We do business in more than 80 countries, including approximately 18 of the 40 countries having the lowest scores in the Transparency International’s Corruption Perception Index survey for 2014, which indicates high levels of corruption.
Each year the legal compliance group along with the internal audit team conducts a joint Foreign Corrupt Practices Act (FCPA) audit in a number of these countries. The countries are predetermined for audit each year based on their CPI score as well as various other risk factors. In addition, the legal compliance group also audits a selection of Baker Hughes’ commercial sales representatives who operate in select high-risk countries. Baker Hughes believes this is one of the first types of audit programs of commercial sales representatives in our industry.
Additionally, we maintain a compliance review program which is an in-depth analysis of FCPA compliance issues. This program includes employee interviews as well as a review of targeted accounting records. The Baker Hughes legal compliance group has also developed a three-day FCPA risk assessment which can be performed in various high-risk countries.
Baker Hughes employees are required to complete FCPA training. This training may be instructor-led or an interactive computer-based training module.