Governance, Ethics and Risk Management 

Integrity, respect, teamwork, innovation and courage — our core values — are fundamental to our reputation and central to our philosophy of corporate governance. Guided by our Code of Conduct, we uphold the highest standards of legal and ethical conduct to do what is in the best interest of our stakeholders, the environment and society.

While some of our standards and rules reinforce legal imperatives in places where we operate, each one of them reflects our commitment to fairness, honesty and ethical business practices. Read more about our approach to governance, ethics and compliance in our  2019 Annual Report and on our website

Code of Conduct

Our Code of Conduct embodies our approach for managing employment, labor relations, human rights and diversity, as well as company policies on equal employment opportunity, affirmative action and harassment. It reinforces our values and describes how we interact with our customers, suppliers and colleagues. The essence of our Code is simple:

  • We act lawfully and ethically
  • We ask if we have a question about the Code or an ethics issue
  • We speak up to report concerns about unethical conduct `

Signed by our chairman and CEO, the Code applies to our Board of Directors and every one of our employees, regardless of role or location. We also expect that all entities doing business with us practice the highest legal, moral and ethical standards as outlined in our Business Partner Code of Conduct. Read more about our approach to supply chain transparency and performance.


Our Code of Conduct and associated Anti-Bribery and Corruption Policy hold all our employees to the highest standards of integrity and legal compliance everywhere we do business. Our Board of Directors oversees the policy, which prohibits all company employees from giving and offering anything of value in exchange for business advantage. This includes a complete ban on facilitation payments to secure routine government functions, even though such payments are permissible under the Foreign Corrupt Practices Act.

All our business partners and service providers are risk-rated and vetted, and higher risk third parties undergo enhanced compliance assessments. We use a third-party vendor to conduct compliance screenings from thousands of global public record databases. These screenings help identify any potential business partners who are not upholding our high standards for ethics and Code of Conduct.

Upholding Our Code

The Audit Committee of our Board of Directors annually reviews our compliance program, including compliance with the Foreign Corrupt Practices Act. We review any significant ethics and compliance matters at least five times per year. On the local level, our executive-level global Business Integrity Council and region-level councils operationalize compliance practices and raise local issues to the executive-level council to consider and fix. Read more about our Corporate Governance Guidelines and board committees and charters.

All (100%) salaried employees complete an annual Code of Conduct training program, including an attestation of their compliance. The training is role-based so that each employee focuses on three to four topics that are most relevant to their position within their company. For example, in 2019, we required the anti-corruption training module of employees in service roles.

Any employee who has a legal or ethical concern can contact the Ethics HelpLine, or get help within the Human Resources and Legal departments or the Ethics and Compliance Group. We take violations of our Code of Conduct seriously by investigating all reports to the Ethics HelpLine and taking immediate action to ensure compliance. Retaliatory actions are not tolerated.