Our compliance policies are approved by the board’s Nominating and Corporate Governance Committee and reviewed regularly and assessed for effectiveness. All employees globally, as well as contractors, are trained, tested and must attest that they have read and understand the policies upon hire and annually thereafter. Test scores are assessed to ensure understanding. Any breach of our policies is investigated, and, when necessary, appropriate actions are taken, which may include termination of employment.
Procedures are in place requiring that gifts, meals and entertainment given to or received from a business partner or government official above certain thresholds must be reported to and approved by the compliance department.
As part of our Global Reporting and Anti-Fraud Policy, we have a Protected Disclosure Hotline (formerly known as the Whistleblower Hotline) that can be accessed easily through both external and internal resources.
We have a number of global policies covering a range of issues. All are made available in 12 languages:
All employees and contractors are required to complete training at least annually on several of our compliance, security, human resource, and business continuity policies, including: