Foreign Corrupt Practices Act

To all Baker Hughes Employees, Agents, Representatives, Consultants, Distributors, and Joint Venture Partners

Baker Hughes Incorporated is committed to maintaining the highest ethical and legal standards. We striveto comply with both the letter and spirit of applicable laws and regulations in each country in which we dobusiness. Integrity, our first Core Value, provides the foundation for all Company policies, procedures, andactions. We conduct our day-to-day business with our shareholders, employees, customers, representatives,suppliers, competitors, governments and the public in an honest and ethical manner.

The Foreign Corrupt Practices Act of 1977 ( “FCPA”) makes it a crime to give, or to offer to give, anything of value to non-U.S.government officials (including employees of state-owned companies, such as national oil and transportation companies) to improperlyinfluence the performance of the officials’ duties. The FCPA also includes requirements that public companies, like Baker Hughes, havestrong internal controls and accurate books and records.

In addition to the FCPA, an emerging consensus against corruption has been bolstered over the past decade by a host of multilateralinstitutions and international treaties. These multilateral institutions include, among others, the OECD and the United Nations. Someof the key conventions include the OECD Anti-Bribery Convention, Inter-American Convention Against Corruption, Council of EuropeCriminal Law Convention on Corruption, and the UN Convention Against Transnational Organized Crime. More than one hundredcountries have also adopted their own domestic anti-bribery laws.

Baker Hughes operates a Best-in-Class global ethics and compliance program which is designed to detect and prevent violations of allapplicable anti-bribery laws throughout its operations. Failure to comply with the FCPA is not tolerated. Any employee who engages inconduct that results in a violation of the FCPA is subject to discipline, which can include his or her employment termination. Penaltiesfor violating the FCPA and other anti-bribery laws can be severe for both Baker Hughes and individual(s) involved. These penalties mayinvolve large fines and even imprisonment.

Interpreting the FCPA is sometimes challenging because many situations potentially covered by the FCPA fall into unclear or “gray”areas. This Guide provides many illustrative examples to facilitate the reader’s understanding and compliance with the FCPA. Theseexamples were carefully chosen to illustrate some of the most common and significant risk areas of the FCPA - issues that BakerHughes must successfully address every day. All Baker Hughes employees acting on behalf of Baker Hughes (referenced in this Guide as“Employees”), agents, consultants, certain distributors, and representatives (collectively referenced in this Guide as “Representatives”)and joint venture partners must fully comply with the provisions of the FCPA. For Employees, compliance with the FCPA, other applicablelaws, Baker Hughes’ Core Values (Integrity, Teamwork, Performance and Learning), and the Baker Hughes Business Code of Conduct is acondition of continued employment.

Employees are expected to 1) read and apply this Guide in their day-to-day jobs, 2) successfully complete the Company’s required FCPAtraining, 3) recognize concerns regarding FCPA compliance, 4) ask questions and promptly report any suspected FCPA violation (seepage 3 of this Guide), 5) read and understand our Core Values and the Baker Hughes Business Code of Conduct, and 6) abide by all other requirements of Baker Hughes’s compliance program.

Thank you for joining us in our commitment to maintain ethical conduct and in continuing to strengthen Baker Hughes’s reputation forexcellence in compliance with laws.

Chad Deaton
Chairman and CEO
Baker Hughes Incorporated




The full Baker Hughes FCPA Guide is available for download (PDF - 4.71MB).