Our success is contingent on conducting our business in an ethical manner. Providing clarity on what our expectations are with respect to ethical and compliant behavior also promotes trust, transparency and reliability among our stakeholders.
We set and communicate high compliance standards to drive ethical behavior by our employees. Our Business Conduct and Ethics Policy, which applies to all ESI directors, officers and employees as well as our contractors and consultants, is the foundation of our integrity and ethics principles and serves as the ethical compass of the company. Each year, all full-time employees, including our executive officers, are required to certify that they have read, understand and will comply with this Policy.
Our Business Conduct and Ethics Policy and other material policies are translated in relevant languages in order to be accessible and understood by the large majority of our employees and made available centrally on our intranet.
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 are shared with all employees, starting with our onboarding process. Any new employee is required to acknowledge in writing their agreement to comply with this Policy.
We expect our suppliers, contractors, sales representatives and any other third-party doing business with ESI to similarly act in a manner consistent with our core values and our Business Conduct and Ethics Policy. We also expect our suppliers around the world and their subcontractors to fully comply with our Supplier Code of Conduct as well as all applicable laws and industry standards.
Training and Monitoring
We require training on our Business Conduct and Ethics Policy and other key corporate policies. Topics covered include bribery, labor & human rights, anti-harassment and discrimination. We also provide related training sessions and refreshers on an annual basis. New modules or refresh of existing trainings are added where and when necessary. In addition, we offer targeted specialized ethical and compliance training for those employees in certain locations or functions, either online or in person.
We use all these training opportunities to foster a culture of ethics and compliance throughout the organization. Ultimately, our goal is to prevent, manage and mitigate any ethics and compliance risks within our walls and beyond our facilities.
Third-Party Risk
Our Supplier Code of Conduct provides minimum standards to deter improper actions and promote ethical and responsible conduct related to human rights, labor, health & safety, the environment, and others. Where appropriate, we require suppliers to review and acknowledge our Supplier Code of Conduct before any transaction with us. We also encourage our business counterparties 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.
We monitor the performance of our suppliers and manage third-party risk using a variety of preemptive screening tools. Compliance-sensitive third parties also receive periodic training. Third parties identified as being located in high-risk jurisdictions or countries under regulatory scrutiny are also required to sign and provide certificates acknowledging compliance with applicable trade laws and regulations. We also request that they complete an online compliance course specifically related to our Foreign Corrupt Practices Act/Anti-Corruption Policy through our Skillsoft training tool to emphasize our expectations with respect to their full adherence to our ethical standards.