  ended  December  31,  2021  of  the  Company,

together  with  any  and  all  exhibits,  documents  and  other  instruments  and  documents  necessary,

advisable  or  appropriate  in  connection  therewith,  including  any  amendments  thereto  (the  “Form

10-K”);

NOW, THEREFORE, the undersigned, in his capacity as a director or officer or both, as the case

may be, of the Company, does hereby appoint Jeremy D. Thigpen,  Mark L. Mey,  Brady K. Long,

  Sandro  Thoma,    David  Tonnel,  and  Daniel  Ro-Trock,  and  each  of  them  severally,  his  true  and

lawful  attorney  or  attorneys  with  power  to  act  with  or  without  the  other,  and  with  full  power  of

substitution and resubstitution, to execute in his name, place and stead, in his capacity as director,

officer or both, as the case may be, of the Company, the Form 10-K and any and all amendments

thereto,  including  any  and  all  exhibits  and  other  instruments  and  documents  said  attorney  or

attorneys  shall  deem  necessary,  appropriate  or  advisable  in  connection  therewith,  and  to  file  the

same  with  the  Commission  and  to  appear  before  the  Commission  in  connection  with  any  matter

relating thereto.  Each of said attorneys shall have the full power and authority to do and perform

in  the  name  and  on  behalf  of  the  undersigned,  in  any  and  all  capacities,  every  act  whatsoever

necessary or desirable to be done in the premises, as fully and to all intents and purposes as the

undersigned might or could do in person, the undersigned hereby ratifying and approving the acts

that said attorneys and each of them, or their or his substitutes or substitute, may lawfully do or

cause to be done by virtue hereof.

IN WITNESS WHEREOF, the undersigned has executed this power of attorney as of the 23 day of

February 2022.

By: /s/ Chadwick C. Deaton  

Name:  Chadwick C. Deaton

 
 
 
 
 
 
   
Exhibit 24

TRANSOCEAN LTD.

Power of Attorney

WHEREAS,  TRANSOCEAN  LTD.,  a  Swiss  company  (the  “Company”),  intends  to  file  with  the

Securities and Exchange Commission (the “Commission”) pursuant to the Securities Exchange Act

of 1934, as amended, and the rules and regulations of the Commission promulgated thereunder, an

Annual  Report  on  Form  10-K  for  the  fiscal  year  ended  December  31,  2021  of  the  Company,

together  with  any  and  all  exhibits,  documents  and  other  instruments  and  documents  necessary,

advisable  or  appropriate  in  connection  therewith,  including  any  amendments  thereto  (the  “Form

10-K”);

NOW, THEREFORE, the undersigned, in her capacity as a director or officer or both, as the case

may be, of the Company, does hereby appoint Jeremy D. Thigpen,  Mark L. Mey,  Brady K. Long,

  Sandro  Thoma,    David  Tonnel,  and  Daniel  Ro-Trock,  and  each  of  them  severally,  her  true  and

lawful  attorney  or  attorneys  with  power  to  act  with  or  without  the  other,  and  with  full  power  of

substitution and resubstitution, to execute in her name, place and stead, in her capacity as director,

officer or both, as the case may be, of the Company, the Form 10-K and any and all amendments

thereto,  including  any  and  all  exhibits  and  other  instruments  and  documents  said  attorney  or

attorneys  shall  deem  necessary,  appropriate  or  advisable  in  connection  therewith,  and  to  file  the

same  with  the  Commission  and  to  appear  before  the  Commission  in  connection  with  any  matter

relating thereto.  Each of said attorneys shall have the full power and authority to do and perform

in  the  name  and  on  behalf  of  the  undersigned,  in  any  and  all  capacities,  every  act  whatsoever

necessary or desirable to be done in the premises, as fully and to all intents and purposes as the

undersigned might or could do in person, the undersigned hereby ratifying and approving the acts

that said attorneys and each of them, or their or his substitutes or substitute, may lawfully do or

cause to be done by virtue hereof.

IN WITNESS WHEREOF, the undersigned has executed this power of attorney as of the 23 day of

February 2022.

By: /s/ Diane de Saint Victor  

Name: Diane de Saint Victor

 
 
 
 
 
   
Exhibit 24

TRANSOCEAN LTD.

Power of Attorney

WHEREAS,  TRANSOCEAN  LTD.,  a  Swiss  company  (the  “Company”),  intends  to  file  with  the

Securities and Exchange Commission (the “Commission”) pursuant to the Securities Exchange Act

of 1934, as amended, and the rules and regulations of the Commission promulgated thereunder, an

Annual  Report  on  Form  10-K  for  the  fiscal  year  ended  December  31,  2021  of  the  Company,

together  with  any  and  all  exhibits,  documents  and  other  instruments  and  documents  necessary,

advisable  or  appropriate  in  connection  therewith,  including  any  amendments  thereto  (the  “Form

10-K”);

NOW, THEREFORE, the undersigned, in his capacity as a director or officer or both, as the case

may be, of the Company, does hereby appoint Jeremy D. Thigpen,  Mark L. Mey,  Brady K. Long,

  Sandro  Thoma,    David  Tonnel,  and  Daniel  Ro-Trock,  and  each  of  them  severally,  his  true  and

lawful  attorney  or  attorneys  with  power  to  act  with  or  without  the  other,  and  with  full  power  of

substitution and resubstitution, to execute in his name, place and stead, in his capacity as director,

officer or both, as the case may be, of the Company, the Form 10-K and any and all amendments

thereto,  including  any  and  all  exhibits  and  other  instruments  and  documents  said  attorney  or

attorneys  shall  deem  necessary,  appropriate  or  advisable  in  connection  therewith,  and  to  file  the

same  with  the  Commission  and  to  appear  before  the  Commission  in  connection  with  any  matter

relating thereto.  Each of said attorneys shall have the full power and authority to do and perform

in  the  name  and  on  behalf  of  the  undersigned,  in  any  and  all  capacities,  every  act  whatsoever

necessary or desirable to be done in the premises, as fully and to all intents and purposes as the

undersigned might or could do in person, the undersigned hereby ratifying and approving the acts

that said attorneys and each of them, or their or his substitutes or substitute, may lawfully do or

cause to be done by virtue hereof.

IN WITNESS WHEREOF, the undersigned has executed this power of attorney as of the 23 day of

February 2022.

By: /s/ Edward R. Muller  

Name:  Edward R. Muller

 
 
 
 
 
 
   
Exhibit 24

TRANSOCEAN LTD.

Power of Attorney

WHEREAS,  TRANSOCEAN  LTD.,  a  Swiss  company  (the  “Company”),  intends  to  file  with  the

Securities and Exchange Commission (the “Commission”) pursuant to the Securities Exchange Act

of 1934, as amended, and the rules and regulations of the Commission promulgated thereunder, an

Annual  Report  on  Form  10-K  for  the  fiscal  year  ended  December  31,  2021  of  the  Company,

together  with  any  and  all  exhibits,  documents  and  other  instruments  and  documents  necessary,

advisable  or  appropriate  in  connection  therewith,  including  any  amendments  thereto  (the  “Form

10-K”);

NOW, THEREFORE, the undersigned, in his capacity as a director or officer or both, as the case

may be, of the Company, does hereby appoint Jeremy D. Thigpen,  Mark L. Mey,  Brady K. Long,

  Sandro  Thoma,    David  Tonnel,  and  Daniel  Ro-Trock,  and  each  of  them  severally,  his  true  and

lawful  attorney  or  attorneys  with  power  to  act  with  or  without  the  other,  and  with  full  power  of

substitution and resubstitution, to execute in his name, place and stead, in his capacity as director,

officer or both, as the case may be, of the Company, the Form 10-K and any and all amendments

thereto,  including  any  and  all  exhibits  and  other  instruments  and  documents  said  attorney  or

attorneys  shall  deem  necessary,  appropriate  or  advisable  in  connection  therewith,  and  to  file  the

same  with  the  Commission  and  to  appear  before  the  Commission  in  connection  with  any  matter

relating thereto.  Each of said attorneys shall have the full power and authority to do and perform

in  the  name  and  on  behalf  of  the  undersigned,  in  any  and  all  capacities,  every  act  whatsoever

necessary or desirable to be done in the premises, as fully and to all intents and purposes as the

undersigned might or could do in person, the undersigned hereby ratifying and approving the acts

that said attorneys and each of them, or their or his substitutes or substitute, may lawfully do or

cause to be done by virtue hereof.

IN WITNESS WHEREOF, the undersigned has executed this power of attorney as of the 23 day of

February 2022.

By: /s/ Frederico F. Curado  

Name:  Frederico F. Curado

 
 
 
 
 
 
   
Exhibit 24

TRANSOCEAN LTD.

Power of Attorney

WHEREAS,  TRANSOCEAN  LTD.,  a  Swiss  company  (the  “Company”),  intends  to  file  with  the

Securities and Exchange Commission (the “Commission”) pursuant to the Securities Exchange Act

of 1934, as amended, and the rules and regulations of the Commission promulgated thereunder, an

Annual  Report  on  Form  10-K  for  the  fiscal  year  ended  December  31,  2021  of  the  Company,

together  with  any  and  all  exhibits,  documents  and  other  instruments  and  documents  necessary,

advisable  or  appropriate  in  connection  therewith,  including  any  amendments  thereto  (the  “Form

10-K”);

NOW, THEREFORE, the undersigned, in his capacity as a director or officer or both, as the case

may be, of the Company, does hereby appoint Jeremy D. Thigpen,  Mark L. Mey,  Brady K. Long,

  Sandro  Thoma,    David  Tonnel,  and  Daniel  Ro-Trock,  and  each  of  them  severally,  his  true  and

lawful  attorney  or  attorneys  with  power  to  act  with  or  without  the  other,  and  with  full  power  of

substitution and resubstitution, to execute in his name, place and stead, in his capacity as director,

officer or both, as the case may be, of the Company, the Form 10-K and any and all amendments

thereto,  including  any  and  all  exhibits  and  other  instruments  and  documents  said  attorney  or

attorneys  shall  deem  necessary,  appropriate  or  advisable  in  connection  therewith,  and  to  file  the

same  with  the  Commission  and  to  appear  before  the  Commission  in  connection  with  any  matter

relating thereto.  Each of said attorneys shall have the full power and authority to do and perform

in  the  name  and  on  behalf  of  the  undersigned,  in  any  and  all  capacities,  every  act  whatsoever

necessary or desirable to be done in the premises, as fully and to all intents and purposes as the

undersigned might or could do in person, the undersigned hereby ratifying and approving the acts

that said attorneys and each of them, or their or his substitutes or substitute, may lawfully do or

cause to be done by virtue hereof.

IN WITNESS WHEREOF, the undersigned has executed this power of attorney as of the 23 day of

February 2022.

By: /s/ Frederik W. Mohn  

Name:  Frederik W. Mohn

 
 
 
 
 
 
   
Exhibit 24

TRANSOCEAN LTD.

Power of Attorney

WHEREAS,  TRANSOCEAN  LTD.,  a  Swiss  company  (the  “Company”),  intends  to  file  with  the

Securities and Exchange Commission (the “Commission”) pursuant to the Securities Exchange Act

of 1934, as amended, and the rules and regulations of the Commission promulgated thereunder, an

Annual  Report  on  Form  10-K  for  the  fiscal  year  ended  December  31,  2021  of  the  Company,

together  with  any  and  all  exhibits,  documents  and  other  instruments  and  documents  necessary,

advisable  or  appropriate  in  connection  therewith,  including  any  amendments  thereto  (the  “Form

10-K”);

NOW, THEREFORE, the undersigned, in his capacity as a director or officer or both, as the case

may be, of the Company, does hereby appoint Jeremy D. Thigpen,  Mark L. Mey,  Brady K. Long,

  Sandro  Thoma,    David  Tonnel,  and  Daniel  Ro-Trock,  and  each  of  them  severally,  his  true  and

lawful  attorney  or  attorneys  with  power  to  act  with  or  without  the  other,  and  with  full  power  of

substitution and resubstitution, to execute in his name, place and stead, in his capacity as director,

officer or both, as the case may be, of the Company, the Form 10-K and any and all amendments

thereto,  including  any  and  all  exhibits  and  other  instruments  and  documents  said  attorney  or

attorneys  shall  deem  necessary,  appropriate  or  advisable  in  connection  therewith,  and  to  file  the

same  with  the  Commission  and  to  appear  before  the  Commission  in  connection  with  any  matter

relating thereto.  Each of said attorneys shall have the full power and authority to do and perform

in  the  name  and  on  behalf  of  the  undersigned,  in  any  and  all  capacities,  every  act  whatsoever

necessary or desirable to be done in the premises, as fully and to all intents and purposes as the

undersigned might or could do in person, the undersigned hereby ratifying and approving the acts

that said attorneys and each of them, or their or his substitutes or substitute, may lawfully do or

cause to be done by virtue hereof.

IN WITNESS WHEREOF, the undersigned has executed this power of attorney as of the 23 day of

February 2022.

By: /s/ Glyn A. Barker  

Name:  Glyn A. Barker

 
 
 
 
 
 
   
Exhibit 24

TRANSOCEAN LTD.

Power of Attorney

WHEREAS,  TRANSOCEAN  LTD.,  a  Swiss  company  (the  “Company”),  intends  to  file  with  the

Securities and Exchange Commission (the “Commission”) pursuant to the Securities Exchange Act

of 1934, as amended, and the rules and regulations of the Commission promulgated thereunder, an

Annual  Report  on  Form  10-K  for  the  fiscal  year  ended  December  31,  2021  of  the  Company,

together  with  any  and  all  exhibits,  documents  and  other  instruments  and  documents  necessary,

advisable  or  appropriate  in  connection  therewith,  including  any  amendments  thereto  (the  “Form

10-K”);

NOW, THEREFORE, the undersigned, in his capacity as a director or officer or both, as the case

may  be,  of  the  Company,  does  hereby  appoint    Mark  L.  Mey,    Brady  K.  Long,    Sandro  Thoma,

 David Tonnel, and Daniel Ro-Trock, and each of them severally, his true and lawful attorney or

attorneys  with  power  to  act  with  or  without  the  other,  and  with  full  power  of  substitution  and

resubstitution, to execute in his name, place and stead, in his capacity as director, officer or both, as

the case may be, of the Company, the Form 10-K and any and all amendments thereto, including

any  and  all  exhibits  and  other  instruments  and  documents  said  attorney  or  attorneys  shall  deem

necessary,  appropriate  or  advisable  in  connection  therewith,  and  to  file  the  same  with  the

Commission  and  to  appear  before  the  Commission  in  connection  with  any  matter  relating

thereto.  Each of said attorneys shall have the full power and authority to do and perform in the

name and on behalf of the undersigned, in any and all capacities, every act whatsoever necessary

or desirable to be done in the premises, as fully and to all intents and purposes as the undersigned

might  or  could  do  in  person,  the  undersigned  hereby  ratifying  and  approving  the  acts  that  said

attorneys and each of them, or their or his substitutes or substitute, may lawfully do or cause to be

done by virtue hereof.

IN WITNESS WHEREOF, the undersigned has executed this power of attorney as of the 23 day of

February 2022.

By: /s/ Jeremy D. Thigpen  

Name:  Jeremy D. Thigpen

 
 
 
 
 
 
   
Exhibit 24

TRANSOCEAN LTD.

Power of Attorney

WHEREAS,  TRANSOCEAN  LTD.,  a  Swiss  company  (the  “Company”),  intends  to  file  with  the

Securities and Exchange Commission (the “Commission”) pursuant to the Securities Exchange Act

of 1934, as amended, and the rules and regulations of the Commission promulgated thereunder, an

Annual  Report  on  Form  10-K  for  the  fiscal  year  ended  December  31,  2021  of  the  Company,

together  with  any  and  all  exhibits,  documents  and  other  instruments  and  documents  necessary,

advisable  or  appropriate  in  connection  therewith,  including  any  amendments  thereto  (the  “Form

10-K”);

NOW, THEREFORE, the undersigned, in her capacity as a director or officer or both, as the case

may be, of the Company, does hereby appoint Jeremy D. Thigpen,  Mark L. Mey,  Brady K. Long,

  Sandro  Thoma,    David  Tonnel,  and  Daniel  Ro-Trock,  and  each  of  them  severally,  her  true  and

lawful  attorney  or  attorneys  with  power  to  act  with  or  without  the  other,  and  with  full  power  of

substitution and resubstitution, to execute in her name, place and stead, in her capacity as director,

officer or both, as the case may be, of the Company, the Form 10-K and any and all amendments

thereto,  including  any  and  all  exhibits  and  other  instruments  and  documents  said  attorney  or

attorneys  shall  deem  necessary,  appropriate  or  advisable  in  connection  therewith,  and  to  file  the

same  with  the  Commission  and  to  appear  before  the  Commission  in  connection  with  any  matter

relating thereto.  Each of said attorneys shall have the full power and authority to do and perform

in  the  name  and  on  behalf  of  the  undersigned,  in  any  and  all  capacities,  every  act  whatsoever

necessary or desirable to be done in the premises, as fully and to all intents and purposes as the

undersigned might or could do in person, the undersigned hereby ratifying and approving the acts

that said attorneys and each of them, or their or his substitutes or substitute, may lawfully do or

cause to be done by virtue hereof.

IN WITNESS WHEREOF, the undersigned has executed this power of attorney as of the 23 day of

February 2022.

By: /s/ Margareth Øvrum  

Name: Margareth Øvrum

 
 
 
 
 
   
Exhibit 24

TRANSOCEAN LTD.

