Values and Ethics

Being a Force for Good Starts Within

We cannot be a force for good outside our company if we don’t emphasize ethics, integrity, compliance, and transparency in our own operations. That’s why we work constantly to ensure that our employees and business partners know, understand, and live up to our Code of Conduct and high ethical standards.

Keeping our Code of Conduct Current

Our Code of Conduct—built on our vision, values, and leadership principles, and applicable to all our directors, officers, and employees—is at the heart of our values and ethics program. The code has been translated into more than 30 languages. Our employees affirm their commitment to comply with it when they first join our company, and our leaders annually certify to their compliance. The code encourages ongoing dialogue about the choices we make every day, and it helps us make sound, ethical decisions, particularly in parts of the world where rules may be less clear.

Our Code of Conduct 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 expectations, sustainability and environmental considerations, and community and social responsibility.

We also train computer-based employees through an online program that the employees are required to complete. The program generally comprises four courses per year covering specific risk areas from the code. To ensure that the policies and principles in our Code of Conduct reach all employees, we annually develop and launch ‘‘Talkabout’’ toolkits in more than 30 languages for employees worldwide. Managers are required to use the toolkits to engage in meaningful discussion with their teams regarding topics from the Code of Conduct. Kits comprise presentation slides, a discussion-leader guide, and a subtitled introductory video that includes messages from our Chief Compliance Officer and other company leaders.

In 2017, we refreshed our Code of Conduct with updated leadership messages, additional guidance on certain areas of higher risk, and case studies providing practical guidance on more complex ethical situations. In 2018, we further updated the code to reflect our updated company values. During the year, our ‘‘Values in Action’’ campaign provided employees around the world with the opportunity to show how they are living our values and helping maintain our values-based culture.

Working to Avoid Conflicts of Interest

Each year, we 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 individual contributor 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. 

Our Whistleblower Hotline

Our Business Conduct GuideLine is a whistleblower hotline available at all hours for employees or third parties to report potential violations of our Code of Conduct—anonymously if they so choose. In 2018, we made toll-free hotlines available in every country in which we do business, to make it easier to report potential violations. Potential violations can also be reported at /guidelinereport. Our GuideLine is operated by an independent third party, and it accepts reports in any language to accommodate our global workforce and customer/ supplier base. 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 Committee. We prohibit retaliation for good-faith reporting.

How we Handle Potential Ethics Violations

We take all reports of ethical violations seriously. We have a new global investigations system that enables us to investigate potential violations effectively and efficiently. Through this process we investigated at least 200 reports in 2017, 164 in 2018, and 196 in 2019. When violations occur, we take corrective action and discuss significant substantiated matters, trends, and geographic “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.