Questo Baker Hughes, found in violation of the FCPA implemented a Corporate Ethics and Ants Corruption Compliance Program. One component of this program, as described in a press release, included keeping all commercial agents previously used and requiring that they undergo ethics education implementing non-required, voluntary FCPA training for the top management only putting in place a whisteblower program to encourage timely reporting of FCPA violations inviting the SEC staff to set up an office in the corporate headquarters for monitoring purposes