Power of Attorney

WHEREAS,  TRANSOCEAN  LTD.,  a  Swiss  company  (the  “Company”),  intends  to  file  with  the

Securities and Exchange Commission (the “Commission”) pursuant to the Securities Exchange Act

of 1934, as amended, and the rules and regulations of the Commission promulgated thereunder, an

Annual  Report  on  Form  10-K  for  the  fiscal  year  ended  December  31,  2021  of  the  Company,

together  with  any  and  all  exhibits,  documents  and  other  instruments  and  documents  necessary,

advisable  or  appropriate  in  connection  therewith,  including  any  amendments  thereto  (the  “Form

10-K”);

NOW, THEREFORE, the undersigned, in his capacity as a director or officer or both, as the case

may be, of the Company, does hereby appoint Jeremy D. Thigpen,  Mark L. Mey,  Brady K. Long,

  Sandro  Thoma,    David  Tonnel,  and  Daniel  Ro-Trock,  and  each  of  them  severally,  his  true  and

lawful  attorney  or  attorneys  with  power  to  act  with  or  without  the  other,  and  with  full  power  of

substitution and resubstitution, to execute in his name, place and stead, in his capacity as director,

officer or both, as the case may be, of the Company, the Form 10-K and any and all amendments

thereto,  including  any  and  all  exhibits  and  other  instruments  and  documents  said  attorney  or

attorneys  shall  deem  necessary,  appropriate  or  advisable  in  connection  therewith,  and  to  file  the

same  with  the  Commission  and  to  appear  before  the  Commission  in  connection  with  any  matter

relating thereto.  Each of said attorneys shall have the full power and authority to do and perform

in  the  name  and  on  behalf  of  the  undersigned,  in  any  and  all  capacities,  every  act  whatsoever

necessary or desirable to be done in the premises, as fully and to all intents and purposes as the

undersigned might or could do in person, the undersigned hereby ratifying and approving the acts

that said attorneys and each of them, or their or his substitutes or substitute, may lawfully do or

cause to be done by virtue hereof.

IN WITNESS WHEREOF, the undersigned has executed this power of attorney as of the 23 day of

February 2022.

By: /s/ Samuel J. Merksamer  

Name:  Samuel J. Merksamer

 
 
 
 
 
 
   
Exhibit 24

TRANSOCEAN LTD.

Power of Attorney

WHEREAS,  TRANSOCEAN  LTD.,  a  Swiss  company  (the  “Company”),  intends  to  file  with  the

Securities and Exchange Commission (the “Commission”) pursuant to the Securities Exchange Act

of 1934, as amended, and the rules and regulations of the Commission promulgated thereunder, an

Annual  Report  on  Form  10-K  for  the  fiscal  year  ended  December  31,  2021  of  the  Company,

together  with  any  and  all  exhibits,  documents  and  other  instruments  and  documents  necessary,

advisable  or  appropriate  in  connection  therewith,  including  any  amendments  thereto  (the  “Form

10-K”);

NOW, THEREFORE, the undersigned, in her capacity as a director or officer or both, as the case

may be, of the Company, does hereby appoint Jeremy D. Thigpen,  Mark L. Mey,  Brady K. Long,

  Sandro  Thoma,    David  Tonnel,  and  Daniel  Ro-Trock,  and  each  of  them  severally,  her  true  and

lawful  attorney  or  attorneys  with  power  to  act  with  or  without  the  other,  and  with  full  power  of

substitution and resubstitution, to execute in her name, place and stead, in her capacity as director,

officer or both, as the case may be, of the Company, the Form 10-K and any and all amendments

thereto,  including  any  and  all  exhibits  and  other  instruments  and  documents  said  attorney  or

attorneys  shall  deem  necessary,  appropriate  or  advisable  in  connection  therewith,  and  to  file  the

same  with  the  Commission  and  to  appear  before  the  Commission  in  connection  with  any  matter

relating thereto.  Each of said attorneys shall have the full power and authority to do and perform

in  the  name  and  on  behalf  of  the  undersigned,  in  any  and  all  capacities,  every  act  whatsoever

necessary or desirable to be done in the premises, as fully and to all intents and purposes as the

undersigned might or could do in person, the undersigned hereby ratifying and approving the acts

that said attorneys and each of them, or their or his substitutes or substitute, may lawfully do or

cause to be done by virtue hereof.

IN WITNESS WHEREOF, the undersigned has executed this power of attorney as of the 23 day of

February 2022.

By: /s/ Vanessa C. L. Chang  

Name: Vanessa C. L. Chang

 
 
 
 
 
   
Exhibit 24

TRANSOCEAN LTD.

Power of Attorney

WHEREAS,  TRANSOCEAN  LTD.,  a  Swiss  company  (the  “Company”),  intends  to  file  with  the

Securities and Exchange Commission (the “Commission”) pursuant to the Securities Exchange Act

of 1934, as amended, and the rules and regulations of the Commission promulgated thereunder, an

Annual  Report  on  Form  10-K  for  the  fiscal  year  ended  December  31,  2021  of  the  Company,

together  with  any  and  all  exhibits,  documents  and  other  instruments  and  documents  necessary,

advisable  or  appropriate  in  connection  therewith,  including  any  amendments  thereto  (the  “Form

10-K”);

NOW, THEREFORE, the undersigned, in his capacity as a director or officer or both, as the case

may be, of the Company, does hereby appoint Jeremy D. Thigpen,  Mark L. Mey,  Brady K. Long,

  Sandro  Thoma,    David  Tonnel,  and  Daniel  Ro-Trock,  and  each  of  them  severally,  his  true  and

lawful  attorney  or  attorneys  with  power  to  act  with  or  without  the  other,  and  with  full  power  of

substitution and resubstitution, to execute in his name, place and stead, in his capacity as director,

officer or both, as the case may be, of the Company, the Form 10-K and any and all amendments

thereto,  including  any  and  all  exhibits  and  other  instruments  and  documents  said  attorney  or

attorneys  shall  deem  necessary,  appropriate  or  advisable  in  connection  therewith,  and  to  file  the

same  with  the  Commission  and  to  appear  before  the  Commission  in  connection  with  any  matter

relating thereto.  Each of said attorneys shall have the full power and authority to do and perform

in  the  name  and  on  behalf  of  the  undersigned,  in  any  and  all  capacities,  every  act  whatsoever

necessary or desirable to be done in the premises, as fully and to all intents and purposes as the

undersigned might or could do in person, the undersigned hereby ratifying and approving the acts

that said attorneys and each of them, or their or his substitutes or substitute, may lawfully do or

cause to be done by virtue hereof.

IN WITNESS WHEREOF, the undersigned has executed this power of attorney as of the 23 day of

February 2022.

By: /s/ Vincent J. Intrieri  

Name: Vincent J. Intrieri

 
 
 
 
 
 
   
CEO CERTIFICATION PURSUANT TO SECTION 302 OF THE SARBANES-OXLEY ACT OF 2002

Exhibit 31.1

I, Jeremy D. Thigpen, certify that:

1.

2.

3.

4.

I have reviewed this report on Form 10-K of Transocean Ltd.;

Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a
material fact necessary to make the statements made, in light of the circumstances under which such statements
were made, not misleading with respect to the period covered by this report;

Based on my knowledge, the financial statements, and other financial information included in this report, fairly
present in all material respects the financial condition, results of operations and cash flows of the registrant as of,
and for, the periods presented in this report;

The registrant’s other certifying officer and I are responsible for establishing and maintaining disclosure controls
and procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial
reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and we have:

a)

designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be
designed under our supervision, to ensure that material information relating to the registrant, including its
consolidated subsidiaries, is made known to us by others within those entities, particularly during the period
in which this report is being prepared;

b) designed such internal control over financial reporting, or caused such internal control over financial

reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of
financial reporting and the preparation of financial statements for external purposes in accordance with
generally accepted accounting principles;

c)

evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report
our conclusions about the effectiveness of the disclosure controls and procedures, as of the end of the period
covered by this report based on such evaluation; and

d) disclosed in this report any change in the registrant’s internal control over financial reporting that occurred

during the registrant’s most recent fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual
report) that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control
over financial reporting; and

5.

The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal
control over financial reporting, to the registrant’s auditors and the audit committee of registrant’s board of
directors (or persons performing the equivalent function):

a)

all significant deficiencies and material weaknesses in the design or operation of internal control over
financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, process,
summarize and report financial information; and

b)

any fraud, whether or not material, that involves management or other employees who have a significant role
in the registrant’s internal control over financial reporting.

Dated:     February 23, 2022

 /s/ Jeremy D. Thigpen
Jeremy D. Thigpen
Chief Executive Officer

CFO CERTIFICATION PURSUANT TO SECTION 302 OF THE SARBANES-OXLEY ACT OF 2002

Exhibit 31.2

I, Mark L. Mey, certify that:

1.

2.

3.

4.

I have reviewed this report on Form 10-K of Transocean Ltd.;

Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a
material fact necessary to make the statements made, in light of the circumstances under which such statements
were made, not misleading with respect to the period covered by this report;

Based on my knowledge, the financial statements, and other financial information included in this report, fairly
present in all material respects the financial condition, results of operations and cash flows of the registrant as of,
and for, the periods presented in this report;

The registrant’s other certifying officer and I are responsible for establishing and maintaining disclosure controls
and procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial
reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and we have:

a)

designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be
designed under our supervision, to ensure that material information relating to the registrant, including its
consolidated subsidiaries, is made known to us by others within those entities, particularly during the period
in which this report is being prepared;

b) designed such internal control over financial reporting, or caused such internal control over financial

reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of
financial reporting and the preparation of financial statements for external purposes in accordance with
generally accepted accounting principles;

c)

evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this  report 
our conclusions about the effectiveness of the disclosure controls and procedures, as of the end of the period 
covered by this report based on such evaluation; and

d) disclosed in this report any change in the registrant’s internal control over financial reporting that occurred

during the registrant’s most recent fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual
report) that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control
over financial reporting; and

5.

The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal
control over financial reporting, to the registrant’s auditors and the audit committee of registrant’s board of
directors (or persons performing the equivalent function):

a)

all significant deficiencies and material weaknesses in the design or operation of internal control over
financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, process,
summarize and report financial information; and

b)

any fraud, whether or not material, that involves management or other employees who have a significant role
in the registrant’s internal control over financial reporting.

Dated:     February 23, 2022

 /s/ Mark L. Mey
Mark L. Mey
Executive Vice President and Chief Financial Officer

CERTIFICATION PURSUANT TO SECTION 906 OF 
THE SARBANES-OXLEY ACT OF 2002 (SUBSECTIONS (a) AND (b) 
OF SECTION 1350, CHAPTER 63 OF TITLE 18, UNITED STATES CODE)

Exhibit 32.1

Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 (Subsections (a) and (b) of Section 1350, Chapter 63
of Title 18, United States Code), I, Jeremy D. Thigpen, Chief Executive Officer of Transocean Ltd., a Swiss corporation
(the “Company”), hereby certify, to my knowledge, that:

(1)

(2)

the Company’s Annual Report on Form 10-K for the year ended December 31, 2021 (the “Report”) fully
complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

information contained in the Report fairly presents, in all material respects, the financial condition and
results of operations of the Company.

Dated: February 23, 2022

/s/ Jeremy D. Thigpen
Jeremy D. Thigpen
Chief Executive Officer

The foregoing certification is being furnished solely pursuant to Section 906 of the Sarbanes-Oxley Act of 2002
(Subsections (a) and (b) of Section 1350, Chapter 63 of Title 18, United States Code) and is not being filed as part of the
Report or as a separate disclosure document.

A signed original of this written statement required by Section 906 has been provided to the Company and will be retained
by the Company and furnished to the U.S. Securities and Exchange Commission or its staff upon request.

CERTIFICATION PURSUANT TO SECTION 906 OF 
THE SARBANES-OXLEY ACT OF 2002 (SUBSECTIONS (a) AND (b) 
OF SECTION 1350, CHAPTER 63 OF TITLE 18, UNITED STATES CODE)

Exhibit 32.2

Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 (Subsections (a) and (b) of Section 1350, Chapter 63
of Title 18, United States Code), I, Mark L. Mey, Executive Vice President and Chief Financial Officer of Transocean Ltd.,
a Swiss corporation (the “Company”), hereby certify, to my knowledge, that:

(1)

(2)

the Company’s Annual Report on Form 10-K for the year ended December 31, 2021 (the “Report”) fully
complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

information contained in the Report fairly presents, in all material respects, the financial condition and
results of operations of the Company.

Dated: February 23, 2022

 /s/ Mark L. Mey
Mark L. Mey
Executive Vice President and Chief Financial Officer

The foregoing certification is being furnished solely pursuant to Section 906 of the Sarbanes-Oxley Act of 2002
(Subsections (a) and (b) of Section 1350, Chapter 63 of Title 18, United States Code) and is not being filed as part of the
Report or as a separate disclosure document.

A signed original of this written statement required by Section 906 has been provided to the Company and will be retained
by the Company and furnished to the U.S. Securities and Exchange Commission or its staff upon request.

DESCRIPTION OF TRANSOCEAN LTD.’S SECURITIES
REGISTERED PURSUANT TO SECTION 12 OF THE
SECURITIES EXCHANGE ACT OF 1934

Exhibit 4.1

As of February 16, 2022, Transocean Ltd. had two classes of securities registered under Section 12 of the Securities
Exchange Act of 1934, as amended: registered shares, par value CHF 0.10 per share (“shares”)  and  exchangeable
bonds due 2023 (“Exchangeable Bonds”).

Description of the Shares

The following description of Transocean Ltd.’s shares is a summary and is subject to the complete text of our Articles
of Association, filed as Exhibit 3.1 to our Quarterly Report on Form 10-Q (Commission File No. 001-38373) for the
quarter ended September 30, 2021, filed on November 2, 2021. We encourage you to read the Articles of Association
carefully. In this description, references to “Transocean,” “we,” ”our,” and “us” mean Transocean Ltd.

Description of Share Capital

Issued Share Capital. As  of  February  16,  2022,  the  share  capital  of  Transocean  registered  shares  in  the  commercial
register, which reflects Transocean’s total issued share capital, excluding shares issued out of Transocean’s conditional
share  capital  not  yet  registered  with  the  commercial  register,  was  CHF  72,817,616.50,  divided  into  728,176,165
registered  Transocean  shares,  par  value  0.10  Swiss  francs  per  share.  The  total  issued  share  capital  of  Transocean,
including  Transocean  shares  issued  out  of  Transocean’s  conditional  share  capital  not  yet  registered  with  the
commercial  register,  was  72,817,645.60  Swiss  francs,  divided  into  728,176,456  registered  Transocean  shares,  par
value  0.10  Swiss  francs  per  share.  The  issued  Transocean  shares  are  fully  paid,  non-assessable,  and  rank  pari  passu
with each other and all other Transocean shares.

General Authorized Share Capital. Our board of directors is authorized to issue new shares at any time until May 27,
2023  and  thereby  increase  the  stated  share  capital  by  a  maximum  amount  of  16,320,285  Swiss  francs  by  issuing  a
maximum of 163,202,850 shares. Our general authorized share capital expires on May 27, 2023.

Our  board  of  directors  determines  the  time  of  the  issuance,  the  issuance  price,  the  manner  in  which  the  new
Transocean shares have to be paid in, the date from which the new Transocean shares carry the right to dividends and,
subject to the provisions of our Articles of Association, the conditions for the exercise of the preemptive rights with
respect to the issuance and the allotment of preemptive rights that are not exercised. The board of directors may allow
preemptive  rights  that  are  not  exercised  to  expire,  or  it  may  place  such  rights  or  Transocean  shares,  the  preemptive
rights  in  respect  of  which  have  not  been  exercised,  at  market  conditions  or  use  them  otherwise  in  our  interest.  A
withdrawal  of  preemptive  rights  with  respect  to  shares  issued  out  of  our  authorized  capital  is  limited  to  26,067,616
shares.  For further information on preemptive rights with respect to our authorized share capital, see “—Preemptive
Rights and Advance Subscription Rights” below.

An  increase  of  the  share  capital  (i)  by  means  of  an  offering  underwritten  by  a  financial  institution,  a  syndicate  of
financial institutions or another third party or third parties, followed by an offer to the then-existing shareholders of
Transocean, and (ii) in partial amounts shall be permissible.

The  shares  will  be  subject  to  the  limitations  for  registration  in  the  share  register  pursuant  to  Articles  7  and  9  of
Transocean’s Articles of Association.

Conditional Share Capital. Article  6  of  Transocean’s  Articles  of  Association  has  not  yet  been  updated  to  reflect  the
issuance  of  291  shares  following  the  exercise  of  certain  of  our  Exchangeable  Bonds.  Accordingly,  the  remaining
authority to issue shares out of conditional share capital is limited to a maximum of 142,363,356 shares; these shares
may be issued through:

● the exercise of conversion, exchange, option, warrant or similar rights for the subscription of shares granted

to third parties or shareholders in connection with bonds, options, warrants or other securities newly or

already issued in national or international capital markets or new or already existing contractual obligations
by or of us or any of our group companies or any of our respective predecessors; or

● in  connection  with  the  issuance  of  shares,  options  or  other  share-based  awards  to  members  of  the  board  of
directors,  members  of  our  executive  management,  employees,  contractors,  consultants  or  other  persons
providing services to us or our subsidiaries.

