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Ethics & Compliance

Our board and management team set the tone 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 relevant tools, resources and training to help employees succeed and to recognize ethical decision-making. Our compliance team is led by the Vice President for Compliance, who reports to the General Counsel.

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 use EthicsPoint as our third-party service provider: / (866) 294-4493
  • Inquiries can be made anonymously subject to the laws of the country in which the employee is based
  • Every inquiry is reported to the chair of the Audit Committee at the same time it is reported to management
  • Every inquiry is fully investigated, reported to the Audit Committee and actions are taken as appropriate


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:

  • Code of Conduct
  • Information Security and Privacy
  • Workplace Harassment
  • Personal Trading
  • Business Continuity Awareness
  • Additionally, relevant job types and business units are required to complete specific training that covers topics such as anti-money laundering, anti-bribery, hiring manager practices, data governance and regulatory compliance
  • Each policy is reviewed regularly and assessed for effectiveness
  • Policies are approved by the Board's Nominating and Corporate Governance Committee
  • Scores are assessed to ensure understanding