Business Code of Conduct Compliance

Our Business Code of Conduct gives broad guidelines for the kind of ethical behavior expected of employees. It addresses a number of issues, including: fair employment practices; conflicts of interest; financial integrity; entertainment; misuse of company assets; U.S. embargoes and trade sanctions; and many other topics.

Annually, Baker Hughes employees are required to complete our Business Code of Conduct Questionnaire online. Employees are encouraged to review the Code of Conduct and affirm their compliance to it. The questionnaire addresses specific compliance areas where problems have occurred and it asks employees to report any potential Code violations they have observed.

In 2009, the Business Code of Conduct Questionnaire was distributed to 16,679 eligible employees, including all accounting, legal, logistics and management-level employees. An analysis of the results revealed that 86% of all respondents who identified a potential violation to the Code of Conduct believed that such potential violation had both been properly reported and properly resolved, indicating the transparency and effectiveness of our compliance programs.

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Business Code of Conduct

We must view compliance with all laws applicable to the Company's business as being the bare minimum for our operating conduct and recognize that ethics is something more.

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