For  information  on  preemptive  rights  with  respect  to  our  conditional  share  capital,  see  “—Preemptive  Rights  and
Advance Subscription Rights” below.

Other Classes or Series of Transocean Shares / Non-voting stock (Genussscheine / Partizipationsscheine). The board
of directors may not create Transocean shares with increased voting powers without the affirmative resolution adopted
by  shareholders  holding  at  least  two-thirds  of  the  voting  rights  and  an  absolute  majority  of  the  par  value  of  the
Transocean shares, each as represented (in person or by proxy) at a general meeting of the shareholders. Our board of
directors  may  create  preferred  stock  with  the  vote  of  a  majority  of  the  votes  cast  at  a  general  meeting  of  our
shareholders (not counting broker non-votes, abstentions and blank or invalid ballots).

Transocean has not issued any non-voting stock to date (Partizipationsscheine, Genussscheine).

Preemptive Rights and Advance Subscription Rights

Under the Swiss Code of Obligations (the “Swiss Code”), the prior approval of a general meeting of shareholders is
generally  required  to  authorize,  for  later  issuance,  the  issuance  of  Transocean  shares,  or  rights  to  subscribe  for,  or
convert into, Transocean shares (which rights may be connected to debt instruments or other obligations). In addition,
the existing shareholders will have preemptive rights in relation to such Transocean shares or rights in proportion to
the  respective  par  values  of  their  holdings.  The  shareholders  may,  with  the  affirmative  vote  of  shareholders  holding
two-thirds  of  the  voting  rights  and  a  majority  of  the  par  value  of  the  Transocean  shares  represented  at  the  general
meeting,  withdraw  or  limit  the  preemptive  rights  for  valid  reasons  (such  as  a  merger,  an  acquisition  or  any  of  the
reasons authorizing the board of directors to withdraw or limit the preemptive rights of shareholders in the context of
an authorized capital increase as described below).

If the general meeting of shareholders has approved the creation of authorized or conditional capital, it may delegate
the decision whether to withdraw or limit the preemptive and advance subscription rights for valid reasons to the board
of directors. However, the valid reasons justifying the exclusion of the preemptive right must be stated in the articles of
association.  Our  Articles  of  Association  provide  for  this  delegation  and  state  the  valid  reasons  with  respect  to  our
authorized  and  conditional  share  capital  in  the  circumstances  described  below  under  “—General  Authorized  Share
Capital” and “—Conditional Share Capital.”

General Authorized Share Capital. At any time until May 27, 2023 and pursuant to Article 5 of Transocean’s Articles
of Association, the board of directors is authorized to withdraw or limit the preemptive rights of the shareholders with
respect to a maximum of 26,067,616 shares and to allot them to individual shareholders or third parties with respect to
the issuance of shares from authorized capital if:

●

●

●

● the  issue  price  of  the  new  shares  is  determined  by  reference  to  the  market

price;

● the  shares  are  issued  in  connection  with  the  acquisition  of  an  enterprise  or
participations  or  any  part  of  an  enterprise  or  participations,  the  financing  or
refinancing of any such transactions or the financing of our new investment
plans;

● the  shares  are  issued  in  connection  with  the  intended  broadening  of  the
shareholder  constituency  of  Transocean  in  certain  financial  or  investor
markets,  for  the  purposes  of  the  participation  of  strategic  partners,  or  in
connection  with  the  listing  of  the  shares  on  domestic  or  foreign  stock
exchanges;

●

●

● in  connection  with  a  placement  or  sale  of  shares,  the  grant  of  an  over-
allotment option of up to 20% of the total number of shares in a placement or
sale of shares to the initial purchasers or underwriters; or

● for  the  participation  of  directors,  members  of  our  executive  management
team,  employees,  contractors,  consultants  and  other  persons  performing
services for our benefit or the benefit of any of our subsidiaries.

Conditional Share Capital. In connection with the issuance of bonds, notes, warrants or other financial instruments or
contractual  obligations  convertible  into  or  exercisable  or  exchangeable  for  our  shares,  the  preemptive  rights  of
shareholders are excluded and the board of directors is authorized to withdraw or limit the advance subscription rights
of shareholders in connection with the issuance of bonds, notes, warrants or other securities or contractual obligations
convertible  into  or  exercisable  or  exchangeable  for  our  shares  if  the  issuance  is  for  purposes  of  financing  or
refinancing the acquisition of an enterprise or business, parts of an enterprise, participations or investments, or if the
issuance occurs in national or international capital markets or through a private placement.

If the advance subscription rights are withdrawn or limited:

●

●

●

● the  respective  financial  instruments  or  contractual  obligations  will  be  issued

or entered into at market conditions;

● the  conversion,  exchange  or  exercise  price,  if  any,  for  instruments  or
obligations  will  be  set  with  reference  to  the  market  conditions  prevailing  at
the  date  on  which  the  instruments  or  obligations  are  issued  or  entered  into;
and

● the  instruments  or  obligations  may  be  converted,  exercised  or  exchanged

during a maximum period of 30 years.

The preemptive rights and the advance subscription rights of shareholders are excluded with respect to shares, bonds,
notes,  warrants  or  other  securities  or  contractual  obligations  issued  from  our  conditional  share  capital  to  directors,
members of executive management, employees, contractors, consultants or other persons providing services to us or
any of our subsidiaries.

Dividends and Other Distributions

Under the Swiss Code, dividends may be paid out only if we have sufficient distributable profits from the previous
fiscal year, or if we have freely distributable reserves (including contribution reserves, which are also referred to as
additional  paid-in  capital),  each  as  will  be  presented  on  our  audited  annual  standalone  statutory  balance  sheet.  The
affirmative vote of shareholders holding a majority of the votes cast at a general meeting of shareholders (not counting
abstentions  and  blank  or  invalid  ballots)  must  approve  the  distribution  of  dividends.  The  board  of  directors  may
propose to shareholders that a dividend or other distribution be paid but cannot itself authorize the distribution.

Payments out of our share capital (in other words, the aggregate par value of our registered share capital) in the form
of dividends are not allowed; however, payments out of registered share capital may be made by way of a par value
reduction. Such a par value reduction requires the approval of shareholders holding a majority of the votes cast at the
general  meeting  of  shareholders  (not  counting  abstentions  and  blank  or  invalid  ballots).  A  special  audit  report  must
confirm  that  claims  of  our  creditors  remain  fully  covered  despite  the  reduction  in  the  share  capital  recorded  in  the
commercial  register.  A  licensed  audit  expert  must  prepare  the  audit  report  and  be  present  at  the  general  meeting  of
shareholders that adopts the resolution.  Upon approval by the general meeting of shareholders of the capital reduction,
the  board  of  directors  must  give  public  notice  of  the  par  value  reduction  resolution  in  the  Swiss  Official  Gazette  of
Commerce  three  times  and  notify  creditors  that  they  may  request,  within  two  months  of  the  third  publication,
satisfaction of or security for their claims.

Under the Swiss Code, if our general reserves amount to less than 20% of our share capital recorded in the commercial
register (i.e., 20% of the aggregate par value of our registered capital), then at least 5% of our annual profit must be

retained as general reserves. The Swiss Code and our Articles of Association permit us to accrue additional general
reserves. In addition, if we acquire our own shares, we would be required to account for these shares, if acquired by
our parent company Transocean Ltd., as a negative item in our shareholders’ equity or, if these shares are acquired by
one of our subsidiaries, to create a special reserve, in each case  on our audited annual standalone statutory balance
sheet in the amount of the purchase price of the shares repurchased by our parent or our subsidiary. The negative item
in our shareholders’ equity or the reserve amount would effectively reduce our capacity to declare dividends or effect
subsequent repurchases of our shares.

Swiss companies generally must maintain a separate company, stand-alone “statutory” balance sheet for the purpose
of, among other things, determining the amounts available for the return of capital to shareholders, including by way of
a distribution of dividends. Our auditor must confirm that a proposal made by the board of directors to shareholders
regarding the appropriation of our available earnings or the distribution of freely distributable reserves conforms to the
requirements of the Swiss Code and our Articles of Association. Dividends are usually due and payable shortly after
the  shareholders  have  passed  a  resolution  approving  the  payment,  but  shareholders  may  also  resolve  at  the  annual
general  meeting  of  shareholders  to  pay  dividends  in  quarterly  or  other  installments.  Our  Articles  of  Association
provide that dividends that have not been claimed within five years after the payment date become our property and
are allocated to the general reserves. Dividends paid out of distributable profits or distributable general reserves are
subject  to  Swiss  withholding  tax,  all  or  part  of  which  can  potentially  be  reclaimed  under  the  relevant  tax  rules  in
Switzerland  or  double  taxation  treaties  concluded  between  Switzerland  and  foreign  countries.  Distributions  to
shareholders in the form of a par value reduction and distributions out of qualifying additional paid-in capital are not
subject to the Swiss federal withholding tax.

Dividends, if declared by us, are expected to be declared, subject to applicable limitations under Swiss law, in U.S.
dollars,  or  in  Swiss  francs,  and  shareholders  may  be  given  the  right  to  elect  to  be  paid  any  such  dividends  in  U.S.
dollars  or  Swiss  francs.  Distribution  through  a  reduction  in  the  par  value  of  the  shares  must  be  declared  in  Swiss
francs; however, shareholders may be provided with the option to elect to be paid in U.S. dollars or Swiss francs.

Repurchases of Shares

The Swiss Code limits our ability to hold or repurchase our own shares. We and our subsidiaries may only repurchase
shares if and to the extent that sufficient freely distributable equity capital is available, as described above under “—
Dividends and Other Distributions.” The aggregate par value of all of our shares held by us and our subsidiaries may
not exceed 10% of the registered share capital. However, we may repurchase our own shares beyond the statutory limit
of  10%  if  the  shareholders  have  passed  a  resolution  at  a  general  meeting  of  shareholders  authorizing  the  board  of
directors to repurchase shares in an amount in excess of 10% and the repurchased shares are dedicated for cancellation.
Any shares repurchased pursuant to such an authorization will then be cancelled at a general meeting of shareholders
upon the approval of shareholders holding a majority of the votes cast at the general meeting. Repurchased shares held
by us or our subsidiaries do not carry any rights to vote at a general meeting of shareholders but are, unless otherwise
resolved  by  our  shareholders  at  a  general  meeting,  entitled  to  the  economic  benefits  generally  associated  with  the
shares.

General Meetings of Shareholders

The general meeting of shareholders is our supreme corporate body. Ordinary and extraordinary shareholders meetings
may be held. Among other things, the following powers will be vested exclusively in the shareholders meeting:

●

●

●

● adoption and amendment of our Articles of Association;

● the annual election of the chairman of the board of directors, the members of
the  board  of  directors,  the  members  of  the  compensation  committee  of  the
board of directors, the auditor and the independent proxy;

● approval  of  the  annual  management  report,  the  stand-alone  statutory

financial statements and the consolidated financial statements;

●

●

●

●

● appropriation of the annual profit shown on our annual stand-alone statutory

balance sheet, in particular the distribution of any dividends;

● discharge  of  the  members  of  the  board  of  directors  and  the  executive
management  team  from  liability  for  business  conduct  during  the  previous
fiscal year(s) to the extent such conduct is known to the shareholders;

● ratification of the maximum aggregate amounts of compensation of the board

of directors and the executive management team;

● subject to certain exceptions, the approval of a business combination with an
interested  shareholder  (as  such  terms  are  defined  in  our  Articles  of
Association); and

● any  other  resolutions  that  are  submitted  to  a  general  meeting  of  shareholders  pursuant  to
law,  our  Articles  of  Association  or  by  voluntary  submission  by  the  board  of  directors
(unless a matter is within the exclusive competence of the board of directors pursuant to the
Swiss Code).

Notice and Proxy Statements

Under  the  Swiss  Code  and  our  Articles  of  Association,  we  must  hold  an  annual,  ordinary  general  meeting  of
shareholders within six months after the end of our fiscal year for the purpose, among other things, of approving the
annual  financial  statements  and  the  annual  management  report,  the  annual  election  of  our  chairman  of  the  board  of
directors,  the  members  of  the  board  of  directors,  the  members  of  the  compensation  committee  of  our  board  of
directors,  our  auditor  and  our  independent  proxy,  and  the  ratification  of  the  maximum  aggregate  amount  of
compensation of the board of directors and the executive management team. The invitation to general meetings must
be  published  in  the  Swiss  Official  Gazette  of  Commerce  at  least  20  calendar  days  prior  to  the  date  of  the  relevant
general meeting of shareholders. The notice of a meeting must state the items on the agenda and the proposals of the
board  of  directors  and  of  the  shareholders  who  requested  that  a  shareholders  meeting  be  held  or  that  an  item  be
included on the agenda and, in case of elections, the names of the nominated candidates. No resolutions may be passed
at  a  shareholders  meeting  concerning  agenda  items  for  which  proper  notice  was  not  given.  This  does  not  apply,
however,  to  proposals  made  during  a  shareholders  meeting  to  convene  an  extraordinary  shareholders  meeting  or  to
initiate a special investigation. No previous notification will be required for proposals concerning items included on
the agenda or for debates as to which no vote is taken.

Annual  general  meetings  of  shareholders  are  convened  by  the  board  of  directors  or,  under  certain  circumstances
required by law, by the auditor. A general meeting of shareholders can be held anywhere.

We expect to set the record date for each general meeting of shareholders on a date not more than 20 calendar days
prior  to  the  date  of  each  general  meeting  and  announce  the  date  of  the  general  meeting  of  shareholders  prior  to  the
record date.

Extraordinary General Meetings of Shareholders

An  extraordinary  general  meeting  may  be  called  upon  the  resolution  of  the  board  of  directors  or,  under  certain
circumstances  required  by  law,  by  the  auditor.  In  addition,  the  board  of  directors  is  required  to  convene  an
extraordinary general meeting of shareholders if so resolved by the general meeting of shareholders, or if so requested
by  shareholders  holding  an  aggregate  of  at  least  10%  of  the  share  capital  recorded  in  the  commercial  register  or
according to the views expressed in legal writing, which is a persuasive authority in Switzerland, holding shares with
an aggregate par value of CHF 1 million, specifying the items for the agenda and their proposals, or if it appears from
the  annual  stand-alone  statutory  balance  sheet  that  half  of  our  share  capital  recorded  in  the  commercial  register  and
legal  reserves  are  not  covered  by  our  assets.  In  the  latter  case,  the  board  of  directors  must  immediately  convene  an
extraordinary general meeting of shareholders and propose financial restructuring measures.

Agenda Requests

Under our Articles of Association, any shareholder may request that an item be included on the agenda of a general
meeting  of  shareholders.  Such  shareholder  may  also  nominate  one  or  more  directors  for  election.  A  request  for
inclusion  of  an  item  on  the  agenda  or  a  nominee  must  be  made  in  writing  at  least  30  calendar  days  prior  to  the
anniversary  date  of  the  proxy  statement  in  connection  with  our  last  general  meeting  of  shareholders;  provided,
however,  that  if  the  date  of  the  general  meeting  of  shareholders  is  more  than  30  calendar  days  before  or  after  the
anniversary date of the last annual general meeting of shareholders, such request must instead be made by the tenth
calendar  day  following  the  date  on  which  we  have  made  public  disclosure  of  the  date  of  the  general  meeting  of
shareholders. The request must specify in writing the relevant agenda items and motions, together with evidence of the
required shares recorded in the share register, as well as any other information as would be required to be included in a
proxy statement pursuant to the rules of the Securities and Exchange Commission.

Under the Swiss Code, a general meeting of shareholders for which a notice of meeting has been duly published may
not be adjourned without publishing a new notice of meeting.

Our annual report, our compensation report pursuant to Swiss law and the auditor’s reports must be made available for
inspection  by  the  shareholders  at  our  registered  office  in  Steinhausen,  Canton  of  Zug,  Switzerland,  no  later  than  20
calendar days prior to the annual general meeting of shareholders. Each shareholder is entitled to request immediate
delivery of a copy of these documents free of charge. Shareholders of record will be notified of this in writing.

Voting

Each  of  our  shares  carries  one  vote  at  a  general  meeting  of  shareholders.  Voting  rights  may  be  exercised  by
shareholders  registered  in  our  share  register  or  by  a  duly  appointed  proxy  of  a  registered  shareholder  (including  the
independent proxy), which proxy need not be a shareholder. Our Articles of Association do not limit the number of
shares that may be voted by a single shareholder. Shareholders wishing to exercise their voting rights who hold their
shares through a bank, broker or other nominee should follow the instructions provided by such bank, broker or other
nominee  or,  absent  instructions,  contact  such  bank,  broker  or  other  nominee  for  instructions.  Shareholders  holding
their shares through a bank, broker or other nominee will not automatically be registered in our share register. If any
such  shareholder  wishes  to  be  registered  in  our  share  register,  such  shareholder  should  contact  the  bank,  broker  or
other nominee through which it holds our shares.

Treasury shares, whether owned by us or one of our majority-owned subsidiaries, will not be entitled to vote at general
meetings of shareholders.

Our Articles of Association do not provide for cumulative voting for the election of directors.

