Foreign Corrupt Practices Act

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

The past two decades have seen a growing global commitment to enacting and enforcing anti-corruption legislation worldwide. In that time, international cooperation efforts have increased and enforcement mechanisms have become more robust and effective. More than one hundred countries around the world, including the United States through the Foreign Corrupt Practices Act of 1977 (“FCPA”) and the United Kingdom through the UK Bribery Act, have adopted domestic anti-bribery laws.

The laws of most jurisdictions throughout the world now make it a crime to give or offer to give anything of value to a government official (including employees of state-owned companies) to improperly influence the performance of the official’s duties. The FCPA also requires that public companies, like Baker Hughes, have strong internal controls and accurate books and records. In a number of countries in which Baker Hughes does business, domestic anti-bribery laws allow for both individuals and corporate organizations to face criminal prosecution for violations.

Baker Hughes is committed to maintaining the highest ethical and legal standards. We strive to comply with both the letter and spirit of applicable laws and regulations in each country in which we operate. Baker Hughes employees, agents, representatives, joint venture partners, consultants, and distributors must fully comply with the provisions of relevant anti-bribery laws. Failure to comply with anti-bribery legislation is not tolerated.

Interpreting anti-bribery legislation can be challenging; many potentially covered situations fall into unclear or “gray” areas. This Guide provides examples to facilitate the reader’s understanding and compliance with the FCPA and other anti-bribery laws. Any Baker Hughes employee who has questions or concerns should contact his/her Baker Hughes Region Legal Counsel or the Baker Hughes Vice President & Chief Compliance Officer. Any other person who may have a question concerning this FCPA Guide should contact the Baker Hughes Business Ethics Help Line or the Company representative named in an applicable contractual agreement.

At Baker Hughes, we know that the way we achieve business results is just as important as the results themselves. Our industry-wide reputation for integrity is among our most powerful assets. Thank you for joining us in our commitment to maintaining the highest standards of ethical conduct and continuing to strengthen Baker Hughes’ reputation for compliance excellence.

Sincerely,

Martin Craighead
Chairman and Chief Executive Officer