Suppliers Code of Conduct

FOR VENDORS, SUPPLIERS AND CONTRACTORS

Baker Hughes is proud of its commitment to always conduct business with the highest degree of integrity and in full compliance with applicable laws and regulations. This commitment to integrity and high standards of ethical conduct extends to Baker Hughes’ dealings with all of its Vendors, Suppliers, and Contractors (collectively, “Suppliers”). It is through this commitment we seek to ensure that we conduct our business in a responsible manner. We expect our Suppliers to have a similar commitment.

By implementing this Code of Conduct (“Code”), we strive to minimize the level of business risk within the supply chain, build closer relationships with our Suppliers and safeguard future supply while helping to ensure that working conditions in Baker Hughes’ supply chain are safe, that workers are treated with respect and dignity, that materials are responsibly sourced, and that manufacturing processes are environmentally responsible.

Business Ethics

Suppliers must be committed to the highest standards of ethical conduct when dealing with Baker Hughes and its employees, other Suppliers, and customers.

Professional Conduct

Suppliers should conduct all of their activities professionally. We expect our Suppliers to be completely objective in their judgment and any recommendations that they give, so that issues are never influenced by anything other than the best and proper interests of Baker Hughes.

Compliance with Laws

We expect our Suppliers’ actions and advice will always conform to relevant law and regulations of the countries in which they operate, and shall not engage in corruption, extortion, or embezzlement in any form. In addition, Supplier should:

  • Not perform any act, which would undermine Baker Hughes’ commitment to conducting its business in an open, vigorous and competitive fashion.
  • Predicate all purchases and sales between Baker Hughes and its Suppliers strictly on considerations of efficiency, price, quality, service and suitability.
  • Uphold fair business standards in advertising, sales, and competition. 

Trade Compliance

Suppliers must:

  • Understand and follow applicable international trade control laws and regulations, including those relating to economic sanctions, customs requirements and export controls.
  • Be cognizant of U.S. Antiboycott laws, regulations, and guidelines and do not take or fail to take any action that could expose Baker Hughes to liability or penalties.
  • Ensure that all transactions are screened in accordance with applicable sanctions and export/import requirements.

Cargo Security

Suppliers will implement and maintain security procedures, such as the minimum security procedures provided by the United States Customs and Border Protection C-TPAT Guidelines, to guard against the introduction of non-manifested cargo.

Anti-Corruption

Suppliers, and their employees, shall not engage in bribery and/or corruption while serving Baker Hughes in any line of business. Specifically, Suppliers shall not do, and shall immediately report to Baker Hughes any request to do, any of the following:

  • directly or indirectly offer, give, authorize, solicit, or accept the giving of money or anything else of value to or from any person, whether a government official or private party, to obtain an improper advantage for Baker Hughes, Supplier, or any third party, or secure the improper performance of that person's function or misuse of that person's position;
  • directly or indirectly offer, give or authorize the giving of money or anything else of value to any government official in his or her personal capacity, to facilitate or expedite government action or approvals;
  • do, or omit to do, any act that will cause Baker Hughes to be in breach of the anti-corruption laws of any country in which they operate;
  • directly or indirectly offer, give or authorize to any Baker Hughes employee or contractor any gift, gratuity, service, favor, or anything else of value to influence or reward that employee or contractor in connection with the any transaction; and
  • acquiesce in any request or demand for any undue financial or other advantage of any kind received by any Supplier in connection with the performance of any transaction.

Suppliers will further:

  • notify its principals, owners, directors, officers, employees, consultants, affiliates, Suppliers, agents, and subcontractors that perform any services for Baker Hughes of the requirements of this Code;
  • have its own compliance program, including policies, procedures and training, to help ensure compliance with anti-corruption laws; and
  • if requested, provide reasonable assistance to Baker Hughes in performing any activity that is required by any government or agency thereof in any relevant jurisdiction for the purpose of compliance with the anti-corruption laws.

Labor and Human Rights

Suppliers must uphold the human rights of workers, and treat their employees with dignity and respect as understood by the international community. We expect our Suppliers to always strive to be fair and objective in their advice and actions, and never to be influenced in their decisions, actions or recommendations by issues of gender, race, creed, color, age or personal disability. Suppliers shall prohibit harassment and unlawful discrimination in the workplace.

Suppliers shall not traffic in persons or use any form of slave, forced, bonded, indentured, or prison labor. This includes the transportation, harboring, recruitment, transfer, or receipt of persons by means of threat, force, coercion, abduction, fraud, or payments to any person having control over another person for the purpose of exploitation. All work must be voluntary and workers shall be free to leave work or terminate their employment with reasonable notice.

Child labor is strictly prohibited and Suppliers shall not employ children.

Health and Safety

Suppliers shall commit to creating safe working conditions and a healthy work environment for all of their workers. Suppliers shall eliminate physical hazards where possible. Where physical hazards cannot be eliminated, Suppliers should provide appropriate engineering controls such as physical guards, interlocks, and barriers. Where appropriate engineering controls are not possible, Suppliers shall establish appropriate administrative controls such as safe work procedures. In all cases, Suppliers shall comply with all applicable health, safety and environmental laws and regulations and provide workers with appropriate personal protective equipment. Workers shall not be disciplined for raising safety concerns and shall have the right to refuse unsafe working conditions without fear of reprisal until management adequately addresses their concerns.