Pursuant to our Articles of Association, the shareholders generally pass resolutions by the affirmative vote of a relative
majority of the votes cast at the general meeting of shareholders (broker nonvotes, abstentions and blank and invalid
ballots will be disregarded), unless otherwise provided by law or our Articles of Association. However, our Articles of
Association provide that directors may be elected at a general meeting of shareholders by a plurality of the votes cast
by  the  shareholders  present  in  person  or  by  proxy  at  the  meeting.  Our  Corporate  Governance  Guidelines  have  a
majority vote policy that provides that the board may nominate only those candidates for director who have submitted
an irrevocable letter of resignation which would be effective upon and only in the event that (1) such nominee fails to
receive  a  sufficient  number  of  votes  from  shareholders  in  an  uncontested  election  and  (2)  the  board  accepts  the
resignation following such failure. If a nominee who has submitted such a letter of resignation does not receive more
votes cast “for” than “against” the nominee’s election, the corporate governance committee must promptly review the
letter  of  resignation  and  recommend  to  the  board  whether  to  accept  the  tendered  resignation  or  reject  it.  The  board
must  then  act  on  the  corporate  governance  committee’s  recommendation  within  90  days  following  the  shareholder
vote. The board must promptly disclose its decision regarding whether or not to accept the nominee’s resignation letter.

The  acting  chair  may  direct  that  resolutions  and  elections  be  held  by  use  of  an  electronic  voting  system.  Electronic
resolutions  and  elections  are  considered  equal  to  resolutions  and  elections  taken  by  way  of  a  written  ballot.  In
accordance with the Swiss Federal Council Ordinance 3 of June 19, 2020, on Measures to Combat the Coronavirus, as
amended, we may, regardless of the number of shareholders attending the general meeting of shareholders and without
complying with the 20-calendar day period for convening general meetings, restrict the personal attendance

of  shareholders  at  a  general  meeting  of  shareholders  and  request  shareholders  to  exercise  their  voting  rights
exclusively  (i)  in  writing  or  electronically  or  (ii)  through  our  independent  proxy.  We  must  give  notice  to  our
shareholders  of  any  such  restriction  no  later  than  four  calendar  days  before  the  date  of  the  general  meeting  of
shareholders.

The  Swiss  Code  and/or  our  Articles  of  Association  require  the  affirmative  vote  of  at  least  two-thirds  of  the  voting
rights and a majority of the par value of the shares, each as represented at a general meeting to approve, among other
things, the following matters:

●

●

●

●

● the amendment to or the modification of the purpose clause in our Articles of

Association;

● the creation or cancellation of shares with privileged voting rights;

● the restriction on the transferability of shares or cancellation thereof;

● the restriction on the exercise of the right to vote or the cancellation thereof;

● an authorized or conditional increase in the share capital;

● an  increase  in  the  share  capital  through  (1)  the  conversion  of  capital  surplus,  (2)  a
contribution in kind, or for purposes of an acquisition of assets, or (3) a grant of special
privileges;

● the limitation on or withdrawal of preemptive rights;

● a change in our registered office;

● the conversion of registered shares into bearer shares and vice versa; and

● our dissolution.

●

●

●

●

●

The same supermajority voting requirements apply to resolutions in relation to transactions among corporations based
on Switzerland’s Federal Act on Mergers, Demergers, Transformations and the Transfer of Assets and Liabilities (the
“Merger Act”), including a merger, demerger or conversion of a corporation (other than a cash-out or certain squeeze-
out mergers, in which minority shareholders of the company being acquired may be compensated in a form other than
through shares of the acquiring company, for instance, through cash or securities of a parent company of the acquiring
company or of another company—in such a merger, an affirmative vote of 90% of the outstanding shares is required).
Swiss law may also impose this supermajority voting requirement in connection with the sale of “all or substantially
all of our assets” by us. See “—Compulsory Acquisitions; Appraisal Rights” below.

Our Articles of Association require the affirmative vote of at least two-thirds of the shares entitled to vote at a general
meeting to approve the following matters:

● the removal of a serving member of the board of directors;

● any changes to Article 14, paragraph 1 specifying advance notice of proposal requirements;

● any changes to Article 18 specifying vote requirements for resolutions and elections;

● any changes to Article 20, paragraph 2 specifying supermajority vote requirements;

● any changes to Article 21 specifying quorum requirements;

● any changes to Article 22 specifying the number of members of the board of directors;

● any changes to Article 23 specifying the term of the board of directors; and

● any changes to Article 24 specifying the organization of the board of directors and the indemnification

provisions for directors and officers.

Our Articles of Association require the affirmative vote of holders of the number of our shares at least equal to the sum
of (A) two-thirds of the number of all shares outstanding and entitled to vote at a general meeting, plus (B) a number
of shares outstanding and entitled to vote at the general meeting that is equal to one-third of the number of shares held
by  an  interested  shareholder,  for  us  to  engage  in  any  business  combination  with  an  interested  shareholder  (as  those
terms  are  defined  in  our  Articles  of  Association)  and  for  the  amendment  of  the  provisions  in  our  Articles  of
Association relating to this shareholder approval requirement.

Quorum for General Meetings

The presence of shareholders, in person or by proxy, holding at least a majority of the shares entitled to vote at the time
when the general meeting proceeds to business is generally the required presence for a quorum for the transaction of
business at a general meeting of shareholders. However, the presence of shareholders, in person or by proxy, holding at
least two-thirds of the share capital recorded in the commercial register at the time when the general meeting proceeds
to  business  is  the  required  presence  for  a  quorum  to  adopt  a  resolution  to  amend,  vary,  suspend  the  operation  of  or
cause any of the following provisions of our Articles of Association to cease to apply:

● Article 18—which relates to proceedings and procedures at general meetings;

● Article 19(g)—which relates to business combinations with interested shareholders;

● Article 20—which sets forth the level of shareholder approval required for certain matters;

● Article 21—which sets forth the quorum at a general meeting required for certain matters, including the

removal of a serving member of the board of directors; and

● Articles 22, 23 and 24—which relate to the size and the organization of the board of directors, the term of

directors and the indemnification provisions for directors and officers.

Additionally, shareholders present, in person or by proxy, holding at least two-thirds of the share capital recorded in
the commercial register at the time when the general meeting proceeds to business constitute the required presence for
a quorum at a general meeting to adopt a resolution to remove a serving director.

Under the Swiss Code, the board of directors has no authority to waive quorum requirements stipulated in the Articles
of Association.

Inspection of Books and Records

Under the Swiss Code, a shareholder has a right to inspect the share register with regard to his, her or its own shares
and  otherwise  to  the  extent  necessary  to  exercise  his,  her  or  its  shareholder  rights.  No  other  person  has  a  right  to
inspect  the  share  register.  The  books  and  correspondence  of  a  Swiss  company  may  be  inspected  with  the  express
authorization  of  the  general  meeting  of  shareholders  or  by  resolution  of  the  board  of  directors  and  subject  to  the
safeguarding of the company’s business secrets. At a general meeting of shareholders, any shareholder is entitled to
request information from the board of directors concerning the affairs of the company. Shareholders may also ask the
auditor questions regarding its audit of the company. The board of directors and the auditor must answer shareholders’
questions to the extent necessary for the exercise of shareholders’ rights and subject to prevailing business secrets or
other of our material interests.

Special Investigation

If the shareholders’ inspection and information rights as outlined above prove to be insufficient, any shareholder may
propose  to  the  general  meeting  of  shareholders  that  a  special  commissioner  investigate  specific  facts  in  a  special
investigation.  If  the  general  meeting  of  shareholders  approves  the  proposal,  we  or  any  shareholder  may,  within  30
calendar days after the general meeting of shareholders, request the court at our registered office to appoint a special
commissioner. If the general meeting of shareholders rejects the request, one or more shareholders representing at least
10% of the share capital or holders of shares in an aggregate par value of at least 2 million Swiss francs may request,
within three months after the general meeting, the court to appoint a special commissioner. The court will issue such an
order if the petitioners can demonstrate prima facie that the board of directors, any member of our board of directors or
one  of  our  officers  infringed  the  law  or  our  Articles  of  Association  and  thereby  damaged  the  company  or  the
shareholders.  The  costs  of  the  investigation  would  generally  be  allocated  to  us  and  only  in  exceptional  cases  to  the
petitioners.

Compulsory Acquisitions; Appraisal Rights

Swiss companies that undertake business combinations and other transactions that are binding on all shareholders are
governed  by  the  Merger  Act.  A  statutory  merger  or  demerger  requires  that  at  least  two-thirds  of  the  shares  and  a
majority of the par value of the shares, each as represented at the general meeting of shareholders, vote in favor of the
transaction. Under the Merger Act, a “demerger” may take two forms:

● a  legal  entity  may  divide  all  of  its  assets  and  transfer  such  assets  to  other  legal  entities,  with  the
shareholders  of  the  transferring  entity  receiving  equity  securities  in  the  acquiring  entities  and  the
transferring entity dissolving upon deregistration in the commercial register; or

● a legal entity may transfer all or a portion of its assets to other legal entities, with the shareholders of the

transferring entity receiving equity securities in the acquiring entities.

If a transaction under the Merger Act receives all of the necessary consents, all shareholders would be compelled to
participate in the transaction. See “—Voting” above.

Swiss  companies  may  be  acquired  by  an  acquirer  through  the  direct  acquisition  of  the  share  capital  of  the  Swiss
company.  With  respect  to  corporations  limited  by  shares,  such  as  Transocean,  the  Merger  Act  provides  for  the
possibility of a so-called “cash-out” or “squeeze-out” merger if the acquirer controls 90% of the outstanding shares. In
these  limited  circumstances,  minority  shareholders  of  the  company  being  acquired  may  be  compensated  in  a  form
other than through shares of the acquiring company (for instance, through cash or securities of a parent company of the
acquiring company or of another company). For business combinations effected in the form of a statutory merger or
demerger  and  subject  to  Swiss  law,  the  Merger  Act  provides  that  if  the  equity  rights  have  not  been  adequately
preserved  or  compensation  payments  in  the  transaction  are  unreasonable,  a  shareholder  may  request  the  competent
court to determine a reasonable amount of compensation.

In addition, under Swiss law, the sale of “all or substantially all of our assets” by us may require a resolution of the
general meeting of shareholders passed by holders of at least two-thirds of the voting rights and a majority of the par
value of the shares, each as represented at the general meeting of shareholders. Whether or not a shareholder resolution
is required depends on the particular transaction, including whether the following test is satisfied:

● the  company  sells  a  core  part  of  its  business,  without  which  it  is  economically  impracticable  or

unreasonable to continue to operate the remaining business;

● the company’s assets, after the divestment, are not invested in accordance with the company’s statutory

business purpose; and

● the  proceeds  of  the  divestment  are  not  earmarked  for  reinvestment  in  accordance  with  the  company’s
business  purpose  but,  instead,  are  intended  for  distribution  to  shareholders  or  for  financial  investments
unrelated to the company’s business.

If all of the foregoing apply, a shareholder resolution would likely be required.

Legal Name; Formation; Fiscal Year; Registered Office

Transocean was initially formed on August 18, 2008. It is incorporated and domiciled in Steinhausen, Canton of Zug,
Switzerland, and operates under the Swiss Code as a stock corporation (Aktiengesellschaft). Transocean is recorded in
the  Commercial  Register  of  the  Canton  of  Zug  with  the  registration  number  CHE-114.461.224.  Transocean’s  fiscal
year is the calendar year.

The address of Transocean’s registered office is Transocean, Turmstrasse 30, 6312 Steinhausen, Switzerland, and the
telephone number at that address is +41 (0)41 749 0500.

Corporate Purpose

Transocean is the parent holding company of the Transocean group. Pursuant to its Articles of Association, its business
purpose  is  to  acquire,  hold,  manage,  exploit  and  sell,  whether  directly  or  indirectly,  participations  in  businesses  in
Switzerland and abroad, in particular in businesses that are involved in offshore contract drilling services for oil and
gas  wells,  oil  and  gas  drilling  management  services,  drilling  engineering  services  and  drilling  project  management
services and oil and gas exploration and production activities, and to provide financing for this purpose. Transocean
may acquire, hold, manage, mortgage and sell real estate and intellectual property rights in Switzerland and abroad.

Duration and Liquidation

Our  Articles  of  Association  do  not  limit  our  duration.  Under  Swiss  law,  we  may  be  dissolved  at  any  time  by  a
resolution adopted at a general meeting of shareholders, which must be passed by the affirmative vote of holders of at
least two thirds of voting rights and an absolute majority of the par value of the shares, each as represented (in person
or by proxy) at the general meeting. Dissolution and liquidation by court order is possible if (1) we become bankrupt
or (2) shareholders holding at least 10% of our share capital so request for valid reasons. Under Swiss law, any surplus
arising out of liquidation (after the settlement of all claims of all creditors) is distributed in proportion to the paid-up
par value of shares held. The amount exceeding the par value of the share is subject to Swiss withholding tax of 35%.
Our shares carry no privilege with respect to such liquidation surplus.

Uncertificated Shares

Our shares have been issued in uncertificated form in accordance with article 973c of the Swiss Code as uncertificated
securities, which have been registered with Computershare, and constitute intermediated securities within the meaning
of  the  Swiss  Federal  Act  on  Intermediated  Securities.  In  accordance  with  article  973c  of  the  Code,  Transocean
maintains a register of uncertificated securities (Wertrechtebuch).

Stock Exchange Listing

Our shares are listed and trade on the NYSE under the symbol “RIG.”

No Sinking Fund

The shares have no sinking fund provisions.

No Liability for Further Calls or Assessments

The shares that have been issued to date are duly and validly issued, fully paid and nonassessable.

No Redemption and Conversion

The  shares  are  not  convertible  into  shares  of  any  other  class  or  series  or  subject  to  redemption  either  by  us  or  the
holder of the shares.

Transfer and Registration of Shares

We  have  not  imposed  any  restrictions  applicable  to  the  transfer  of  our  shares,  other  than  the  requirement  that  an
acquirer of shares expressly declares to have acquired the shares in its own name and for its own account. Our share
register  is  maintained  by  Computershare,  which  acts  as  transfer  agent  and  registrar.  The  share  register  reflects  only
record owners of our shares. Swiss law does not recognize fractional share interests.

Description of the 2023 Exchangeable Bonds

The following description of the Exchangeable Bonds is a summary and does not purport to be complete. It is subject
to, and qualified by reference to, all of the provisions of the Exchangeable Bonds and the indenture among Transocean
Inc. (“TINC”),  as  issuer,  Transocean  Ltd.  (“Transocean”),  as  guarantor,  and  Computershare  Trust  Company,  N.A.
and  Computershare  Trust  Company  of  Canada,  as  co-trustees,  dated  January  30,  2018  (the  “indenture”).  We
encourage you to read the indenture for additional information. In this summary, “we,” “our” and “us” means TINC,
as issuer of the Exchangeable Bonds, and “guarantor” means Transocean, as guarantor of the Exchangeable Bonds,
unless, in each case, we indicate otherwise or the context indicates otherwise.

General

The  Exchangeable  Bonds  are  our  general  unsecured  and  senior  obligations,  and  are  exchangeable  into  Transocean’s
Shares  as  described  under  “—Exchange  Rights”  below.  The  Exchangeable  Bonds  are  fully  and  unconditionally
guaranteed on a senior unsecured basis by the guarantor. The Exchangeable Bonds will mature on January 30, 2023.

The  Exchangeable  Bonds  pay  cash  interest  at  an  annual  rate  of  0.5%  on  the  principal  amount  of  the  Exchangeable
Bonds  to,  but  excluding,  the  next  scheduled  interest  payment  date  until  January  30,  2023.  Interest  is  payable  semi-
annually  in  arrears  on  January  30  and  July  30  of  each  year,  to  holders  of  record  at  the  close  of  business  on  the
preceding January 15 and July 15, respectively. Accrued interest is computed on the basis of a 360-day year composed
of twelve 30-day months. In the event of the repurchase by us at the option of the holder of an Exchangeable Bond,
interest ceases to accrue on the Exchangeable Bonds under the terms of and subject to the conditions of the indenture.

Any  amounts  on  the  Exchangeable  Bonds  that  are  payable  but  not  punctually  paid  or  provided  for  (“defaulted
amounts”) will cease to be payable to the holder of the Exchangeable Bonds on the relevant payment date but will
accrue interest per annum at the rate borne by the Exchangeable Bonds, subject to applicable law, from, and including,
the relevant payment date. We may elect to pay the defaulted amounts and any interest accrued (i) to the holders of the
Exchangeable Bonds as of the close of business on a special record date, which will be not more than 15 days and not
less  than  10  days  prior  to  the  date  of  our  proposed  payment  of  such  defaulted  amounts  or  (ii)  in  any  other  lawful
manner not inconsistent with the requirements of the New York Stock Exchange, or any other securities exchange or
automated quotation system on which the Exchangeable Bonds may be listed or designated for trading.

The indenture does not contain any financial covenants or any restrictions on the payment of dividends, the making of
investments,  the  incurrence  of  indebtedness,  the  granting  of  liens  or  mortgages,  or  the  issuance  or  repurchase  of
securities  by  us.  The  indenture  does  not  contain  any  covenants  or  other  provisions  to  protect  holders  of  the
Exchangeable  Bonds  in  the  event  of  a  highly  leveraged  transaction  or  a  fundamental  change,  except  to  the  extent
described under “—Exchange Rights—Increased Exchange Rate in Connection with Fundamental Changes” and “—
Repurchase Rights Following Fundamental Change or Tax Event” below.

As of February 16, 2022, $139,750,000 aggregate principal amount of Exchangeable Bonds were outstanding.

The  Exchangeable  Bonds  are  not  be  subject  to  a  sinking  fund  provision  and  are  not  be  subject  to  defeasance  or
covenant defeasance under the indenture.

