Maintaining Ethical Culture: Compliance, Anti-Bribery & Corporate Integrity
Maintaining a Strong Ethical Culture
Our company has earned a solid reputation for being ethical and trustworthy. To uphold this, we enforce strict anti-bribery and anti-corruption policies, promoting honesty and integrity in our interactions with customers, business partners, and colleagues.
Our Approach
Our Ethics and Compliance Program is built on our core value of doing what’s right. We ensure high ethical standards across the organization by delivering education, training, and conducting risk assessments. These efforts help reinforce adherence to our Global Code of Conduct, policies, and legal requirements.
We assess our ethical culture through an annual survey administered by an external organization. This survey provides insights into our company’s culture, helping us benchmark our progress against industry standards and track improvements year-over-year.
2023 Actions and Performance
In 2023, the survey results highlighted our employees’ confidence in our commitment to maintaining an ethical culture and adhering to our Global Code of Conduct. Employees indicated a strong understanding of our policies and trust in our “safe to say” environment. Our ethical performance consistently meets or exceeds industry benchmarks, reflecting the strength of our Ethics and Compliance Program.
We regularly benchmark our program through the Business Ethics Leadership Alliance (BELA) and the Department of Justice Guidance. The Enterprise Chief Ethics and Compliance Officer shares these results with executive leadership and the Audit Committee.
This marks the 13th time we’ve been recognized for ethical leadership since the launch of the Ethisphere list in 2006. We are honored to be recognized as one of the World’s Most Ethical Companies® in 2024.
Alignment with Our Global Code of Conduct
All employees must complete annual training and acknowledge our Global Code of Conduct (Code). The training covers a range of topics on a rotating basis, such as anti-bribery and corruption, insider trading, conflicts of interest, and more. In 2023, the training focused on reporting Code violations, protecting company assets, and managing conflicts of interest. Employees must sign an attestation of understanding after completing the training.
In 2023, 99.9% of active employees completed this training. Knowledge was assessed through quizzes to ensure understanding of the material.
Regular Program Review
Our Ethics and Compliance team, Corporate Special Investigations Unit, and other compliance personnel continually assess the effectiveness of our Code. This includes monitoring the Ethics Hotline, releasing an Annual Report of Investigations, conducting annual surveys, and tracking employee views on compliance policies.
Survey results are shared with leaders to identify strengths and areas for improvement, along with guidance for fostering ethics-related discussions within teams.
Reporting Unethical Behavior
We provide multiple channels for employees, customers, and business partners to report unethical or fraudulent activity, including an Ethics Hotline and an online reporting form, both of which allow anonymous submissions. Employees can also report concerns directly to the Enterprise Chief Ethics and Compliance Officer or other designated compliance officers.
We remind employees regularly about these reporting options. In 2023, all reports made through the Ethics Hotline were thoroughly reviewed and investigated.
Anti-Bribery, Anti-Corruption, and Conflicts of Interest
We are committed to supporting global and local efforts to combat corruption and financial crimes. To stay vigilant, we conduct annual risk assessments on anti-bribery and corruption (AB&C). The Enterprise Chief Ethics and Compliance Officer oversees the AB&C program and reports risks to the Audit Committee.
In 2023, all board members and senior management received materials on AB&C trends, and no regulatory charges were filed against the company.
Ongoing Ethics and Compliance Training
We provide additional, role-specific training to employees based on their responsibilities. This includes topics like financial crimes, anti-money laundering, and anti-bribery and corruption for those in high-risk roles.
Looking Ahead
In 2024, we remain focused on evaluating our Ethics and Compliance Program, improving employee communication and training on key risk topics, and continuing to monitor our ethical culture through annual surveys.
Our company has earned a solid reputation for being ethical and trustworthy. To uphold this, we enforce strict anti-bribery and anti-corruption policies, promoting honesty and integrity in our interactions with customers, business partners, and colleagues.
Our Approach
Our Ethics and Compliance Program is built on our core value of doing what’s right. We ensure high ethical standards across the organization by delivering education, training, and conducting risk assessments. These efforts help reinforce adherence to our Global Code of Conduct, policies, and legal requirements.
We assess our ethical culture through an annual survey administered by an external organization. This survey provides insights into our company’s culture, helping us benchmark our progress against industry standards and track improvements year-over-year.
2023 Actions and Performance
In 2023, the survey results highlighted our employees’ confidence in our commitment to maintaining an ethical culture and adhering to our Global Code of Conduct. Employees indicated a strong understanding of our policies and trust in our “safe to say” environment. Our ethical performance consistently meets or exceeds industry benchmarks, reflecting the strength of our Ethics and Compliance Program.
We regularly benchmark our program through the Business Ethics Leadership Alliance (BELA) and the Department of Justice Guidance. The Enterprise Chief Ethics and Compliance Officer shares these results with executive leadership and the Audit Committee.
This marks the 13th time we’ve been recognized for ethical leadership since the launch of the Ethisphere list in 2006. We are honored to be recognized as one of the World’s Most Ethical Companies® in 2024.
Alignment with Our Global Code of Conduct
All employees must complete annual training and acknowledge our Global Code of Conduct (Code). The training covers a range of topics on a rotating basis, such as anti-bribery and corruption, insider trading, conflicts of interest, and more. In 2023, the training focused on reporting Code violations, protecting company assets, and managing conflicts of interest. Employees must sign an attestation of understanding after completing the training.
In 2023, 99.9% of active employees completed this training. Knowledge was assessed through quizzes to ensure understanding of the material.
Regular Program Review
Our Ethics and Compliance team, Corporate Special Investigations Unit, and other compliance personnel continually assess the effectiveness of our Code. This includes monitoring the Ethics Hotline, releasing an Annual Report of Investigations, conducting annual surveys, and tracking employee views on compliance policies.
Survey results are shared with leaders to identify strengths and areas for improvement, along with guidance for fostering ethics-related discussions within teams.
Reporting Unethical Behavior
We provide multiple channels for employees, customers, and business partners to report unethical or fraudulent activity, including an Ethics Hotline and an online reporting form, both of which allow anonymous submissions. Employees can also report concerns directly to the Enterprise Chief Ethics and Compliance Officer or other designated compliance officers.
We remind employees regularly about these reporting options. In 2023, all reports made through the Ethics Hotline were thoroughly reviewed and investigated.
Anti-Bribery, Anti-Corruption, and Conflicts of Interest
We are committed to supporting global and local efforts to combat corruption and financial crimes. To stay vigilant, we conduct annual risk assessments on anti-bribery and corruption (AB&C). The Enterprise Chief Ethics and Compliance Officer oversees the AB&C program and reports risks to the Audit Committee.
In 2023, all board members and senior management received materials on AB&C trends, and no regulatory charges were filed against the company.
Ongoing Ethics and Compliance Training
We provide additional, role-specific training to employees based on their responsibilities. This includes topics like financial crimes, anti-money laundering, and anti-bribery and corruption for those in high-risk roles.
Looking Ahead
In 2024, we remain focused on evaluating our Ethics and Compliance Program, improving employee communication and training on key risk topics, and continuing to monitor our ethical culture through annual surveys.
Companies