baker Hughes, found in violation of the FCPA, implemented a Corporate Ethics and Anti-Corruption Compliance Program. One component of this program, as described in a press release, included:

	1	keeping all commercial agents previously used and requiring that they undergo ethics education.
2		implementing non-required, voluntary FCPA training for the top management only.
3		putting in place a whisteblower program to encourage timely reporting of FCPA violations.
4		inviting the SEC staff to set up an office in the corporate headquarters for monitoring purposes