Guarantee

Our obligations under the indenture, including the repurchase obligations resulting from a fundamental change or tax
event, are fully and unconditionally guaranteed, on a senior unsecured basis by the guarantor.

The guarantor’s obligations under the guarantee are limited to the maximum amount as, after giving effect to all other
contingent  and  fixed  liabilities  of  the  guarantor,  will  result  in  the  guarantor’s  obligation  under  the  guarantee  not
constituting  a  fraudulent  transfer  or  conveyance  for  purposes  of  any  Bankruptcy  Law,  the  Uniform  Fraudulent
Conveyance Act, the Uniform Fraudulent Transfer Act or any similar federal or state law.

The  Exchangeable  Bonds  are  not  obligations  of,  or  guaranteed  by,  any  of  our  or  the  guarantor’s  existing  or  future
subsidiaries.

Ranking/Additional Debt

The Exchangeable Bonds are our general unsecured obligations and rank:

(1) senior in right of payment to all of our existing and future subordinated indebtedness;

(2) equal in right of payment with all of our existing and future unsecured senior indebtedness;

(3)  effectively  junior  in  right  of  payment  to  all  of  our  existing  and  future  secured  indebtedness  to  the  extent  of  the
value of the assets securing such indebtedness; and

(4) structurally subordinated to all secured and unsecured liabilities of our subsidiaries.

The  guarantee  is  a  senior  unsecured  obligation  of  the  guarantor  and  will  rank  equally  in  right  of  payment  with  the
guarantor’s other senior unsecured indebtedness from time to time outstanding.

The indenture does not limit the amount of debt that we or any of our subsidiaries may incur or issue, and it does not
restrict  transactions  between  us  and  our  affiliates  or  dividends  and  other  distributions  by  us  or  our  subsidiaries.  As
described under “—General,” we may issue additional Exchangeable Bonds under the indenture from time to time.

Exchange Rights

General

Unless  the  Exchangeable  Bonds  are  previously  repurchased,  holders  may  exchange  their  Exchangeable  Bonds  for
Shares  at  any  time  prior  to  the  close  of  business  on  the  business  day  immediately  preceding  the  maturity  date.  The
initial  exchange  rate  of  the  Exchangeable  Bonds  is  97.29756  Shares  per  $1,000  principal  amount  of  Exchangeable
Bonds. The exchange rate is subject to change as described below under “—Increased Exchange Rate in Connection
with a Fundamental Change,” “—Increased Exchange Rate in Connection with a Tax Event” and “—Exchange Rate
Adjustments.” A holder may exchange fewer than all of such holder’s Exchangeable Bonds so long as the portion of
Exchangeable Bonds exchanged is an integral multiple of $1,000 principal amount.

We  will  satisfy  our  exchange  obligation  through  delivery  by  the  guarantor  of  the  Shares.  See  “—Settlement  Upon
Exchange.” Upon exchange of an Exchangeable Bond, a holder will not receive any cash payment of interest (unless
such  exchange  occurs  between  a  regular  record  date  and  the  interest  payment  date  to  which  it  relates  and  the
exchanging  holder  held  the  Exchangeable  Bonds  on  that  record  date),  and  we  will  not  adjust  the  exchange  rate  to
account for accrued and unpaid interest. Accordingly, any accrued but unpaid interest will be deemed to be paid in full
upon exchange, rather than cancelled, extinguished or forfeited.

Holders  of  Exchangeable  Bonds  at  the  close  of  business  on  a  regular  record  date  will  receive  payment  of  interest
payable on the corresponding interest payment date notwithstanding the exchange of such Exchangeable Bonds at any
time after the close of business on the applicable regular record date. Exchangeable Bonds surrendered for exchange
by a holder after the close of business on any regular record date but prior to the next interest payment date must be
accompanied  by  payment  of  an  amount  equal  to  the  interest  that  the  holder  on  the  record  date  is  to  receive  on  the
Exchangeable Bonds; provided, however, that no such payment need be made (1) for exchanges following the regular
record date immediately preceding the maturity date, (2) if we have specified a repurchase date following a tax event
or fundamental change that is after a record date and on or prior to the next interest payment date or (3) only to the

extent  of  overdue  interest,  if  any  overdue  interest  exists  at  the  time  of  exchange  with  respect  to  such  Exchangeable
Bonds. No other payments or adjustments for interest will be made upon exchange.

Holders of the Shares issuable upon exchange, if any, will not be entitled to receive any dividends payable to holders
of  the  Shares  as  of  any  record  time  or  date  before  such  Shares  are  delivered  to  the  holder  upon  exchange  of  such
holder’s Exchangeable Bonds.

If a holder has already delivered a repurchase notice as described under “—Repurchase Rights Following Fundamental
Change or Tax Event” with respect to an Exchangeable Bond, the holder may not surrender that Exchangeable Bond
for exchange until the holder has withdrawn the repurchase notice in accordance with the indenture.

Settlement Upon Exchange

To  exchange  the  Exchangeable  Bonds,  a  holder  of  Exchangeable  Bonds  in  certificated  form  must  deliver  an
irrevocable, duly completed exchange notice, together with the certificated security, to the exchange agent along with
appropriate endorsements and transfer documents, if required, and pay any interest and transfer or similar tax, in each
case, if required, and a holder of Exchangeable Bonds in global form must comply with the applicable procedures of
the depositary in effect at the time and pay any interest and transfer or similar tax, in each case, if required. The date a
holder  satisfies  these  requirements  is  called  the  “exchange  date.”  The  form  of  exchange  notice  is  attached  to  the
indenture.

Delivery of the Shares upon exchange will be accomplished by book-entry transfer of the required number of Shares
through The Depository Trust Company, New York, New York (“DTC”). The trustee will initially act as the exchange
agent.

Upon exchange of the Exchangeable Bonds, a holder will receive, for each $1,000 principal amount of Exchangeable
Bonds exchanged, the Shares at the exchange rate in effect on the exchange date. Cash will be delivered in lieu of any
fractional shares. Settlement will occur through the exchange agent on the third business day following the exchange
date (or, if the exchange is in connection with a fundamental change, on the fifth business day following the exchange
date).

The guarantor’s delivery to the holder of the Shares and any cash, if applicable, in settlement as described above will
satisfy our exchange obligation.

Increased Exchange Rate in Connection with a Fundamental Change

If the effective date of any fundamental change occurs prior to the maturity date, and a holder elects to exchange its
Exchangeable  Bonds  during  the  period  commencing  on  such  effective  date  and  ending  on  the  business  day
immediately before the fundamental change repurchase date (the “fundamental change period”), then the guarantor
will increase the exchange rate for the Exchangeable Bonds surrendered for exchange as described below.

We  will  notify  holders  of  any  such  fundamental  change  and  the  anticipated  effective  date  in  accordance  with  the
procedures outlined in the indenture and described in “—Repurchase Rights Following Fundamental Change or Tax
Event” below.

The increased exchange rate applicable to any exchange in connection with a fundamental change due to a change of
control will be determined as follows:

COCER

COCER

OER

EP

c

= OER x (1 +(EP x (c/t))), where

= change of control exchange rate

= exchange rate otherwise applicable, before giving effect to increase

= 22.50%

= the  number  of  days  from  and  including  the  date  of  the  change  of  control  to  but  excluding  the

maturity date

t

= the number of days from and including the issue date to but excluding the maturity date

Notwithstanding the foregoing, the increased exchange rate applicable to any exchange in connection with a
fundamental change due to a listing failure event will be determined as follows:

LFER

LFER

OER

EP

c

t

= OER x (1 +(EP x (c/t))), where

= listing failure event exchange rate

= exchange rate otherwise applicable, before giving effect to increase

= 22.50%

= the  number  of  days  from  and  including  the  date  of  the  listing  failure  event  to  but  excluding  the

maturity date

= the number of days from and including the issue date to but excluding the maturity date

For  the  avoidance  of  doubt,  if  a  holder  exchanges  its  Exchangeable  Bonds  prior  to  the  fundamental  change  period,
then, whether or not such fundamental change occurs, the holder will not be entitled to an increased exchange rate in
connection with such fundamental change.

A  “fundamental  change”  will  be  deemed  to  have  occurred  at  such  time  after  the  original  issuance  of  the
Exchangeable Bonds when any of the following has occurred:

● a change of control event; or

● a listing failure event.

“Change of control” means the occurrence of any of the following:

A. the sale, lease, transfer, conveyance or other disposition (other than by way of merger, amalgamation or statutory
plan of arrangement or consolidation), in one or a series of related transactions, of all or substantially all of our and our
subsidiaries’ or the guarantor’s and its subsidiaries’ assets, in each case taken as a whole, to any “person” or “group”
(as such terms are used in Sections 13(d) and 14(d) of the Exchange Act) other than to us, the guarantor or one of the
guarantor’s other subsidiaries;

B. the consummation of any transaction (including, without limitation, any merger, amalgamation or statutory plan of
arrangement or consolidation) the result of which is that any “person” or “group” (as such terms are used in Sections
13(d) and 14(d) of the Exchange Act) becomes the beneficial owner (as defined in Rules 13d-3 and 13d-5 under the
Exchange Act), directly or indirectly, of more than 50% of the combined voting power of the guarantor’s or our voting
stock or other voting stock into which the guarantor’s or our voting stock is reclassified, consolidated, exchanged or
changed, measured by voting power rather than number of shares;

C. we or the guarantor consolidate, amalgamate, or enter into a statutory plan of arrangement with, or merge with or
into,  any  “person”  (as  that  term  is  used  in  Section  13(d)(3)  of  the  Exchange  Act),  or  any  person  consolidates,
amalgamates, or enters into a statutory plan of arrangement with, or merges with or into, us or the guarantor, in any
such event pursuant to a transaction in which any of the guarantor’s, our or of such other person’s outstanding voting
stock is converted into or exchanged for cash, securities or other property, other than any such transaction where the
shares  of  our  or  the  guarantor’s  voting  stock  outstanding  immediately  prior  to  such  transaction  constitute,  or  are
converted  into  or  exchanged  for,  voting  stock  representing  more  than  50%  of  the  combined  voting  power  of  the
surviving person immediately after giving effect to such transaction; or

D. the adoption of a plan relating to the guarantor’s or our liquidation or dissolution.

Notwithstanding the foregoing, any holding company whose only significant asset is our capital stock or any of our
direct or indirect parent companies will not itself be considered a “person” or “group” for purposes of clause B above.
Further, notwithstanding the foregoing, no change of control of the guarantor will be deemed to have occurred if at
least  90%  of  the  consideration  for  the  Shares  (excluding  cash  payments  for  fractional  shares)  in  the  transaction  or
transactions otherwise constituting a change of control in respect of the guarantor consist of common stock, ordinary

shares,  American  Depositary  Receipts  or  equivalent  capital  stock  traded  on  the  New  York  Stock  Exchange,  The
NASDAQ Global Select Market or The NASDAQ Global Market, or any successor to any such market, or which will
be  so  traded  when  issued  or  exchanged  in  connection  with  the  transaction  or  transactions  otherwise  constituting  a
change  of  control  in  respect  of  the  guarantor,  and  as  a  result  of  such  transaction  or  transactions,  the  Exchangeable
Bonds  become  exchangeable,  upon  the  conditions  for  exchange  and  actual  exchange  in  accordance  with  the  terms
hereof, into such common stock, ordinary shares, American Depositary Receipts or equivalent capital stock.

“Change of control event” means (a) in the case of a change of control in respect of us, on any date during the 60-day
period (which period will be extended so long as the rating of the Exchangeable Bonds is under publicly announced
consideration  for  a  possible  downgrade  by  any  of  the  rating  agencies  (as  defined  in  the  indenture))  (the  “trigger
period”)  after  the  earlier  of  (1)  the  occurrence  of  a  change  of  control;  or  (2)  public  notice  of  the  occurrence  of  a
change of control or the intention by us to effect a change of control, (i) in the event the Exchangeable Bonds are rated
investment  grade  by  at  least  two  of  the  rating  agencies  prior  to  such  public  notice,  the  rating  of  the  Exchangeable
Bonds by any rating agency shall be below investment grade, (ii) in the event the Exchangeable Bonds are rated below
Investment  Grade  by  at  least  two  of  the  rating  agencies  prior  to  such  public  notice,  the  rating  of  the  Exchangeable
Bonds by any rating agency will be decreased by one or more categories or (iii) the Exchangeable Bonds will not be,
or cease to be, rated by at least one of the rating agencies; provided that, in each case, such event is in whole or in part
in  connection  with  the  change  of  control  and  (b)  in  the  case  of  a  change  of  control  in  respect  of  the  guarantor,  the
effective date of such change of control. Notwithstanding the foregoing, no Change of Control Event will be deemed to
have  occurred  in  connection  with  any  particular  Change  of  Control  unless  and  until  such  Change  of  Control  has
actually been consummated.

A “listing  failure  event”  will  be  deemed  to  have  occurred  at  the  time  after  the  Exchangeable  Bonds  are  originally
issued  if  the  Shares  (or  any  other  ordinary  shares,  common  shares  or  American  depositary  shares  underlying  the
Exchangeable Bonds) cease to be listed or quoted on any of The New York Stock Exchange, The NASDAQ Global
Select Market or The NASDAQ Global Market (or any of their respective successors) and are not listed or quoted on
one of The New York Stock Exchange, The NASDAQ Global Select Market or The NASDAQ Global Market (or any
of their respective successors) concurrently with such cessation.

Increased Exchange Rate in Connection with a Tax Event

If  a  tax  event  occurs  prior  to  the  maturity  date,  and  a  holder  elects  to  exchange  its  Exchangeable  Bonds  during  the
period commencing on such effective date and ending on the day before the tax event repurchase date (the “tax event
repurchase period”), then the guarantor will increase the exchange rate for the Exchangeable Bonds surrendered for
exchange, as described below.

We will notify holders of any such tax event in accordance with the procedures outlined in the indenture and described
in  “—Fundamental  Change  or  Tax  Event  Requires  Us  to  Repurchase  Exchangeable  Bonds  at  the  Option  of  the
Holder” below.

The increase exchange rate applicable to any exchange in connection with a tax event will be determined as follows:

TEER

TEER

OER

EP

c

t

= OER x (1 +(EP x (c/t))), where

= tax event exchange rate

= exchange rate otherwise applicable, before giving effect to increase

= 22.50%

= the number of days from and including the date of the tax event to but excluding the maturity date

= the number of days from and including the issue date to but excluding the maturity date

For the avoidance of doubt, if a holder exchanges its Exchangeable Bonds prior to the tax event repurchase period,
then, whether or not such tax event occurs, the holder will not be entitled to an increased exchange rate in connection
with such tax event.

A “tax event” will be deemed to have occurred if, at any time after the Exchangeable Bonds are originally issued, (x)
we reasonably determine that (A) as a result of (I) any change in or amendment to the laws or treaties (or any

regulations or rulings promulgated thereunder) of any taxing jurisdiction (as defined below), or (II) any change in the
official  position  regarding  the  application  or  interpretation  of  such  laws,  treaties,  regulations  or  rulings  by  any
legislative body, court, governmental agency or regulatory authority, which change or amendment becomes effective
on  or  after  (1)  the  issue  date,  in  the  case  of  the  Cayman  Islands  or  Switzerland,  or  (2)  the  date  such  jurisdiction
becomes a taxing jurisdiction, in the case of any other taxing jurisdiction, we, the guarantor or any such successor, as
applicable,  have  or  will  become  obligated  to  pay,  on  the  next  succeeding  date  on  which  interest  is  due,  additional
amounts pursuant to the indenture with respect to any of the Exchangeable Bonds; or (B) on or after (1) the issue date,
in the case of the Cayman Islands or Switzerland, or (2) the date such jurisdiction becomes a taxing jurisdiction, in the
case of any other taxing jurisdiction, any action has been taken by any taxing authority of, or any decision has been
rendered by a court of competent jurisdiction in a taxing jurisdiction, including any of those actions specified in (A)
above, whether or not such action was taken or such decision was rendered with respect to us, the guarantor or any
such  successor,  as  applicable,  or  any  change,  amendment,  application  or  interpretation  will  be  officially  proposed,
which in any case, in an opinion of counsel, will result in us, the guarantor or any such successor becoming obligated
to  pay,  on  the  next  succeeding  date  on  which  interest  is  due,  additional  amounts  with  respect  to  any  of  the
Exchangeable Bonds, and, in any such case, we or the guarantor, as applicable, in our business judgment, determine
that such obligation cannot be avoided by the use of reasonable measures available to us or the guarantor; and (y) we
provide notice to all holders of the Exchangeable Bonds and the trustee and the paying agent no less than 20, and no
more than 60, days prior to the earliest date on which we or the guarantor would be obligated to withhold tax resulting
from the amendment or change described in (A) or (B) above were a payment in respect of the Exchangeable Bonds
then due that we are designating such amendment or change as a tax event.

We are not obligated to designate any event as a tax event. As a result, any development described in clause (x) of the
preceding paragraph will not constitute a tax event unless we elect, at our option, to designate it as such. If we declare
a tax event, however, and a tax event offer to repurchase pursuant to the indenture, neither we nor the guarantor will
thereafter be required to pay related additional amounts in respect of the Exchangeable Bonds. See “—Tax Additional
Amounts.”

