EthicsPoint - Baker Hughes Oilfield Operations LLC

FAQs

Reporting Security & Confidentiality

About EthicsPoint

What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX that enables management and employees to work together to address fraud, abuse, and other misconduct in the workplace while cultivating a positive work environment.

This system makes it easy to report an incident about an actual or potential violation of Our Way: The Baker Hughes Code of Conduct, company policies or procedures, workplace issues like financial and auditing concerns, harassment, theft, unsafe conditions or any other violations. Reports may be made on either an anonymous or named basis. You may report anonymously with confidence on this site if you choose. In order to assist in the investigation, those reporting potential violations are encouraged to identify themselves; however, anonymous reports will also be accepted and investigated.

Why do we need a system like EthicsPoint?

Baker Hughes believes that a work environment in which all employees maintain the highest levels of integrity, conduct business in a professional manner, treat one another with dignity & respect, and strongly support open communication without repercussions creates a better place to work as well as a more productive company. Besides, it’s the right thing to do. To make it even easier for you to ‘say something’ when you ‘see something’, Baker Hughes leverages the expertise of Navex to empower you to promote ethical behavior. You may use this system to report concerns or ask questions about ethical conduct, policy violations or report any concerns that you may have.

Our employees are our most important asset. By creating open channels of communication, we promote a positive work environment and maximize productivity.

An effective reporting system augments our other efforts to foster a culture of integrity and ethical decision-making.

Reporting – General

May I report using either the Internet or the telephone?

Yes. EthicsPoint enables you to file a confidential, anonymous report via either the telephone or the Internet.

What types of situations should I report?

The EthicsPoint system allows employees to report any violation of our stated Code of Conduct, or other concern you may have.

If I see a violation, shouldn't I just report it to my manager, security, or human resources and let them deal with it?

When you observe some behavior that you believe violates our code of conduct, we expect you to report it. Ideally, you should bring any concerns forward to your direct manager or other member of our management team. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that we have partnered with NAVEX. We would rather you report anonymously than keep the information to yourself.

The investigation process does not replace proper management and employee discipline by supervisors in the regular course of business. The investigation process is intended to bring clarity to cases where it has not been established if wrongdoing has occurred or cases where managers fail to act promptly and appropriately to address an issue that requires response.

The Global Investigations Team should refer employee activities, actions, or omissions that do not represent an alleged violation of the Code, company policies, or the law, that require immediate action by specialized functions outside of Compliance, or that do not require employee discipline or remedial action to the respective functions or business units to manage in the regular course of business. Should the Global Investigations Team refer an issue, it does not imply that the issue should not be addressed but simply means an investigation may not be required by the Global Investigations Team in Compliance. While by no means all-inclusive, a few examples are as follows:

Allegation	Response by
Employee relations - Annual leave request denied by manager.	Local human resources
Cybersecurity - Phishing or third party fraud attempts.	Digital Technology Function: Report to reportphishing@bakerhughes.com
An employee who asserts they do not have the latest laptop, or a colleague is wearing too much perfume/cologne, or another is not timely cleaning out the community refrigerator.	Local leadership at the site
Concerns on the job site that a five-gallon water bottle stored on floor is partially blocking a walkway, an employee fails to wear safety glasses, or a fire extinguisher is not located near a cutting activity on-site.	HSE
Recommendation on sales or pricing process improvement.	Respective business unit
An employee threatens to cause physical harm to a coworker, or an employee is caught stealing company assets in the act/red-handed.	Security and/or local law enforcement

To report HR concerns, including an annual leave request denied by manager, overtime calculation issues and bonus-related questions, visit My HR
To report HSE, please visit: https://bakerhughes.gensuite.com/home/
To report Quality, please visit: https://my.bakerhughes.com/sites/quality-site/SitePageModern/5661/stop-work-for-quality
To report Security, please visit: https://my.bakerhughes.com/sites/security-site/SitePageModern/2149/report-a-concern
To report a suspected Cybersecurity or Data Privacy incident including virus or malware infection, computer attack, software vulnerability, data loss from computer systems, or unauthorized access or use, destruction, modification, or unintended or inappropriate disclosure of Personal Information, please follow the instructions provided here.
For general Data Privacy inquiries or issues, please visit the Digital Trust Compliance site or email the Digital Trust Compliance Office at DigitalTrustCompliance@bakerhughes.com

Why should I report what I know? What’s in it for me?

We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment. And, corporate misconduct can threaten the very existence of an entire company.

Does management really want me to report?

We certainly do. In fact, we need you to report. You know what is going on in our company - both good and bad. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the company and our people. Also, offering positive input may help identify issues that can improve corporate culture and performance.

Where do these reports go? Who can access them?

Reports are entered directly on the EthicsPoint secure server. NAVEX makes these reports available only to specific individuals within the company who are charged with evaluating the report, based on the type of violation and location of the incident. Each of these report recipients has had training in keeping these reports in the utmost confidence.

Isn’t this system just an example of someone watching over me?

No. EthicsPoint is a positive aspect of our overall philosophy that allows us to ensure a safe, secure and ethical workplace. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions, or communicate a concern. Effective communication is critical in today’s workplace and this is a great tool to enhance that communication.

We have carefully chosen the best reporting tool to meet our compliance obligations while maintaining a positive reporting environment.

Reporting Security & Confidentiality

It is my understanding that any report I send from a company computer generates a server log that shows every website that my PC connects with. Won’t this log identify me as the report originator?

NAVEX does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available.

If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside our work environment (such as one located at an Internet café or at a friend’s house) through the EthicsPoint secure website. Many people choose this option, as NAVEX data shows that fewer than 12% of reports are generated during business hours.

Can I file a report from home and still remain anonymous?

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is totally maintained.

Is the telephone toll-free hot line confidential and anonymous too?

Yes. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into the EthicsPoint Web site. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

There is a section in the report to identify yourself, if you wish.

Tips & Best Practices

I am aware of some individuals acting unethically, but it doesn't affect me. Why should I bother reporting it?

Our company promotes ethical behavior. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. You only have to consider what happened in recent corporate scandals to see the disastrous effects that a lapse in ethics can have on an otherwise healthy company. If you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report it.

I am not sure if what I have observed or heard is a violation of company policy, or involves unethical conduct, but it just does not look right to me. What should I do?

File a report. NAVEX can help you prepare and file your report so it can be properly understood. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The EthicsPoint system and report distribution ensure that implicated parties are not notified or granted access to reports in which they have been named.

What if I remember something important about the incident after I file the report? Or what if the company has further questions for me concerning my report?

When you file a report at the EthicsPoint Web site or through the EthicsPoint Call Center, you receive a unique, randomized number called a “Report Key” and are asked to choose a password. You can return to the EthicsPoint system again either by Internet or telephone and access the original report to add more detail or answer questions posed by a company representative. We strongly suggest that you return to the site in the time specified to answer company questions. You and the company now have entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.

Are these follow-ups on reports as secure as the first one?

All EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.

Can I still file a report if I don’t have access to the Internet?

You can file an EthicsPoint report from any computer that can access the Internet. You can file from home. Many public locations, including the public library, have Internet computers. If you don’t have access to or are uncomfortable using a computer, you can call the EthicsPoint toll-free hotline, which is available 24 hours a day, 365 days a year.