Ethics and Compliance

Our success is contingent on conducting our business in an ethical manner. We believe that integrity and ethical conduct are choices that our people must make every day. It is a commitment that all of our directors, officers and employees must reinforce regularly.  We incorporate these values in the Elements of our Culture, the “5Cs” (“Challenge”, “Commit”, “Collaborate”, “Choose” and “Care”), which are present in our offices around the world on posters, signs and banners translated into multiple languages.

Managing Risks

Our commitment to ethics and compliance begins at the very top of our organization. Our Board-approved Business Conduct and Ethics Policy and other ethics and compliance policies serve as guideposts for our behavior and management practices. The Business Conduct and Ethics Policy, for example, describes in clear and simple terms what is expected of our directors, officers, employees, contractors and consultants. This policy, translated in many languages, is shared with all employees as part of our new hire onboarding process and new employees are required to acknowledge their agreement to comply in writing. We also provide related training sessions and refreshers on a recurring basis.

Ultimately, our goal is to prevent, manage and mitigate any ethics and compliance risks within our walls and beyond our facilities. This includes engagement with governments, customers, suppliers, distributors and communities —while upholding the high standards of business conduct described in our policies.

Training and Monitoring

Our employees receive training on ethics and compliance when they first join our company using our online training platform. Key risk areas identified through our annual risk assessment drive the addition of new modules or the refresh of existing trainings that we use to engage our employees and foster a culture of ethics and compliance throughout the organization.

Third Party Risk

We expect all suppliers to adhere to our Supplier Code of Conduct while conducting business with or on behalf of our company. The code, translated in multiple languages, establishes minimum standards of conduct required for all our suppliers and provides examples of actual or potential non-compliance matters and illustrations of good management practices. We also encourage our business partners to share their own supplier requirements and relevant polices. This helps us align and provide consistency across our broad supply chain, adding transparency and efficiency to our risk management process.

Training and Monitoring