Materials Sourcing

Suppliers should responsibly source materials used in their products and services. Suppliers shall implement supply chain due diligence policies and take affirmative measures to determine if proceeds from the mining, trading, transportation, smelting or refining of any ores, minerals or derivatives are used to benefit or fund individuals or groups engaged in violence or human rights abuses. When Suppliers become aware that these materials are in their supply chain, they must find alternative sources.

Environment

At Baker Hughes, environmental considerations are an integral part of our business practices.

Suppliers should commit to reducing the environmental impact of their designs, manufacturing processes, and waste emissions. Suppliers shall comply with any applicable laws and regulations prohibiting or restricting the use or handling of specific substances. Suppliers must obtain, maintain, and keep current all required environmental permits (for example, discharge monitoring) and registrations and follow the operational and reporting requirements of such permits.

Relationships with Baker Hughes and its Employees

Suppliers should not engage any Baker Hughes employee in, or give the appearance of engaging in, any activity involving a conflict of interest, or reasonably foreseeable conflict, between personal interests and those of Baker Hughes.

Supplier should not offer Baker Hughes employees anything of value which may influence, or create the appearance of influencing, the business decisions the employees may make. This prohibition includes gifts in excess of US$150.00, kickbacks in any form or amount, and meals or entertainment of even nominal value when inappropriate or repetitive in nature.

Intellectual Property and Confidentiality of Information

Baker Hughes retains the ownership of all intellectual property that we create and in return we respect the intellectual copyright vested in our Suppliers’ intellectual property. Suppliers must respect intellectual property rights and safeguard Baker Hughes customer information; transfer of technology and know-how must be done in a manner that protects intellectual property rights.

Suppliers should only use Baker Hughes information and property (including tools, drawings and specifications) for the purpose for which they are provided to the Supplier and for no other purposes.

Suppliers should also take appropriate steps to safeguard and maintain the confidentiality of Baker Hughes proprietary information, including maintaining it in confidence and in secure work areas and not disclosing it to third parties (including other customers, subcontractors, etc.) without the express prior written permission of Baker Hughes.

Further Suppliers should:

  • Observe and respect Baker Hughes’ patents, trademarks and copyrights, and comply with such restrictions or prohibitions on their use, and the intellectual property rights of third parties.
  • Comply with all applicable rules and laws concerning cross-border data transfers.
  • Maintain all personal and sensitive data in a secure and confidential manner in accordance with applicable laws, regulations and contractual requirements.

We expect their Suppliers to extend the same standards to all their customers, Suppliers and employees.

Management Accountability and Responsibility

Suppliers should adopt or establish a management system that is consistent with this Code and applicable laws and regulations; identify and mitigate related operational risks; and facilitate continuous improvement. Suppliers must have clearly identified company representatives responsible for ensuring implementation and periodic review of the Supplier’s management systems, to include the following:

  • Assessment and Management—A process to identify environmental, health and safety, business ethics, labor, human rights, and legal compliance risks associated with their operations; determine the relative significance of each risk; and implement appropriate procedures and physical controls to ensure compliance and control the identified risks.
  • Performance Objectives with Implementation Plans and Measures—Written standards, performance objectives, targets, and implementation plans, including a periodic assessment of the Supplier’s performance against those objectives.
  • Audits and Assessments—Periodic self-evaluations of their suppliers to ensure they are acting in a manner consistent with these expectations.

Quality Assurance

We expect our Suppliers to maintain the quality of what they do through constant ongoing review of all aims, activities, outcomes and the cost-effectiveness of every activity. We encourage regular review meetings and want to receive regular progress reports.

Disclosure of Information

Suppliers must accurately record and disclose information regarding their business activities, structure, financial situation, and performance in accordance with applicable laws and regulations.

Documentation and Records

Supplier shall have processes to identify, monitor, and understand applicable laws and regulations and the additional requirements imposed by this Code. Supplier shall obtain, maintain, and keep current a valid business license as required by applicable laws and regulations. Supplier shall have processes for creation of documents and records to ensure regulatory compliance and conformity to this Code, with appropriate confidentiality measures to protect privacy. All Suppliers will keep accurate books, records, and accounts in connection with the services to be performed for Baker Hughes.

Corrective Action Process

Supplier shall have a process for timely correction of any deficiencies identified by an internal or external audit, assessment, inspection, investigation, or review.

Reporting

Suppliers that have any ethics or compliance related concerns are encouraged to use the Baker

Hughes Business Ethics Help Line (within the U.S. call – 1.800.288.8475 or by calling collect from outside the U.S. – 1.713.626.0521). Additional free, direct-dial access numbers are available on the Business Ethics Help Line link on the Baker Hughes website to allow direct calls without international calling charges. The Legal Department may be contacted by dialing the Chief Compliance Officer at (+1) 713-439-8439. Calls to the Business Ethics Help Line or the use of the online version can be made in confidence or anonymously. Reports can also be made via the online version of the Business Ethics Help Line (https://www.tnwinc.com/Reportline/BakerHughes).