Exchange Rate Adjustments

The  exchange  rate  will  be  adjusted  for  certain  events,  as  described  below,  except  that  we  will  not  make  any
adjustments to the exchange rate if holders of Exchangeable Bonds have the right to participate (other than in the case
of a share split or share combination or a tender or exchange offer), as a result of holding the Exchangeable Bonds, in
any of the transactions described below without having to exchange their Exchangeable Bonds:

(1) If the guarantor exclusively issues the Shares as a dividend or distribution on the Shares, or effects a subdivision or
combination of the outstanding Shares, the exchange rate will be adjusted based on the following formula:

ER’ = ER0
x

OS’
OS0

ER0

ER’

OS0

OS

= the  exchange  rate  in  effect  immediately  prior  to  the  close  of  business  on  the  record
date of such dividend or distribution, or immediately prior to the open of business on
the date of the subdivision or combination

= the exchange rate in effect immediately after the close of business on such record date

or date of subdivision or combination

= the  number  of  Shares  outstanding  immediately  prior  to  such  subdivision  or

combination

= the  number  of  Shares  that  would  be  outstanding  immediately  after  giving  effect  to

such dividend, distribution, subdivision or combination

Any adjustment made under this paragraph (1) will become effective immediately after the close of business on the
record date for such dividend or distribution, or immediately after the open of business on the date for such subdivision
or combination, as applicable. If any dividend or distribution of the type described in this paragraph (1) is declared but
not so paid or made, the exchange rate will be immediately readjusted, effective as of the date the guarantor’s board of
directors determines not to pay such dividend or distribution, to the exchange rate that would then be in effect if such
dividend or distribution had not been declared.

(2)  If  the  guarantor  issues  to  all  or  substantially  all  holders  of  the  Shares,  rights,  options  or  warrants  (other  than  in
connection with a shareholder rights plan) that allow such holders, for a period ending not more than 45 days after the
announcement date of such issuance, to subscribe for or purchase the Shares at a price per Share that is less than the
average of the last reported sale prices of the Shares for the ten consecutive trading days ending on the business day
immediately  preceding  the  announcement  date  of  such  issuance,  the  exchange  rate  will  be  adjusted  based  on  the
following formula:

ER’ = ER0 x

where,

OS0 + X
OS0 + Y

ER0

ER’
OS0

X

Y

= the  exchange  rate  in  effect  immediately  prior  to  the  close  of  business  on  the  record

date for such issuance

= the exchange rate in effect immediately after the close of business on such record date

= the number of Shares outstanding immediately prior to the close of business on such

record date

= the total number of Shares issuable pursuant to such rights, options or warrants

the  number  of  Shares  equal  to  the  aggregate  price  payable  to  exercise  such  rights,
options  or  warrants  divided  by  the  average  of  the  last  reported  sale  prices  of  the
Shares  for  the  ten  consecutive  trading  days  ending  on  the  trading  day  immediately
preceding the announcement of the issuance of such rights, options or warrants

Any  increase  made  under  this  paragraph  (2)  will  become  effective  immediately  after  the  close  of  business  on  the
record date for such issuance. To the extent that the Shares are not delivered after the expiration of such rights, options
or warrants, the exchange rate will be decreased to be the exchange rate that would then be in effect had the increase
with respect to the issuance of such rights, options or warrants been made on the basis of delivery of only the number
of Shares actually delivered. If such rights, options or warrants are not so issued, the exchange rate will be decreased to
the exchange rate that would then be in effect if such record date for such issuance had not occurred.

(3) If the guarantor distributes the Shares, evidences of its indebtedness, other assets or property of the guarantor or
rights,  options  or  warrants  to  acquire  the  Shares  or  other  securities,  to  all  or  substantially  all  holders  of  the  Shares,
excluding (i) dividends, distributions or issuances as to which an adjustment was effected as described in paragraphs
(1)  or  (2)  above,  (ii)  dividends  or  distributions  paid  exclusively  in  cash  as  to  which  an  adjustment  was  effected  as
described in paragraph (4) below, and (iii) spin-offs (as defined below) as to which the provisions set forth below in
this paragraph (3) apply (any of such Shares, evidences of indebtedness, other assets or property or rights, options or
warrants  to  acquire  the  Shares  or  other  securities,  the  “distributed  property”),  then  the  exchange  rate  will  be
increased based on the following formula:

ER’ = ER0 x

where,

SP0
SP0 - FMV

ER0

ER’
SP0

FMV

= the  exchange  rate  in  effect  immediately  prior  to  the  close  of  business  on  the  record

date for such distribution;

= the exchange rate in effect immediately after the close of business on such record date;

= the  average  of  the  last  reported  sale  prices  of  the  Shares  over  the  10  consecutive
trading  day  period  ending  on,  and  including,  the  trading  day  immediately  preceding
the ex-dividend date for the distribution; and

= the  fair  market  value  (as  determined  by  the  guarantor’s  Board  of  Directors)  of  the
distributed property with respect to each outstanding Share on the ex-dividend date for
the distribution.

Any increase made as described in this paragraph (3) will become effective immediately after the close of business on
the record date for such distribution. If the distribution is not so paid or made, the exchange rate will be decreased to

the exchange rate that would then be in effect if the distribution had not been declared. Notwithstanding the foregoing,
if the fair market value of the Shares is equal to or greater than SP0, in lieu of the foregoing increase, each holder of
Exchangeable Bonds will receive, in respect of each $1,000 principal amount thereof, at the same time and upon the
same terms as holders of the Shares receive the distributed property, the amount and kind of distributed property such
Holder would have received if the holder owned a number of Shares equal to the exchange rate in effect on the ex-
dividend date for the distribution.

With respect to an adjustment as described in this paragraph (3) where there has been a payment of a dividend or other
distribution on the Shares or shares of capital stock of any class or series, or similar equity interest, of or relating to
one  of  the  guarantor’s  subsidiaries  or  other  business  units,  that  are,  or,  when  issued,  will  be,  listed  or  admitted  for
trading  on  a  U.S.  national  securities  exchange  (a  “spin-off”),  the  exchange  rate  will  be  increased  based  on  the
following formula:

ER’ = ER0 x

FMV0 + MP0
MP0

where,

ER0

ER’

FMV0

= the  exchange  rate  in  effect  immediately  prior  to  the  close  of  business  on  the  record

date for the spin-off;

= the exchange rate in effect immediately after the close of business on the record date

for the spin-off;

= the average of the last reported sale prices of the capital stock or similar equity interest
distributed  to  holders  of  the  Shares  applicable  to  one  Share  over  the  first  10
consecutive trading day period after, and including, the ex-dividend date of the spin-
off (the “valuation period”); and

MP0

= the average of the last reported sale prices of the Shares over the valuation period.

The increase to the exchange rate under the preceding paragraph will occur at the close of business on the record date
for the spin-off; provided that if the relevant exchange date occurs during the valuation period, references to “10” in
the preceding paragraph will be deemed to be replaced with lesser number of trading days as have elapsed from, and
including, the ex-dividend date of the spin-off to, and including, the exchange date in determining the exchange rate.

For purposes of this paragraph (3), rights, options or warrants distributed by the Guarantor to all holders of the Shares
entitling  them  to  subscribe  for  or  purchase  shares  of  the  Guarantor’s  Capital  Stock,  including  the  Shares  (either
initially or under certain circumstances), which rights, options or warrants, until the occurrence of a specified event or
events (a “trigger event”): (i) are deemed to be transferred with such Shares; (ii) are not exercisable; and (iii) are also
issued in respect of future issuances of the Shares, will be deemed not to have been distributed for purposes of this
paragraph (3) (and no adjustment to the exchange rate under this paragraph (3) will be required) until the occurrence of
the earliest trigger event, whereupon such rights, options or warrants will be deemed to have been distributed and an
appropriate  adjustment  (if  required)  to  the  exchange  rate  will  be  made  under  this  paragraph  (3).  If  any  such  right,
option or warrant, including any such existing rights, options or warrants distributed prior to the date of the indenture,
are subject to events, upon the occurrence of which such rights, options or warrants become exercisable to purchase
different  securities,  evidences  of  indebtedness  or  other  assets,  then  the  date  of  the  occurrence  of  any  and  each  such
event will be deemed to be the date of distribution and record date with respect to new rights, options or warrants with
such rights (in which case the existing rights, options or warrants will be deemed to terminate and expire on such date
without exercise by any of the holders thereof). In addition, in the event of any distribution (or deemed distribution) of
rights,  options  or  warrants,  or  any  trigger  event  or  other  event  (of  the  type  described  in  the  immediately  preceding
sentence)  with  respect  thereto  that  was  counted  for  purposes  of  calculating  a  distribution  amount  for  which  an
adjustment  to  the  exchange  rate  under  this  paragraph  (3)  was  made,  (1)  in  the  case  of  any  such  rights,  options  or
warrants  that  have  all  been  redeemed  or  purchased  without  exercise  by  any  holders  thereof,  upon  such  final
redemption  or  purchase  (x)  the  exchange  rate  will  be  readjusted  as  if  such  rights,  options  or  warrants  had  not  been
issued and (y) the exchange rate will then again be readjusted to give effect to such distribution, deemed distribution or
trigger event, as the case may be, as though it were a cash distribution, equal to the per share redemption or purchase
price  received  by  a  holder  or  holders  of  the  Shares  with  respect  to  such  rights,  options  or  warrants  (assuming  such
holder  had  retained  such  rights,  options  or  warrants),  made  to  all  holders  of  the  Shares  as  of  the  date  of  such
redemption or purchase, and

(2) in the case of such rights, options or warrants that will have expired or been terminated without exercise by any
holders thereof, the exchange rate will be readjusted as if such rights, options and warrants had not been issued.

For  purposes  of  paragraphs  (1)  and  (2)  above  and  this  paragraph  (3),  if  any  dividend  or  distribution  to  which  this
paragraph (3) is applicable also includes one or both of:

●

●

● a  dividend  or  distribution  of  the  Shares  to  which  paragraph  (1)  above  is

applicable (the “clause A distribution”); or

● a dividend or distribution of rights, options or warrants to which paragraph

(2) above is applicable (the “clause B distribution”),

then,  in  either  case,  (1)  such  dividend  or  distribution,  other  than  the  clause  A  Distribution  and  the  clause  B
Distribution, will be deemed to be a dividend or distribution to which this paragraph (3) is applicable (the “clause C
distribution”)  and  any  exchange  rate  adjustment  required  by  this  paragraph  (3)  with  respect  to  such  clause  C
distribution  will  then  be  made,  and  (2)  the  clause  A  distribution  and  clause  B  distribution  will  be  deemed  to
immediately  follow  the  clause  C  distribution  and  any  exchange  rate  adjustment  required  by  paragraphs  (1)  and  (2)
above and with respect thereto will then be made, except that, if determined by the guarantor (I) the record date of the
clause A distribution and the clause B distribution will be deemed to be the record date of the clause C distribution and
(II) any Shares included in the clause A distribution or clause B distribution will be deemed not to be “outstanding
immediately  prior  to  the  close  of  business  on  such  record  date”  within  the  meaning  of  paragraph  (1)  above  or
“outstanding  immediately  prior  to  the  close  of  business  on  such  record  date”  within  the  meaning  of  paragraph  (2)
above.

(4) If any cash dividend or distribution is made to all or substantially all holders of Shares, the exchange rate will be
increased based on the following formula:

ER’ = ER0 x

SP0
SP0 - C

where,

ER0

ER’

SP0

C

= the  exchange  rate  in  effect  immediately  prior  to  the  close  of  business  on  the  record

date for such dividend or distribution;

= the exchange rate in effect immediately after the close of business on the record date

for such dividend or distribution;

= the last reported sale price of the Shares on the trading day immediately preceding the

record date for the ex-dividend or distribution;

= the amount in cash per share the guarantor distributes to all or substantially all holders

of the Shares.

Any increase pursuant to this paragraph (4) will become effective immediately after the close of business on the record
date  for  such  dividend  or  distribution.  If  such  dividend  or  distribution  is  not  so  paid,  the  exchange  rate  will  be
decreased, effective as of the date the guarantor’s board of directors determines not to make or pay such dividend or
distribution, to be the exchange rate that would then be in effect if the dividend or distribution had not been declared.
Notwithstanding the foregoing, if C (as defined above) is equal to or greater than SP0 (as defined above), in lieu of the
foregoing  increase,  each  holder  of  Exchangeable  Bonds  will  receive,  for  each  $1,000  principal  amount  of
Exchangeable Bonds, at the same time and upon the same terms as holders of the Shares, the amount of cash that the
Holder would have received if the Holder owned a number of the Shares equal to the exchange rate on the ex-dividend
date for the cash dividend or distribution.

(5) If the guarantor or any of its subsidiaries makes a payment in respect of a tender offer (which for the avoidance of
doubt  will  not  include  any  open  market  buybacks  or  purchases  that  are  not  tender  offers)  or  exchange  offer  for  the
Shares, to the extent that the cash and value of any other consideration included in the payment per share of

Shares exceeds the average of the last reported sale prices of the Shares over the 10 consecutive trading day period
commencing on, and including, the trading day next succeeding the last date on which tenders or exchanges may be
made pursuant to such tender or exchange offer, the exchange rate will be increased based on the following formula:

ER’ = ER0 x

where,

AC + (SP’ x OS’)
OS0 X SP

ER0

ER’

AC

OS0

OS’

SP

SP’

= the  exchange  rate  in  effect  immediately  prior  to  the  open  of  business  on  the  trading
day  immediately  following  the  trading  day  next  succeeding  the  date  such  tender  or
exchange offer expires;

= the exchange rate in effect immediately after the open of business on the trading day
immediately  following  the  trading  day  next  succeeding  the  date  such  tender  or
exchange offer expires;

= the  aggregate  value  of  all  cash  and  any  other  consideration  (as  determined  by  the
guarantor’s  Board  of  Directors)  paid  or  payable  for  the  Shares  purchased  or
exchanged in the tender or exchange offer;

= the  number  of  Shares  outstanding  immediately  prior  to  the  date  such  tender  or
exchange  offer  expires  (prior  to  giving  effect  to  the  purchase  of  all  the  Shares
accepted for purchase or exchange in the tender or exchange offer);

the number of Shares outstanding immediately after the date such tender or exchange
offer  expires  (after  giving  effect  to  the  purchase  of  all  the  Shares  accepted  for
purchase or exchange in the tender or exchange offer);

the  average  of  the  last  reported  sale  prices  of  the  Shares  over  the  10  consecutive
trading  day  period  ending  on,  and  including,  the  trading  day  immediately  preceding
the date the tender or exchange offer expires; and

the  average  of  the  last  reported  sale  prices  of  the  Shares  over  the  10  consecutive
trading day period commencing on, and including, the trading day next succeeding the
date the tender or exchange offer expires.

The  increase  to  the  exchange  rate  under  this  paragraph  (5)  will  occur  at  the  open  of  business  on  the  trading  day
immediately following the trading day next succeeding the date such tender or exchange offer expires; provided that if
the relevant exchange date occurs during the 10 trading days immediately following, and including, the trading day
next  succeeding  the  expiration  date  of  any  tender  or  exchange  offer,  references  to  “10”  or  “10th”  in  the  preceding
paragraph will be deemed replaced with such lesser number of trading days as have elapsed between the date that such
tender or exchange offer expires and the exchange date in determining the exchange rate as of such trading day.

Except  as  stated  above,  the  exchange  rate  will  not  be  adjusted  for  the  issuance  of  the  Shares  or  any  securities
convertible into or exchangeable for the Shares or the right to purchase any of the foregoing.

The guarantor may from time to time, to the extent permitted by law and subject to applicable rules of the New York
Stock Exchange or any exchange on which any of the guarantor’s securities are then listed, increase the exchange rate
of the Exchangeable Bonds by any amount for any period of at least 20 business days. In such case, we will give at
least 15 calendar days’ notice of such increase. We may make such increases in the exchange rate, in addition to those
set forth above, as the guarantor’s board of directors deems advisable or to avoid or diminish any income tax to holders
of our ordinary shares resulting from any dividend or distribution of shares (or rights to acquire shares) or from any
event treated as such for income tax purposes.

Notwithstanding anything in this section to the contrary, we will not be required to adjust the exchange rate unless the
adjustment  would  result  in  a  change  of  at  least  1%  of  the  exchange  rate.  However,  we  will  carry  forward  any
adjustments  that  are  less  than  1%  of  the  exchange  rate  and  take  them  into  account  when  determining  subsequent
adjustments.

In addition, without limiting the generality of any other provision of the Exchangeable Bonds, the exchange rate will
not be adjusted:

(1) upon the issuance of any Shares pursuant to any present or future plan providing for the reinvestment of dividends
or interest payable on the guarantor’s securities and the investment of additional optional amounts in the Shares under
any plan;

(2)  upon  the  issuance  of  any  Shares  or  options  or  rights  to  purchase  the  Shares  pursuant  to  any  present  or  future
employee, director, officer or consultant benefit, compensation or stock purchase plan or program of or assumed by the
guarantor or any of its subsidiaries;

(3) upon the issuance of any Shares pursuant to any option, warrant, right or exercisable, exchangeable or convertible
security not described above and outstanding as of the issue date of the Exchangeable Bonds;

(4)  upon  the  repurchase  of  any  Shares  pursuant  to  an  open-market  share  repurchase  program  or  other  buyback
transaction that is not a tender or exchange offer of the type described in paragraph (5) above;

(5) solely for a change in the nominal value of the Shares; or

(6) for accrued and unpaid interest, if any.

As a result of any adjustment of the exchange rate, the holders of Exchangeable Bonds may, in certain circumstances,
be deemed to have received a distribution that is treated as a dividend for U.S. federal income tax purposes. In certain
other circumstances, the absence of an adjustment may result in a taxable dividend to the holders of ordinary shares.

