Baker Hughes 2015 Annual Report Download - page 43

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COMPLIANCE
We do business in more than 80 countries, including approximately 16 of the 40 countries having the lowest
scores in the Transparency International’s Corruption Perception Index survey for 2015, which indicates high levels
of corruption. We devote significant resources to the development, maintenance, communication and enforcement
of our Business Code of Conduct, our anti-bribery compliance policies, our internal control processes and
procedures and numerous other compliance related policies. Notwithstanding the devotion of such resources, and
in part as a consequence thereof, from time to time we discover or receive information alleging potential violations
of laws and regulations, including the FCPA and our policies, processes and procedures. We conduct timely
internal investigations of these potential violations and take appropriate action depending upon the outcome of the
investigation.
We anticipate that the devotion of significant resources to compliance-related issues, including the necessity for
investigations, will continue to be an aspect of doing business in a number of the countries in which oil and natural
gas exploration, development and production take place and in which we conduct operations. Compliance-related
issues have, from time to time, limited our ability to do business or have raised the cost of operating in these
countries. In order to provide products and services in some of these countries, we may in the future utilize
ventures with third parties, sell products to distributors or otherwise modify our business approach in order to
improve our ability to conduct our business in accordance with applicable laws and regulations and our Business
Code of Conduct.
Our Best-in-Class Global Ethics and Compliance Program (our “Compliance Program”) is based on (i) our Core
Values of Integrity, Performance, Teamwork, Learning and Courage; (ii) the standards contained in our Business
Code of Conduct; and (iii) the laws of the countries where we operate. Our Compliance Program is referenced
within the Company as “C2” or “Completely Compliant.” The Completely Compliant theme is intended to establish
the proper Tone-at-the-Top throughout the Company. Employees are consistently reminded that they play a crucial
role in ensuring that the Company always conducts its business ethically, legally and safely.
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 continued our reduction of the use of commercial sales representatives and processing agents,
including the reduction of customs agents.
• 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 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 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 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 relating to third
party commercial agents in non-U.S. jurisdictions.
• 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.