Baker Hughes 2014 Annual Report Download - page 61

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36
Highlights of our Compliance Program include the following:
• We have comprehensive internal policies over such areas as facilitating payments; travel, entertainment,
gifts and charitable donations connected to non-U.S. government officials; payments to non-U.S.
commercial sales representatives; and the use of non-U.S. police or military organizations for security
purposes. In addition, we have country-specific guidance for customs standards, visa processing, export
and re-export controls, economic sanctions and antiboycott laws.
• We have a comprehensive employee compliance training program covering substantially all employees.
• We have a due diligence procedure for commercial sales, processing and professional agents and an
enhanced process for classifying distributors.
• We have a special compliance committee, which is made up of senior officers, that meets no less than once
a year to review the oversight reports for all active commercial sales representatives.
• We have continued our reduction of the use of commercial sales representatives and processing agents,
including the reduction of customs agents.
• We use technology to monitor and report on compliance matters, including a web-based antiboycott
reporting tool and a global trade management software tool.
• We have a compliance governance committee, which includes senior officers of the Company, that reviews
our effectiveness and compliance with processes and controls of the Company's global compliance
program including all areas covered by the Business Code of Conduct.
• We have a program designed to encourage reporting of any ethics or compliance matter without fear of
retaliation including a worldwide Business Helpline operated by a third party and currently available toll-free
in 150 languages to ensure that our helpline is easily accessible to employees in their own language.
• We have a centralized finance organization including an enterprise-wide accounting system and company-
wide policies. In addition, the corporate audit function has incorporated anti-corruption procedures in audits
of certain countries. We also conduct FCPA risk assessments and legal audit procedures.
• We continue to work to ensure that we have adequate legal compliance coverage around the world,
including the coordination of compliance advice and customized training across all regions and countries
where we do business.
• We have a centralized human resources function, including consistent standards for pre-hire screening of
employees, the screening of existing employees prior to promoting them to positions where they may be
exposed to corruption-related risks, and a uniform policy for new hire training.
LIQUIDITY AND CAPITAL RESOURCES
Our objective in financing our business is to maintain sufficient liquidity, adequate financial resources and
financial flexibility in order to fund the requirements of our business. At December 31, 2014, we had cash and cash
equivalents of $1.74 billion, of which approximately $1.31 billion was held by foreign subsidiaries. A substantial
portion of the cash held by foreign subsidiaries at December 31, 2014 was reinvested in our international operations
as our intent is to use this cash to, among other things, fund the operations of our foreign subsidiaries. If we decide
at a later date to repatriate those funds to the U.S., we may be required to provide taxes on certain of those funds
based on applicable U.S. tax rates net of foreign tax credits. We have a committed revolving credit facility with
commercial banks and a related commercial paper program under which the maximum combined borrowing at any
time under both the credit facility and the commercial paper program is $2.50 billion. At December 31, 2014, we
had no commercial paper outstanding; therefore, the amount available for borrowing under the facility as of
December 31, 2014 was $2.50 billion. We believe that cash on hand, cash flows generated from operations and the
available credit facility, including the issuance of commercial paper, will provide sufficient liquidity to manage our
global cash needs. In 2014, we used cash to pay for a variety of activities including working capital needs, capital
expenditures, acquisitions, repurchase of our common stock and payment of dividends.