Recapitalizations, Reclassifications and Changes of the Shares

If the guarantor is a party to (1) a recapitalization, reclassification or change of the Shares, (2) a consolidation, merger
or  combination,  (3)  a  sale,  lease  or  transfer  to  a  third  party  of  the  consolidated  assets  of  the  guarantor  and  its
subsidiaries or (4) any statutory share exchange, in each case, as a result of which the Shares would be converted into,
or exchanged for, stock, other securities, other property or assets, then the exchange rights will be changed into a right
to exchange the Exchangeable Bonds into the kind and amount of stock, other securities, other property or assets that a
holder would have been entitled to receive if such holder had held a number of ordinary shares equal to the applicable
exchange rate in effect immediately prior to the transaction (the “reference property”). The amount of cash and any
reference property holders receive will be based on the daily exchange values of reference property and the applicable
exchange rate, as described above.

If an event described in the immediately preceding paragraph causes the Shares to be converted into, or exchanged for,
the right to receive more than a single type of consideration (determined based in part upon any form of shareholder
election), then (i) the reference property into which the Exchangeable Bonds will be exchangeable will be deemed to
be  (x)  the  weighted  average  of  the  types  and  amounts  of  consideration  received  by  the  holders  of  the  Shares  that
affirmatively make such an election or (y) if no holders of the Shares affirmatively make such an election, the types
and  amounts  of  consideration  actually  received  by  the  holders  of  Shares,  and  (ii)  the  unit  of  reference  property  for
purposes  of  the  immediately  preceding  paragraph  will  refer  to  the  consideration  referred  to  in  clause  (i)  in  this
paragraph attributable to one Share.

To  the  extent  that  the  Exchangeable  Bonds  become  exchangeable  into  the  right  to  receive  cash  following  an  event
described above, interest will not accrue on such cash.

If  the  transaction  also  constitutes  a  fundamental  change,  a  holder  can  alternatively  require  us  to  purchase  all  or  a
portion  of  such  holder’s  Exchangeable  Bonds  as  described  under  “—Repurchase  Rights  Following  Fundamental
Change or Tax Event” below.

Calculations in Respect of the Exchangeable Bonds

We  will  be  responsible  for  making  all  calculations  called  for  under  the  Exchangeable  Bonds.  These  calculations
include, but are not limited to, determinations of the last reported sale prices of the Shares, the accrued interest payable
on the Exchangeable Bonds, the tax event repurchase price, the change of control repurchase price, the listing failure
event repurchase price and the exchange rate of the Exchangeable Bonds. We will make all these calculations in good
faith and, absent manifest error, our calculations shall be final and binding on holders of the Exchangeable Bonds. We
will provide a schedule of our calculations to each of the trustee and the exchange agent, and each of the trustee and
exchange agent is entitled to rely conclusively on the accuracy of our calculations without independent verification.
The trustee will forward our calculations to any holder of the Exchangeable Bonds upon the request of such holder at
our cost and expense.

Repurchase Rights Following Fundamental Change or Tax Event

If we undergo a fundamental change or tax event after the first issuance of the Exchangeable Bonds, each holder will
have the option to require us to purchase its Exchangeable Bonds on a date of our choosing (the “repurchase date”)
that is not less than 60 business days after the fundamental change (or a longer period if required by applicable law). In
the event of a change of control repurchase event, we will pay a purchase price equal to 101% of the principal amount
of  the  holder’s  Exchangeable  Bonds  plus  accrued  and  unpaid  interest  up  to  but  excluding  the  date  of  purchase  (the
“change of control repurchase price”).  In  the  event  of  a  listing  failure  event  or  tax  event,  we  will  pay  a  purchase
price equal to 100% of the principal amount of the holder’s Exchangeable Bonds plus accrued and unpaid interest up
to but excluding the date of purchase (the “listing failure event repurchase price” or “tax event repurchase price,”
as  applicable).  However,  if  the  repurchase  date  is  after  a  record  date  and  on  or  prior  to  the  corresponding  interest
payment date, the interest will be paid on the interest payment date to the holder of record on the record date. A holder
may require us to purchase all or any part of the Exchangeable Bonds so long as the principal amount at maturity of
the Exchangeable Bonds being purchased is an integral multiple of $1,000.

Our ability to repurchase Exchangeable Bonds with cash at any time may be limited by the terms of our then existing
borrowing  agreements.  The  indenture  prohibits  us  from  repurchasing  Exchangeable  Bonds  in  connection  with  the
holders’  repurchase  rights  if  any  event  of  default  under  the  indenture  has  occurred  and  is  continuing,  except  for  a
default in the payment of the repurchase price with respect to the Exchangeable Bonds. If a fundamental change occurs
at a time when we are prohibited from repurchasing the Exchangeable Bonds, we could seek the consent of our lenders
to purchase the Exchangeable Bonds or attempt to refinance the debt. If we do not obtain such consent or we are not
able to refinance the debt, we would not be permitted to repurchase the Exchangeable Bonds. Our existing borrowing
agreements currently do not restrict us from repurchasing the Exchangeable Bonds so long as we remain in compliance
with certain financial covenants.

On or before the 20th calendar day after a fundamental change, we will provide notice to the trustee and to each holder
of the Exchangeable Bonds of the fundamental change which specifies the terms and conditions and the procedures
required for exercise of a holder’s right to require us to repurchase its Exchangeable Bonds. Such notice will specify:

(1) the events causing the fundamental change;

(2) the date of such fundamental change;

(3) the last date by which a holder of Exchangeable Bonds may exercise the repurchase right;

(4) the fundamental change repurchase date;

(5) the change of control repurchase price or the listing failure event repurchase price, as applicable;

(6) the name and address of the paying agent and the exchange agent, if applicable;

(7) the exchange rate and any adjustments to the exchange rate;

(8) that Exchangeable Bonds with respect to which a fundamental change purchase notice is given by the holder may
be exchanged only if the fundamental change purchase notice has been withdrawn in accordance with the terms of the
indenture; and

(9) the procedures that holders must follow to exercise these rights.

No  less  than  20  and  no  more  than  60  days  prior  to  the  earliest  date  on  which  we  would  have  to  withhold  tax  in
connection with a tax event, we will provide notice to the trustee and to each holder of the Exchangeable Bonds of the
tax  event  which  specifies  the  terms  and  conditions  and  the  procedures  required  for  exercise  of  a  holder’s  right  to
require us to repurchase its Exchangeable Bonds. Such notice will specify:

(1) the events causing the tax event;

(2) the date of such tax event;

(3) the last date by which a holder of Exchangeable Bonds may exercise the repurchase right;

(4) the tax event repurchase date;

(5) the tax event repurchase price;

(6) the name and address of the paying agent and the exchange agent, if applicable;

(7) the exchange rate and any adjustments to the exchange rate;

(8)  that  Exchangeable  Bonds  with  respect  to  which  a  tax  event  purchase  notice  is  given  by  the  holder  may  be
exchanged only if the tax event purchase notice has been withdrawn in accordance with the terms of the indenture;

(9) the impact of such tax event on our obligation to pay additional amounts; and

(10) the procedures that holders must follow to exercise these rights.

To  exercise  the  repurchase  right,  a  holder  of  Exchangeable  Bonds  must  deliver,  at  any  time  prior  to  the  close  of
business on the business day immediately preceding the repurchase date specified in our notice, written notice to the
paying agent of the holder’s exercise of its repurchase right.

The  holder  may  withdraw  any  written  repurchase  notice  by  delivering  a  written  notice  of  withdrawal  to  the  paying
agent  prior  to  the  close  of  business  on  the  business  day  immediately  preceding  the  repurchase  date  that  states  the
principal amount of the withdrawn Exchangeable Bonds, the certificate number of the Exchangeable Bonds in the case
of  a  physical  bond  and  the  principal  amount,  if  any,  of  Exchangeable  Bonds  that  remain  subject  to  the  original
repurchase notice, which must be in principal amounts of $1,000 or an integral multiple of $1,000.

For purposes of defining a fundamental change:

●

●

●

● the  terms  “person”  and  “group”  have  the  meanings  given  to  them  in

Sections 13(d) and 14(d) of the Exchange Act or any successor provisions;

● the  term  “group”  includes  any  group  acting  for  the  purpose  of  acquiring,
holding  or  disposing  of  securities  within  the  meaning  of  Rule  13d-5(b)(1)
under the Exchange Act or any successor provision; and

● the  term  “beneficial  owner”  is  determined  in  accordance  with  Rule  13d-3

under the Exchange Act.

Rule 13e-4 under the Exchange Act, as amended, requires the dissemination of certain information to security holders
if  an  issuer  tender  offer  occurs  and  may  apply  if  the  repurchase  option  becomes  available  to  holders  of  the
Exchangeable Bonds. We will comply with this rule to the extent applicable at that time.

We could, in the future, enter into certain transactions, including certain recapitalizations, that would not constitute a
fundamental change with respect to the fundamental change repurchase feature of the Exchangeable Bonds, but that
would increase the amount of our outstanding indebtedness or the outstanding indebtedness of our subsidiaries.

No  Exchangeable  Bonds  may  be  repurchased  at  the  option  of  holders  upon  a  fundamental  change  if  the  principal
amount of the Exchangeable Bonds has been accelerated, and such acceleration has not been rescinded, on or prior to
such date (except in the case of an acceleration resulting from our default in the payment of the tax event repurchase
price, the change of control repurchase price or the listing failure event repurchase price).

The  fundamental  change  repurchase  feature  of  the  Exchangeable  Bonds  may  in  certain  circumstances  make  it  more
difficult or discourage a takeover of us or the guarantor. The fundamental change repurchase feature, however, is not
the  result  of  our  knowledge  of  any  specific  effort  to  accumulate  the  Shares,  to  obtain  control  of  us  by  means  of  a
merger,  scheme  of  arrangement,  tender  offer  solicitation  or  otherwise,  or  by  management  to  adopt  a  series  of  anti-
takeover  provisions.  Instead,  the  fundamental  change  repurchase  feature  is  a  standard  term  contained  in  securities
similar  to  the  Exchangeable  Bonds,  is  limited  to  specified  transactions  and  may  not  include  other  events  that  might
adversely affect our or the guarantor’s financial condition or results of operations.

Consolidation, Merger and Sale of Assets

● We  have  agreed,  for  so  long  as  any  Exchangeable  Bonds  remain
outstanding, that we will not consolidate with or merge into any entity, or
transfer  or  dispose  of  all  or  substantially  all  of  our  assets  to  any  entity,
unless, among certain other requirements:

● either (a) we or the guarantor is the continuing entity or (b) the continuing
entity  is  organized  under  the  laws  of  the  United  States,  the  District  of
Columbia,  the  Cayman  Islands,  Bermuda,  the  British  Virgin  Islands,
Cyprus, the Kingdom of the Netherlands, the Grand Duchy of Luxembourg,
England,  Scotland,  Wales,  Ireland,  or  any  other  jurisdiction  that  does  not
adversely affect the rights of any Holder under the indenture in any material
respect;

● immediately after giving effect to such transaction or series of transactions,
no default or event of default will have occurred and be continuing or would
result therefrom; and

● the  successor  (if  not  us  or  the  guarantor)  expressly  assumes  our  or  the
guarantor’s, as applicable, covenants and obligations under the indenture.

●

●

●

●

Additional Covenants

The covenants summarized below will apply to the Exchangeable Bonds.

Ownership of the Company

The guarantor will continue to own (directly or indirectly) 100% of our common equity.

Covenants with Respect to the Shares

The  guarantor  will  keep  available  at  all  times  (a)  conditional  share  capital  to  issue  and/or  (b)  the  Shares  held  in
treasury by the guarantor or any of its subsidiaries to deliver to holders of the Exchangeable Bonds the full number of
Shares  issuable  or  deliverable,  as  applicable,  upon  exchange  of  the  Exchangeable  Bonds,  which  Shares  will  not  be
subject  by  law  to  preemptive  rights  and  in  respect  of  which  no  contractual  preemptive  rights  will  be  granted.  The
guarantor will cause the person in whose name any Shares will be issuable upon exchange to be effectively treated as a
stockholder

of record of such Shares for purposes of any dividends or distribution payable on the Shares as of the close of business
on the relevant exchange date.

The guarantor will not alter its share capital or amend its articles of association if and to the extent such alteration or
amendment  would  have  the  effect  of  preventing,  hindering  or  impairing  the  right  of  holders  of  the  Exchangeable
Bonds to exchange their Exchangeable Bonds for the Shares.

The  guarantor  undertakes  to  and  covenants  with  the  trustee  that  in  the  event  of  our  failing  to  comply  with  our
obligations pursuant to the provisions described under “—Exchange Rights—Settlement Upon Exchange” above, the
guarantor will cause us to comply with such obligations.

Required Information

At any time we and the guarantor are not subject to Sections 13 or 15(d) of the Exchange Act, we will, so long as any
of the Exchangeable Bonds or the Shares constitute “restricted securities” within the meaning of Rule 144(a)(3) under
the Securities Act, promptly provide to any holder, beneficial owner or prospective purchaser of such Exchangeable
Bonds or any such Shares, upon written request, the information required to be delivered pursuant to Rule 144A(d)(4)
under the Securities Act (or any other provision of Rule 144A, as such rule may be amended from time to time), to
facilitate the resale of such Exchangeable Bonds or the Shares pursuant to Rule 144A under the Securities Act, as such
rule may be amended from time to time.

We and the guarantor will file with the trustee within fifteen days after the same are required to be filed with the SEC,
copies of any documents or reports that we are required to file with the SEC pursuant to Section 13 or 15(d) of the
Exchange  Act  (giving  effect  to  any  grace  period  provided  by  Rule  12b-25  under  the  Exchange  Act).  Any  such
document or report that we or the guarantor files with the SEC via the SEC’s EDGAR system will be deemed to be
filed with the trustee for purposes of this paragraph at the time such documents are filed via the EDGAR system.

Delivery of such reports, documents and information to the trustee is for informational purposes only, and the trustee’s
receipt  of  such  shall  not  constitute  constructive  notice  of  any  information  contained  therein  or  determinable  from
information contained therein, including our compliance with any of our covenants (as to which the trustee is entitled
to rely exclusively on officers’ certificates). The trustee shall not be obligated to monitor or confirm, on a continuing
basis or otherwise, our compliance with this required information covenant or the posting of any reports, documents
and information on the EDGAR system or any website.

Events of Default

Each of the following will constitute an event of default under the indenture:

● we or the guarantor defaults in the payment of interest on any Exchangeable Bond when

due and payable, and the default continues for a period of 30 days;

● we  or  the  guarantor  defaults  in  the  payment  of  the  principal  (including  the  tax  event
repurchase  price,  change  of  control  repurchase  price  or  listing  failure  event  repurchase
price, if applicable) of, or premium on, any Exchangeable Bond when due and payable at
maturity, upon required repurchase or otherwise;

●

●

● we  or  the  guarantor  fails  to  comply  with  our  respective  obligations  to
exchange  the  Exchangeable  Bonds  in  accordance  with  the  indenture  upon
exercise of a holder’s exchange right;

● we or the guarantor fails to make an offer in connection with a fundamental

change or tax event in accordance with the indenture;

●

●

●

●

● we or the guarantor fails to comply with any covenant or agreement in the
indenture  and  such  default  or  breach  continues  for  90  days  after  we  have
been given written notice specifying such default or breach and requiring it
to be remedied in accordance with the indenture;

● the occurrence of a listing failure event;

● certain  events  involving  bankruptcy,  insolvency  or  liquidation  of  us  or  the

guarantor; and

● the  guarantee  ceases  to  be  in  full  force  and  effect  or  is  declared  null  and
void  in  a  judicial  proceeding,  or  the  guarantor  denies  or  disaffirms  its
obligations under the indenture.

If  an  event  of  default  described  above  will  occur  and  be  continuing,  the  trustee  or  the  holders  of  at  least  25%  in
aggregate principal amount of the Exchangeable Bonds then outstanding may declare the Exchangeable Bonds due and
payable  at  their  principal  amount  together  with  accrued  interest,  and  thereupon  the  trustee  may,  at  its  discretion,
proceed to protect and enforce the rights of the holders of Exchangeable Bonds by appropriate judicial proceedings.
Such  declaration  may  be  rescinded  and  annulled  with  the  written  consent  of  the  holders  of  a  majority  in  aggregate
principal amount of the Exchangeable Bonds then outstanding on behalf of all holders of Exchangeable Bonds, subject
to  the  provisions  of  the  indenture.  Notwithstanding  the  foregoing,  no  such  waiver  or  rescission  and  annulment  will
extend to affect any default or event of default resulting from (i) the nonpayment of the principal (including the change
of control repurchase price, the listing failure event repurchase price or the tax event repurchase price, if applicable) of,
or accrued and unpaid interest on, any Exchangeable Bonds, (ii) failure to repurchase any Exchangeable Bonds when
required  or  (iii)  a  failure  to  pay  or  deliver,  as  the  case  may  be,  the  consideration  due  upon  exchange  of  the
Exchangeable  Bonds.  Further,  notwithstanding  the  foregoing,  the  guarantor’s  failure  to  own  (directly  or  indirectly)
100% of the common equity of us shall constitute an event of default immediately upon such event.

