1. Costs & Benefits of GEs Anti-Corruption Program Josie Jardim General Counsel Latin America Diretora Jurídica para América Latina GE Latin America Conference on Corporate Responsibility for Promoting Integrity and Fighting Corruption

2. Agenda Highlights of GEs Anti-Corruption Program Costs Benefits The importance of the individual behavior Additional Thoughts

3. 3 / GE / Highlights - GEs anti-corruption program Oldest remaining company in the Dow Jones….not because we are perfect, but because weve learned from our compliance history and mistakes and weve adapted. Not just anti-corruption rhetoric Not limited to FCPA compliance

4. 4 / GE / Costs – the obvious $$$ & Time Prevention: top compliance team, training, communication, policies & procedures, procedures, controls Detection: audits, ombuds program, surveys, metrics, Session D, early warning system Response: investigations, discipline, process improvement Leadership Prevention Detection Response If there isnt a process that can be measured, the compliance program does not exist

5. 5 / GE / Costs – The not so obvious Unfair Competition Though calls on GE Leaders who do not get it Being so vocal about our anti-corruption program makes us sometimes cutucar a onça com vara curta

6. 6 / GE / Benefits – The obvious Protects our Reputation Avoidance of regulatory fines, penalties or lost licenses The rules of the game are clear: dos and donts …black and white---legal & ethical Disciplined Processes Early identification of issues Reputation 2009 Hesburgh Award … exemplary ethical & governance practices A Worlds Most Ethical Company … 07 – 09

7. 7 / GE / Benefits – The not so obvious Promotes Growth. Its a competitive advantage w/ clients Promotes the rule of law in the countries where we operate It raises the bar It provides a safety net for when formal controls are weak or absent In the war for talent, its a retention tool

8. 8 / GE / Compliance depends on individual behavior…

9. 9 / GE / Although some developed world corporations will affirmatively implement anti-corruption programs because of affirmative benefits inside the company, in the marketplace and in broader global society, many others will only do so if there is a real threat of negative impact--of national prosecutions causing catastrophic problems... Ben W. Heineman The Atlantic article - Transparency International USA February 2010 The additional push…

10. QUESTIONS ?

11. Thank You Obrigada Gracias