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.