Tax Additional Amounts

We and the guarantor, or any such successor, as applicable, will pay any amounts due with respect to the Exchangeable
Bonds  without  deduction  or  withholding  for  any  and  all  present  and  future  withholding  taxes,  levies,  imposts  and
charges  (a  “withholding  tax”)  imposed  by  or  for  the  account  of  the  Cayman  Islands,  Switzerland  or  any  other
jurisdiction  in  which  we  or  the  guarantor,  or  any  such  successor,  as  applicable,  are  resident  for  tax  purposes  or  any
political  subdivision  or  taxing  authority  of  such  jurisdiction  (the  “taxing jurisdiction”),  unless  such  withholding  or
deduction is required by law. If such deduction or withholding is at any time required, we or the guarantor, or any such
successor, as applicable, will (subject to compliance by you with any relevant administrative requirements) pay you
additional amounts as will result in your receipt of such amounts as you would have received had no such withholding
or deduction been required.

If  the  taxing  jurisdiction  requires  us  to  deduct  or  withhold  any  of  these  taxes,  levies,  imposts  or  charges,  we  or  the
guarantor, or any such successor, as applicable, will (subject to compliance by the holder of Exchangeable Bonds with
any  relevant  administrative  requirements)  pay  these  additional  amounts  in  respect  of  principal  amount,  redemption
price,  repurchase  price  and  interest  (if  any),  in  accordance  with  the  terms  of  the  Exchangeable  Bonds  and  the
indenture,  as  may  be  necessary  so  that  the  net  amounts  paid  to  the  holder  or  the  trustee  after  such  deduction  or
withholding  will  equal  the  principal  amount,  redemption  price,  repurchase  price  and  interest  (if  any),  on  the
Exchangeable Bonds. However, none of us or the guarantor, or any such successor, as applicable, will pay additional
amounts in the following instances:

(1)  if  any  withholding  would  not  be  payable  or  due  but  for  the  fact  that  (1)  the  holder  (or  a  fiduciary,  settlor,
beneficiary of, member or shareholder of, the holder, if the holder is an estate, trust, partnership or corporation), is a
domiciliary,  national  or  resident  of,  or  engaging  in  business  or  maintaining  a  permanent  establishment  or  being
physically present in, the taxing jurisdiction or otherwise having some present or former connection with the taxing
jurisdiction  other  than  the  holding  or  ownership  of  the  Exchangeable  Bonds  or  the  collection  of  principal  amount,
redemption price, repurchase price and interest (if any), in accordance with the terms of the Exchangeable Bonds and
the indenture, or the enforcement of the Exchangeable Bonds or (2) where presentation is required, the Exchangeable
Bonds were presented more than 30 days after the date such payment became due or was provided for, whichever is
later,

(2) if any withholding tax would not have been imposed but for the failure to comply with certification, information,
documentation or other reporting requirements concerning the nationality, residence, identity or connections with the
relevant tax authority of the holder or beneficial owner of the Exchangeable Bonds, if this compliance is required by
statute or by regulation as a precondition to relief or exemption from such withholding tax,

(3) if any withholding tax would not be payable but for a tax event and we have made a tax event offer to repurchase
pursuant to the indenture, or

(4) if any withholding tax is required to be made in respect of payments made to holders of the Exchangeable Bonds
resident  in  Switzerland  (including  any  holders  of  Exchangeable  Bonds  who  fail  to  provide  required  certification,
documentation  or  other  information  establishing  residence  outside  of  Switzerland)  pursuant  to  laws  enacted  by
Switzerland  providing  for  the  taxation  of  payments  according  to  principles  similar  to  those  laid  down  in  the  draft
legislation of the Swiss Federal Council of December 17, 2014, or otherwise changing the Swiss federal withholding
tax  system  from  an  issuer-based  system  to  a  paying  agent-based  system  to  which  a  person  other  than  the  issuer  is
required to withhold tax on any interest payment, or any combination of the instances described in the preceding bullet
points.

Notwithstanding  anything  herein  to  the  contrary,  if  a  holder  does  not  elect  to  exchange,  or  cause  repurchase  of,  its
Exchangeable Bonds following a tax event, none of us or the guarantor, or any such successor, as applicable, will be
required to pay additional amounts with respect to payments made in respect of such Exchangeable Bonds following
the tax event repurchase date, and all subsequent payments in respect of such Exchangeable Bonds will be subject to
any  tax  required  to  be  withheld  or  deducted  under  the  laws  of  a  relevant  taxing  jurisdiction.  The  obligation  to  pay
additional amounts to any such holder for payments made on or in periods prior to the tax event repurchase date will
remain subject to the exceptions described above.

Satisfaction and Discharge

When (a)(i) all outstanding Exchangeable Bonds have been delivered to the trustee for cancellation; or (ii) we or the
guarantor  has  deposited  with  the  trustee  or  delivered  to  holders,  as  applicable,  after  the  Exchangeable  Bonds  have
become  due  and  payable,  whether  on  the  maturity  date,  any  tax  event  repurchase  date,  any  fundamental  change
repurchase  date,  upon  exchange  or  otherwise,  cash,  the  Shares,  and  any  cash  in  lieu  of  fractional  Shares,  solely  to
satisfy the guarantor’s exchange obligation, sufficient, without consideration of any reinvestment of interest, to pay all
of  the  outstanding  Exchangeable  Bonds  and  all  other  sums  due  and  payable  under  the  indenture  by  us  and  the
guarantor; and (b) we have delivered to the trustee an officers’ certificate and an opinion of counsel, each stating that
all conditions precedent for the satisfaction and discharge of the indenture have been complied with, then the indenture
will cease to be of further effect with respect to the Exchangeable Bonds.

Amendments to the Indenture

With the consent of the holders of at least a majority of the aggregate principal amount of the Exchangeable Bonds
then  outstanding,  we,  the  guarantor  and  the  trustee  may  enter  into  supplemental  indentures  for  the  purpose  of
modifying or amending any of the provisions of the indenture or any supplemental indentures thereto, or of modifying
in any manner the rights of the holders hereunder or thereunder; provided, however, that, without the consent of each
holder of an outstanding Exchangeable Bond affected, no such supplemental indenture shall:

●

●

●

● reduce  the  principal  amount  of  the  then  outstanding  Exchangeable  Bonds  whose

holders must consent to an amendment, supplement or waiver;

● reduce the principal of or change the fixed maturity of any Exchangeable Bonds;

● reduce the rate of or change the time for payment of interest on any Exchangeable

Bond;

● make  any  change  that  adversely  affects  the  exchange  rights  or  tax  event  or  fundamental

change repurchase rights of the Exchangeable Bonds;

● waive a default or event of default in the payment or delivery, as the case may be, of (i) the
principal (including the tax event repurchase price, the change of control repurchase price or
the listing event repurchase price, if any) of, (ii) interest on or (iii) any consideration due upon
exchange  of,  the  Exchangeable  Bonds  (except  a  rescission  of  acceleration  of  the
Exchangeable Bonds by the holders of at least a majority in aggregate principal amount of the
then outstanding Exchangeable Bonds and a waiver of the payment default that resulted from
such acceleration);

●

●

●

●

●

●

● make  any  Exchangeable  Bond  payable  in  money  other  than  that  stated  in  the

Exchangeable Bond;

● make  any  change  in  the  provisions  of  the  indenture  relating  to  waivers  of  past
defaults  or  the  rights  of  holders  of  Exchangeable  Bonds  to  receive  payments  of
principal of, or interest or premium, if any, on the Exchangeable Bonds;

● adversely  alter  any  of  the  provisions  with  respect  to  a  repurchase  of  the
Exchangeable  Bonds  upon  a  tax  event  or  fundamental  change  or  waive  any
payment of the tax event repurchase price, the change of control repurchase price
or the listing failure event repurchase price;

● cause the Exchangeable Bonds or the guarantee to become subordinated in right of

payment to any other indebtedness of us or the guarantor, as applicable;

● make any change in the amendment and waiver provisions; or

● release  the  guarantor  from  its  obligations  under  the  guarantee  or  the  indenture,

except as permitted by the indenture.

Further, without requiring the consent of any holders, we, the guarantor and the trustee may enter into supplemental
indentures for one or more of the following purposes:

● to cure any ambiguity or to correct or supplement any provision in the indenture
which may be inconsistent with any other provision in the indenture, provided
such action will not adversely affect the interests of the holders of Exchangeable
Bonds in any material respect;

● to  provide  for  uncertificated  Exchangeable  Bonds  in  addition  to  or  in  place  of
physical bonds or to alter the provisions of the indenture regarding the form of
the  Exchangeable  Bonds  (including  the  related  definitions)  in  a  manner  that
does  not  adversely  affect  any  holder  of  Exchangeable  Bonds  in  any  material
respect;

● to provide for the assumption of our or the guarantor’s obligations to the holders
under the indenture by a successor company as provided for in the indenture;

● to make any change that would provide any additional rights or benefits to the
holders that does not adversely affect the legal rights hereunder of any holder in
any  material  respect,  as  determined  in  good  faith  by  us,  as  evidenced  in  an
officers’ certificate, or to surrender any right or power conferred upon us or the
guarantor;

● to evidence and provide the acceptance of the appointment of a successor trustee

pursuant to the terms of the indenture;

● to add an additional guarantor to the Exchangeable Bonds;

● to increase the exchange rate;

●

●

●

●

●

●

●

●

●

●

● to provide for the issuance of additional Exchangeable Bonds as permitted under

the indenture;

● in  connection  with  any  event  described  under  “—Recapitalizations,
Reclassifications and Changes of the Shares,” to provide that the Exchangeable
Bonds are exchangeable into reference property, subject to the provisions of the
indenture,  and  make  such  related  changes  to  the  terms  of  the  Exchangeable
Bonds to the extent expressly required; or

● to  conform  the  provisions  of  the  indenture  of  the  Exchangeable  Bonds  to  this

“Description of Transocean Exchangeable Bonds.”

Global Exchangeable Bonds: Book-Entry Form

The  Exchangeable  Bonds  are  represented  by  one  or  more  global  securities.  A  global  security  is  a  special  type  of
indirectly held security. Each global security is deposited with, or on behalf of, DTC and be registered in the name of a
nominee of DTC.

Investors may hold interests in the Exchangeable Bonds outside the United States through Euroclear or Clearstream if
they  are  participants  in  those  systems,  or  indirectly  through  organizations  which  are  participants  in  those  systems.
Euroclear and Clearstream will hold interests on behalf of their participants through customers’ securities accounts in
Euroclear’s  and  Clearstream’s  names  on  the  books  of  their  respective  depositaries  which  in  turn  will  hold  such
positions in customers’ securities accounts in the names of the nominees of the depositaries on the books of DTC. All
securities in Euroclear or Clearstream are held on a fungible basis without attribution of specific certificates to specific
securities clearance accounts.

Ownership  of  beneficial  interests  in  a  global  security  will  be  limited  to  DTC  participants  (i.e.,  persons  that  have
accounts with DTC or its nominee) or persons that may hold interests through DTC participants including Euroclear
and  Clearstream.  Ownership  of  beneficial  interests  in  a  global  security  will  be  shown  on,  and  the  transfer  of  that
ownership will be effected only through, records maintained by DTC or its nominee (except with respect to persons
that are themselves DTC participants).

So long as DTC or its nominee is the registered owner of a global security, DTC or the nominee will be considered the
sole  owner  or  holder  of  the  Exchangeable  Bonds  represented  by  that  global  security  under  the  indenture.  Except  as
described below, owners of beneficial interests in a global security will not be entitled to have Exchangeable Bonds
represented by that global security registered in their names, will not receive or be entitled to receive physical delivery
of Exchangeable Bonds in definitive form and will not be considered the owners or holders of the Exchangeable Bonds
under  the  indenture.  Principal  and  interest  payments  on  Exchangeable  Bonds  registered  in  the  name  of  DTC  or  its
nominee  will  be  made  to  DTC  or  the  nominee,  as  the  registered  owner.  None  of  us,  the  guarantor,  the  trustee,  any
paying agent or the registrar for the Exchangeable Bonds will have any responsibility or liability for any aspect of the
records  relating  to  or  payments  made  on  account  of  beneficial  interests  in  a  global  security  or  for  maintaining,
supervising or reviewing any records relating to such beneficial interests or with respect to delivery to any participant,
member, beneficial owner or other person (other than DTC) of any notice. The laws of some states require that certain
purchasers of securities take physical delivery of such securities in definitive form. Those limits and laws may impair
the ability to transfer beneficial interests in a global security.

We expect that DTC or its nominee, upon receipt of any payment of principal or interest, will credit immediately the
participants’ accounts with payments in amounts proportionate to their beneficial interests in the principal amount of
the  relevant  global  security  as  shown  on  the  records  of  DTC  or  its  nominee.  We  also  expect  that  payments  by
participants to owners of beneficial interests in a global security held through those participants will be governed by
standing instructions and customary practices, as is the case with securities held for the accounts of customers in bearer
form or registered in “street name,” and will be the responsibility of those participants.

If DTC is at any time unwilling or unable to continue as a depositary and a successor depositary is not appointed by us
within 90 days, we will issue Exchangeable Bonds in definitive form in exchange for the entire global security for the
Exchangeable Bonds. In addition, we may at any time choose not to have Exchangeable Bonds represented by a

global security and will then issue Exchangeable Bonds in definitive form in exchange for the entire global security
relating to the Exchangeable Bonds. In any such instance, an owner of a beneficial interest in a global security will be
entitled  to  physical  delivery  in  definitive  form  of  Exchangeable  Bonds  represented  by  the  global  security  equal  in
principal amount to that beneficial interest and to have the Exchangeable Bonds registered in its name. Exchangeable
Bonds  so  issued  in  definitive  form  will  be  issued  as  registered  Exchangeable  Bonds  in  minimum  denominations  of
$1,000 and integral multiples thereof, unless otherwise specified by us.

Meetings of Holders

Meetings of holders of Exchangeable Bonds may be called at any time for any of the following purposes:

● to give any notice to us or to the trustee or to give any directions to the trustee
permitted  under  the  indenture,  or  to  consent  to  the  waiving  of  any  default  or
event of default under the indenture and its consequences, or to take any other
action authorized to be taken by holders of Exchangeable Bonds in respect of
an event of default or remedy in respect of an event of default;

● to  remove  the  trustee  and  nominate  a  successor  trustee  pursuant  to  the

indenture;

● to  consent  to  the  execution  of  an  indenture  or  supplemental  indenture

amending or modifying the indenture; or

● to take any other action authorized to be taken by or on behalf of the holders of
any  specified  aggregate  principal  amount  of  Exchangeable  Bonds  under  any
other provision of the indenture.

●

●

●

●

Calls of Meetings

The trustee may at any time call a meeting of holders of Exchangeable Bonds to take any action specified above, to be
held at such time and place as the trustee will determine. Notice of every meeting of holders of Exchangeable Bonds,
setting forth the time and place of such meeting and in general terms the action proposed to be taken at such meeting
and the establishment of any record date, will be delivered to holders of Exchangeable Bonds. Such notice will also be
delivered to us, not less than 20 or more than 90 days prior to the date fixed for the meeting.

Any meeting of holders of Exchangeable Bonds will be valid without notice if the holders of all Exchangeable Bonds
then outstanding are present in person or by proxy or if notice is waived before or after the meeting by the holders of
all  Exchangeable  Bonds  then  outstanding,  and  if  we  and  the  trustee  are  either  present  by  duly  authorized
representatives or have, before or after the meeting, waived notice.

In case at any time we or the holders of at least 25% of the aggregate principal amount of the Exchangeable Bonds
then outstanding will have requested the trustee to call a meeting of holders of Exchangeable Bonds, by written request
setting forth in reasonable detail the action proposed to be taken at the meeting, and the trustee will not have delivered
the notice of such meeting within 20 days after receipt of such request, then we or such holders may determine the
time and the place for such meeting and may call such meeting to take any action described above, by delivering notice
thereof as provided in this section.

Qualifications for Voting

To be entitled to vote at any meeting of holders, a person must (a) be a holder of one or more Exchangeable Bonds on
the record date pertaining to such meeting and (b) be a person appointed by an instrument in writing as proxy by a
holder of one or more Exchangeable Bonds on the record date pertaining to such meeting. The only persons entitled to
be present or to speak at any meeting of holders will be the persons entitled to vote at such meeting and their counsel,
any representatives of the trustee and its counsel and any of our representatives and our counsel.

Notices

Any  notice  or  communication  delivered  or  to  be  delivered  to  a  holder  of  Exchangeable  Bonds,  so  long  as  the
Exchangeable  Bonds  remain  in  global  form,  will  be  delivered  in  accordance  with  the  applicable  procedures  of  the
depositary  and  shall  be  sufficiently  given  to  it  if  so  delivered  within  the  time  prescribed.  Notices  to  holders  of
Exchangeable  Bonds  in  certificated  form  will  be  given  by  mail  to  the  holder’s  address  as  it  appears  in  the
Exchangeable Bonds register.

Information Regarding the Co-Trustees

Computershare  Trust  Company,  N.A.  and  Computershare  Trust  Company  of  Canada  are  co-trustees  under  the
indenture governing the Exchangeable Bonds. Computershare Trust Company, N.A. has also been appointed by us as
paying  agent,  exchange  agent,  registrar  and  custodian  with  regard  to  the  Exchangeable  Bonds.  The  trustee  and  its
affiliates  provide  and  may  from  time  to  time  in  the  future  provide  banking  and  other  services  to  us  in  the  ordinary
course of their business.

Governing Law

The indenture and the Exchangeable Bonds are governed by, and construed in accordance with, the law of the State of
New York.