Human Trafficking

Disclosures under the California Transparency in Supply Chain Act of 2010 [Cal Civ Code §1714.43 (c)]

Guiding Principles

At Baker Hughes, we believe principled business practices are key to our success. We seek to play a positive role in the communities where we work by conducting business in a way that respects human rights. Our business operations adhere to the principles of the United Nations Universal Declaration of Human Rights as a general standard of human rights worldwide. We are committed to universal human rights standards, such as nondiscriminatory treatment, voluntary employment, freedom of association, minimum wage, anti-harassment, and maintaining a healthy and safe work environment.

It is our expectation that our direct suppliers of tangible goods will uphold the human rights of workers, and treat their employees with dignity and respect as understood by the international community. We expect our direct 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. Direct suppliers shall prohibit harassment and unlawful discrimination in the workplace; and 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 as is the employment of children.

California Transparency in Supply Chain Act

These principles evidence our efforts to eradicate slavery and human trafficking by our direct supply chain for tangible goods that we offer for sale:

  • Verification of product received from direct suppliers of tangible goods

We evaluate and address the risks of human trafficking and slavery in our direct supply chain of tangible goods by establishing our expectations of our management and employees in our company Business Code of Conduct and suppliers in our Supplier Code of Conduct.

We verify, evaluate and address the risks of human trafficking and slavery in our direct supply chain of tangible goods through our supplier due diligence program and post-contract award audits as well as through the enforcement of the terms and conditions under which our direct suppliers perform their work for us.

Our Business Ethics Help Line is a free, multilingual, 24-hour service answered by an independent third party. The help line provides a forum to report concerns or instructions on the reporting process so concerns or questionable conduct can be brought to our company’s attention. Callers are allowed to identify themselves or remain anonymous. Anonymous reports are protected to the extent possible, but it can limit our company’s ability to investigate the concerns raised. The Business Ethics Help Line may be contacted toll free in the United States at (1) 800-288-8475 or by calling collect from outside the United States at (+1) 713-626-0521. Additional free, direct-dial access numbers are available on the Business Ethics Help Line link on the Baker Hughes homepage to allow direct calls without international calling charges. The Legal Department or Enterprise Security may be contacted by dialing the Chief Compliance Officer at (+1) 713-439-8439 or Enterprise Security (+1) 713-439-8609.

These efforts have not been verified by a third party

  • Audits of direct suppliers of tangible goods

Our procurement due diligence process includes an evaluation of and certification by our direct suppliers of their compliance with international standards and all laws regarding forced labor, slavery, human trafficking and the worst forms of child labor in the countries in which they do business.

We also perform post-contract award audits of our direct suppliers. Our direct suppliers are provided a short period of notice prior to the audits to help ensure that the information needed for the audit is available. These audits focus on whether the suppliers are committed to conducting business with the highest degree of ethics and in full compliance with all applicable laws and regulations and have the programs in place to do so. The audits are conducted by our Financial Compliance team, who operate independently of our supply chain organization. The audits are not conducted by an independent third party.

  • Certification of materials from direct suppliers incorporated into products

We require our direct suppliers, as a part of our due diligence process, to certify that they comply with international standards and all laws regarding forced labor, slavery, human trafficking and the worst forms of child labor of the country or countries in which they do business.

Subsequently, our post contract review of direct suppliers requires the supplier’s to certify that they are committed to conducting business with the highest degree of ethics and in full compliance with all applicable laws and regulations, and that they have a program in place to ensure compliance.

Our direct suppliers are further obligated to comply with the terms and conditions in our contracts that include compliance with all applicable laws and regulations. We have revised our standard supplier contract to specifically preclude suppliers from using any form of forced or child labor, whether in the form of prison labor, indentured labor, bonded labor or otherwise. Slavery and human trafficking are prohibited.

The company has the right to terminate a supplier’s contract and cease any further activity with the supplier should our due diligence process evidence that a supplier is failing to meet the company terms of our standard supplier contract or if the supplier otherwise violates the law.

  • Internal accountability and standards

Should the company be made aware of a violation of our Business Code of Conduct, Supplier Code of Conduct or applicable laws or regulations by one of our management or employees or a supplier, the company would have the discretion to terminate any or all of those relationships and take such other actions as it would deem legally available.

  • Training

The company provides training to all of its new and existing employees and management regarding the principles established by our Business Code of Conduct and Core Values. It provides the guidelines and identifies resources available for making ethical and legal decisions in the workplace. In addition, there is specific procurement compliance training for supply chain employees.

The company is currently reviewing an electronic training module that will be used to provide training on human rights trafficking and slavery for supply chain management and employees that are in roles that directly deal with our suppliers.

Corporate Social Responsibility

At Baker Hughes, corporate social responsibility (CSR) is central to our core values. We conduct our business in an ethical and responsible way. We’ve invested in a number of initiatives to maintain our strong CSR position for the future.

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