Ethics & Compliance

Our Board and management team sets the tone from the top for our culture and hold all employees and consultants accountable for operating ethically and in compliance with labor laws, financial regulations and other standards that apply to our businesses. We provide the relevant tools, resources and training to help employees succeed and to recognize ethical decision-making.

Policies

We have a number of global policies covering a range of issues. All are made available in eight languages:

  • Code of Business Conduct
  • Personal Trading Policy
  • Anti-Bribery Policy
  • Reporting and Anti-Fraud Policy
  • Anti-Money Laundering and Sanctions Policy
  • Business Gifts, Meals and Entertainment Policy
  • Each policy is reviewed regularly and assessed for effectiveness
  • Policies are approved by the Board's Nominating and Corporate Governance Committee
  • All employees globally, including contractors, are trained, tested and must attest that they have read and understand the policies upon hire and annually thereafter
  • Scores are assessed to ensure understanding
  • Our Global Compliance team is led by the Vice President for Compliance, who reports to the General Counsel
  • Any breach of our policies is investigated and 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.

Protected Disclosure

We have a Protected Disclosure Hotline (formerly known as the Whistleblower Hotline) which can be accessed easily through both external and internal resources.

  • We use EthicsPoint as our third-party service provider
  • Inquiries can be made anonymously subject to the laws of the country the employee is based in
  • Every inquiry is fully investigated and actions are taken as appropriate

Contact information

ethicspoint.com / (866) 294 4493