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Advancing Reservoir Performance

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A LETTER FROM MARTIN CRAIGHEAD Dear Colleagues: At Baker Hughes, we know that with global reach comes global responsibility. We take pride in our reputation for delivering high-quality products and services in a manner that never compromises our integrity or our standards of business conduct. R. C. Baker and Howard Hughes set the foundation more than a century ago with their groundbreaking innovations. Today, their legacy and our reputation depend on you—people who know that no amount of financial success is more important than doing what is right. Nothing should compromise our steadfast commitment to integrity. The Baker Hughes Business Code of Conduct reinforces our Core Values of Integrity, Teamwork, Performance, Learning, and Courage. This book sets out the basic expectations of the company and provides information about where to find more detailed standards and procedures on particular topics. It is based on our shared beliefs and commitment to compliance at every level of the company. All Baker Hughes employees, without exception, have a responsibility to read, understand, and strictly adhere to the principles contained in our Code of Conduct. Failure to do so can put Baker Hughes and our employees at risk. We also have the duty to promptly raise any question and report any concern regarding the company’s failure to meet these standards. Baker Hughes policy prohibits retaliation against an employee who reports such a violation or concern in good faith. We all share the responsibility of making our Code of Conduct a central part of our everyday business activities. Those with whom we do business expect and deserve nothing less. Our reputation and future success depend on each of us taking personal responsibility for living the values outlined in our Code of Conduct. By understanding and complying with the Code of Conduct, we can continue to be known as a company that delivers excellent financial returns while never compromising our Core Values. Thank you for your hard work and continued commitment to maintaining the Baker Hughes reputation for high ethical standards. Sincerely,

Martin Craighead Chairman and CEO 2

Baker Hughes Business Code of Conduct

BAKER HUGHES CORE VALUES

Integrity Teamwork Performance

Integrity is the foundation of our individual and corporate actions.

Teamwork leverages our individual strengths.

Performance excellence will drive the results that differentiate us from our competitors.

Learning

A learning environment is the way to achieve the full potential of each individual and the company.

Courage

Courage empowers us to lead boldly and act decisively. 3

TABLE OF CONTENTS 5 Introducing Our Code of Conduct 7 Using Our Code 8 Seeking Guidance and Raising Concerns

37 International Trade and Transactions 38 Antiboycott Laws 40 Import and Export Controls 41 U.S. and International Economic Sanctions

9 Caring for Our People and Communities 10 12 13 14

Employment Practices Human Rights Health, Safety, and Environment Substance Abuse (Drugs and Alcohol)

15 Protecting Our Assets 16 18 20 23

Financial Integrity Communications Use of Company Assets Conflicts of Interest

25 Operating Our Business the Right Way 26 28 30 36

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Competition and Antitrust Laws Inside Information and Insider Trading Antibribery Money Laundering

43 Employee Compliance and Reporting 44 Observance of Our Code 45 Protection from Retaliation 46 Employee Resources for Reporting and Asking Questions 47 Code of Conduct Definitions 48 Glossary of Terms 50 Index 53 Acknowledgment and Agreement

Baker Hughes Business Code of Conduct

Introducing Our Code of Conduct At Baker Hughes, we know global reach equals global responsibility. As our operations enter new territories and our employee population continues to grow, we all have an ongoing duty to conduct business ethically and legally. Our company’s reputation, success, and progress depend on our ability to act responsibly and with careful consideration in situations that may present legal or ethical dilemmas. This Code of Conduct (Code) contains the rules and guidelines with which we as Baker Hughes employees must comply every day. Read it. Understand it. As employees of Baker Hughes, we all receive regular training on our Code to assist us in following its letter and spirit. Our Code incorporates our five Core Values: Integrity, Teamwork, Performance, Learning, and Courage. It outlines the behaviors we must follow to maintain our company’s ethical standards. It shows us how to use our good judgment to resolve ethical dilemmas and provides the contact information we should use when we have questions or concerns. Our employees are the indispensable ingredient that holds our company together, reinforces its reputation for excellence, and ensures its progress and success. We are the foundation on which our company is built, and we are responsible for its global legacy.

INTRODUCING OUR CODE OF CONDUCT What are my responsibilities? Familiarize myself with and follow the policies, laws, and Conduct business according to the highest legal and eth Report concerns of known or suspected misconduct imm Seek guidance from a supervisor, the Legal department, o

(HR) if in doubt. Our Code imposes heightened duties on supervisors. Those supervise other employees are expected to Promote compliance by example. Be a role model for

ethical behavior Support and take part in ethics and compliance activities,

such as training Treat all employees fairly and with respect Hold team members accountable for principled performa Enforce our Code consistently Ensure all team members understand our Code’s

requirements and that employees have the resources to comply with the company’s expectations Encourage employees to seek guidance and speak up Provide support to employees asking questions or

raising concerns. Maintain an open-door policy Protect employees from retaliation 6

Baker Hughes Business Code of Conduct

USING OUR CODE As employees, directors, and officers of Baker Hughes, we have made a commitment to understand and follow the principles laid out in our Code. While the Code cannot address every challenging situation, it provides contact information and additional resources to use when in doubt. Our Code is supplemented by policies and procedures on a range of topics. When coupled with our Ethics and Compliance Training Program, our Code and policies contain everything necessary to help us make sound, ethical decisions.

Definitions Words with legal, technical, or particular meanings are defined throughout this Code. Look for definitions embedded in the Code sections that follow. Definitions also appear in the glossary.

Red Flags Certain sections contain red flags, which may indicate a violation of this Code, applicable law, or company policy. If you encounter a red flag, seek immediate assistance before proceeding.

Although we all may be subject to the laws and regulations of different countries, each of us is responsible for knowing and following the laws that apply to us wherever we work. Our Code forms the principles for business conduct expected by our company. Where local customs, laws, or regulations differ from our Code, you should apply our Code or local requirements, whichever sets the highest standard of behavior. If you are in doubt, always seek assistance before proceeding.

What are my responsibilities? Each section of this Code contains a list of actions we should take to meet our company’s expectations. These lists also may contain details about where to seek assistance or find more information.

Question and Answer Examples of situations we may encounter, along with guidance about how to address them, can be found throughout this Code. These examples provide insight about how the sections apply in our everyday operations.

Consequences for violating our Code Violations of our Code may carry serious consequences, including disciplinary action up to and including termination, and possible civil or criminal liability. We all have a duty to report any known or suspected unethical or unlawful conduct through the proper channels.

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SEEKING GUIDANCE AND RAISING CONCERNS The decision to report a concern or problem is not always easy, but we are encouraged to voice concerns and seek help no matter what the nature of the problem or how minor it may appear. We may ask questions, seek guidance, and report concerns to a manager, HR representative, or the Legal department. Concerns also may be reported to the Business Ethics Help Line. Baker Hughes will make every effort to keep confidential all investigations as well as the statements and other information employees report.

If you are in doubt about whether to seek guidance or raise concerns, ask yourself: Is the action legal? Is the action in line

Retaliation An act that negatively affects an employee in reaction to the employee filing a complaint or legal proceeding, or for participating in an investigation or legal hearing. Examples may include, but are not limited to, termination, loss of wages, or change in work hours.

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with our company Core Values?

Our company strives to investigate all concerns promptly and fairly. All concerns are presumed to be good-faith reports at the outset of an investigation. For more information about how to report concerns and our investigation process, see the Encouraging Employee Compliance and Reporting section in this Code.

Does it comply with

Protection against retaliation

What would others think

our Code? Could it cause any risk

to me or our company?

Our company does not tolerate any form of retaliation against employees who make a good-faith report and/or participate in investigations for known or suspected ethical or legal misconduct or policy violation. If you believe you or others are the subject of retaliation, you should immediately notify HR, the Legal department, the Chief Compliance Officer, or the Business Ethics Help Line. For more information, see our Global Antiretaliation Policy.

about this action? How would this look if

the action were reported to the public? Does it feel right?

QUESTION

ANSWER

What is the role of the Ethics and Compliance group in overseeing our Code?

Our company’s Ethics and Compliance program is overseen by our Chief Compliance Officer, who manages various aspects of the program, including implementation and enforcement of our Code of Conduct. As part of the Legal department, the Ethics and Compliance group supports Baker Hughes business in meeting its ethical and legal obligations, and effectively managing or mitigating identified ethics and compliance risks. Our Ethics and Compliance group also is responsible for helping employees and others resolve ethical dilemmas and comply with our company’s Code and policies.

Baker Hughes Business Code of Conduct

Caring for Our People and Our Communities At Baker Hughes, the safety and integrity of our people and communities always come first. You are our greatest pride, and the trust of our communities is our greatest reward. We always strive to minimize our impact on the environment while treating each other fairly and with respect.

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EMPLOYMENT PRACTICES Baker Hughes is committed to a workplace free from discrimination and harassment. Our policy is to provide equal opportunity for everyone in recruiting, hiring, developing, promoting, and compensating employees, without regard to race, color, age, religion, ethnicity, disability, gender, national origin, sexual orientation, or any other basis protected under the law. We expect everyone to be treated with fairness, honesty, and professionalism in their business relationships. Our workplace is one in which merit is the means to success. We hire, evaluate, and promote employees based on their abilities, achievements, experience, and performance. We do not tolerate harassment, including ethnic, racial, religious, or sexual. Behavior creating an intimidating, hostile, malicious, degrading, humiliating, or offensive environment— whether verbal or physical—violates our policy and may be against the law. If you believe you have experienced, witnessed, or heard of incidents of unequal treatment or harassment in violation of our policies, you must immediately notify your supervisor or HR representative. Our company will promptly investigate each complaint and take corrective action if appropriate. Anyone making such a complaint or participating in an investigation will be protected against retaliation.

