As a values-based company, we want to be known as much for our ethics and integrity as for our innovation. That’s why we work continually to ensure that our employees and business partners know, understand and live up to our Code of Conduct and high ethical standards. Between 2014 and 2016, we continued to reinforce our standards at every level of our company and help employees avoid ethical pitfalls—and report them when they occur.
At the heart of our values and ethics program is our Code of Conduct, which is built on our leadership principles and applies to all of our directors, officers and employees. The code has been translated into 32 languages; our employees learn the code and affirm their commitment to comply with it when they first join our company and annually. The code is designed to encourage ongoing dialogue about the choices we make every day and help us make great decisions, particularly in parts of the world where rules may be less clear. Our Code of Conduct describes our beliefs and provides our employees with guidance on ethical matters such as equal employment opportunity, compliance with laws and internal controls, protection of company assets and intellectual property, avoidance of conflicts of interest, fair dealing and antitrust compliance, anti-corruption and anti-bribery, sustainability and environmental consideration, and community and social responsibility. The code is available for review online.
We train employees on the Code of Conduct at least biannually. In addition, we offer four online courses per year that designated employees with computers are required to complete. To ensure that the policies and principles encompassed in our Code of Conduct reach all of our employees globally, we also develop and launch three ‘‘talkabout’’ toolkits each year, which managers use to engage in meaningful discussion with their teams regarding topics from the Code of Conduct.
During 2016, we updated our Code of Conduct with new messages from our leadership, additional guidance for higher-risk areas of concern and detailed case studies intended to provide guidance in gray areas, all written in plain and easy-to-understand language. We also created a portable pocket version for distribution to all employees. In 2017, we introduced the updated Code of Conduct through communications to managers and other employees. Our planned “Values in Action” campaign will give employees the opportunity to share self-produced videos demonstrating how they are living the values described in the code.
We annually require all employees at the level of manager and above to complete a compliance certification in which they must disclose, among other things, whether they or any of their immediate family members have a job, contract or other position with an entity that has commercial dealings with our company. Employees in other jobs at risk for potential conflicts are certified every other year. In all cases, disclosures are reviewed by our compliance department in consultation with our law department and senior management to determine whether the disclosed activity significantly influences our business. Our Chief Compliance Officer provides a report on the disclosures to the Governance and Social Responsibility Committee of our Board of Directors. In the most significant cases, the committee is tasked with determining whether a conflict exists. We typically investigate 15 to 20 potential cases of conflict each year, taking corrective action as appropriate.
Employees and third parties can report potential violations of our Code of Conduct—anonymously, if they choose—by calling several toll-free hotlines in countries where we do business. Potential violations can also be reported online at https://secure.ethicspoint.com/domain/media/en/gui/38923/index.html. Our GuideLine is operated by an independent third party and accepts reports in any language to accommodate our global workforce, customers and suppliers. All reports are investigated under the direction of our Chief Compliance Officer, in consultation with the law department and senior management and with oversight from the Governance and Social Responsibility Committee. We prohibit retaliation for good-faith reporting.
We take all reports of ethical violations seriously. We investigated approximately 180 complaints in both 2015 and 2016. When violations occur, we take appropriate corrective action and discuss significant substantiated matters, trends and hotspots with our senior leadership and Board of Directors to promote transparency, good governance and ongoing learning. We also publish general investigation metrics on our internal website.