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 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 three ‘‘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.