The Baker Hughes Code of Conduct
Our Code of Conduct includes our Anti-Bribery & Corruption policy, which prohibits bribery in all business dealings, in every country around the world, with governments, employees of state-owned companies and the private sector, or anyone else whatsoever.
Our Anti-Discrimination policy, also included in Our Code of Conduct, prohibits discrimination or harassment against any employee or applicant based on race, color, religion, national or ethnic origin, sex (including pregnancy), sexual orientation, gender identity or expression, age, disability, veteran status or other characteristic protected by law. Our policy also prohibits retaliation for concerns raised in good faith.
In November 2019 we launched Our Way, the newly refreshed Baker Hughes Code of Conduct. The code of conduct is titled “Our Way” because it is premised upon doing things the right way, the ethical way, and the compliant way. It’s in our DNA to act with integrity in all that we do, and our code of conduct reflects that core belief. By consistently demonstrating this commitment; we distinguish ourselves in the industry and strengthen the trust between us, our employees, customers, suppliers, and the public; maintaining our reputation as a responsible business. Our Way serves as a reminder that as we take energy forward, we are expected to act with integrity in all that we do.
We are committed to ensuring that employees, suppliers, and partners understand and conduct their activities in accordance with our code of conduct. We take active steps to offer global learning courses in various formats and languages so that our integrity and compliance expectations are clear and understood. In 2019, we offered tailored courses in many areas, some of which are included below:
2. Improper payments and anti-bribery
3. Working with governments
5. Supplier relationships
6. Securing operations globally
7. Competition law
8. Conflicts of interest
9. International trade compliance
10. Intellectual property
11. Fair employee practices
12. Anti-money laundering
13. Cyber security and privacy
14. Insider trading and stock tipping
A global structure of compliance counsels and professionals provides advice, training, and support in places where Baker Hughes does business.
A Compliance Review Board, composed of senior officers of the company meets quarterly, as well as Product Company and regional compliance committees.
Regular compliance risk assessments focus on country and third party risks (including corruption risk), to identify opportunities for continuous improvement and resource allocation.
Our comprehensive employee training program targets key risks that employees face on an ongoing basis. In 2019 a total of 59,464 employees, representing 94.2% of our workforce, completed ethics and compliance programs, including Code of Conduct training.
Open Reporting Environment
Employees are encouraged to report any ethics or compliance matters without fear of retaliation, including a global network of trained employee ombudspersons, a dedicated website where employees can raise anonymous concerns, and a worldwide, 24-hour integrity helpline operated by a third party and available in 150 languages.
Privacy and cybersecurity
Baker Hughes takes security and data privacy very seriously. Given our global footprint and the increasing sophistication of cyber attacks, cybersecurity and privacy protection are a crucial part of our risk management and sustainability management systems.
Baker Hughes protects our digital systems and data through a comprehensive cybersecurity management program. We follow the NIST cybersecurity framework and conduct third party reviews of our program. We operate a comprehensive Cyber Fusion Center to coordinate resources, reduce incident response time and shift toward a proactive cyber defense model. In addition to hardening our own cyber defenses, we assist our customers in maintaining the security of their systems via our Nexus Control Systems business.
We comply with all applicable global privacy regulations in the markets where we operate, including the General Data Protection Regulation (GDPR) framework in Europe. During 2019 we conducted GDPR compliance training for employees whose roles involve handling customer data.
Our cybersecurity and data privacy program is conducted with board level oversight, and quarterly reports are provided to the Board of Directors.