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Discrimination Failure to provide equal opportunity on the basis of someone’s race, gender, religion, or any other class protected by law.

Harassment An unwanted or hostile situation created for the purpose of violating an individual’s dignity, creating an intimidating, malicious, degrading, humiliating, or offensive environment for that individual, or interfering with an individual’s ability to perform his or her job. It could be conduct related to age, gender, marital status, pregnancy, race, national or ethnic origin, color, disability, religion, sexual orientation, or any other protection guaranteed by law.

Baker Hughes Business Code of Conduct

What are my responsibilities?

QUESTION

Respect all coworkers, clients, and business partners.

Arjun, a manager, overhears his colleague, Ludo, say to his employee, Sheila: “How old are you? Isn’t it time you retire?” Although she finds the comment on her age offensive, Sheila does not complain. Does Arjun have any obligation to act?

Be sensitive to how my behavior affects those around me. Never tell jokes

that may offend someone else. Put myself in the other person’s position and consider my actions. Speak up if I find someone’s actions offensive or hostile. Report the situation to a supervisor, HR representative, or the Business

Ethics Help Line if I personally experience or am aware of any act of discrimination or harassment. Seek guidance from an HR representative or the Legal department if in

doubt about the appropriate action to take. See our Global Equal Employment Opportunity and Antiharassment

Policy and Global Antiretaliation Policy for more information.

ANSWER As a manager, Arjun is held to a heightened standard of conduct. Ludo’s comment on Sheila’s age is inappropriate. Although Sheila has not complained about her supervisor’s comment, Arjun still has an obligation to address the conduct directly with Ludo and report the issue to HR.

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HUMAN RIGHTS We support the protection of human rights and we expect the same of our business partners and suppliers. 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, antiharassment, and maintaining a healthy and safe work environment. We promote a culture of ethical and lawful behavior, consistent with Baker Hughes policies. We should always be alert to evidence of human rights abuses around us.

What are my responsibilities? Comply with all applicable labor laws where I work. Be vigilant of possible human rights violations, such

as forced or child labor. Know the minimum age requirement for all employees. Understand how human rights affect our relationships

with our suppliers, customers, and communities.

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Seek guidance from an HR representative or the

Legal department if I believe this provision of the Code conflicts with the laws, customs, or practices where I work. Report immediately any suspected violations of human

rights to a supervisor, HR representative, the Legal department, or the Business Ethics Help Line.

QUESTION

ANSWER

What freedoms are included in human rights?

Some human rights apply specifically to the workplace. These guarantee dignity and fairness for employees, and include the right to organize and bargain collectively, as well as the right to fair pay and working conditions. Other human rights, such as the prohibitions against human trafficking, slavery, forced and child labor, torture, and punishment, protect people more generally from cruel treatment.

Baker Hughes Business Code of Conduct

HEALTH, SAFETY, AND ENVIRONMENT We are committed to protecting our people, respecting the environment, and earning the trust of our customers and communities. Safety and environmental protection are conditions of employment for everyone who works at Baker Hughes. We all share responsibility for our own safety, as well as that of our coworkers and communities. We believe doing a job well means doing it safely, even if it takes longer to complete. All employees are authorized and obligated to Stop Work when they feel an activity might present an unacceptable risk to people or may harm the environment.

QUESTION While working on a rigsite, Luis thinks there is danger of a surface spill. What should he do?

ANSWER Luis should immediately use his Stop Work authority. At Baker Hughes, each of us has the right to stop a job if we see an unsafe situation. If, after exercising his Stop Work authority, Luis still is unable to prevent the problem, he should promptly report it to his line manager, a local HR representative, or the Legal department to allow for early investigation.

We must comply with applicable laws, regulations, and procedures. Our Health, Safety, Environment, and Security (HSE&S) Management System helps us achieve our safety and environmental stewardship goals. Violations of applicable health, safety, and environment (HSE) laws, policies, or procedures, or the intentional failure to prevent violations or take reasonable corrective actions will result in appropriate disciplinary action up to and including termination.

What are my responsibilities? Comply with all applicable HSE laws and regulations. Complete all assigned training on health and safety issues. Stop work immediately if I encounter an unsafe working condition. Report all HSE incidents promptly to a supervisor

and cooperate with efforts to investigate the incident. Conserve resources, such as water and energy, and reduce waste

and greenhouse gas emissions. Familiarize myself with our HSE&S Management System. Seek advice from a supervisor if I am concerned about my own

safety or the safety of those around me.

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SUBSTANCE ABUSE (DRUGS AND ALCOHOL) We promote a positive work environment, free from the harmful effects of drugs or alcohol. Drugs and alcohol may affect everyone’s safety. Working under the influence of either substance impairs our judgment and slows our reflexes, which can have a negative effect on our job performance and can cause serious safety hazards. Our company is committed to providing a safe workplace and complying with drug and alcohol laws in the countries where we operate. We do not tolerate the possession, purchase...