WHERE CAN I FIND COMPANY POLICIES?
- You can ﬁnd many of our function-related policies on our Company’s intranet site and Convercent. You can also ask your manager or Human Resources manager for copies of applicable policies.
WHAT SHOULD I DO IF MY MANGER ASKS ME TO PERFORM A TASK THAT I BELIEVE MIGHT VIOLATE OUR CODE OR A LAW?
- Raise your concerns openly and honestly with your manager. If you are not satisﬁed with your manager’s response, or otherwise feel uncomfortable speaking to your manager, raise the issue with the Legal Department.
- You should never knowingly violate our Code, a policy or a law simply because a manager directs you to do so or because you failed to ask for guidance.
HOW DO I KNOW WHEN I SHOULD SEEK GUIDANCE?
If something does not feel right, then it might not be the right thing to do. Ask yourself:
- Am I sure this course of action is legal? Is it consistent with our Values, Code and policies?
- Could it be considered unethical or dishonest?
- Could it hurt the Company’s reputation? Put our company at risk?
- Cause our company to lose credibility?
- Will this hurt other people? Employees? Customers? Consumers? Investors?
- Will it reﬂect poorly on me or the Company? How would it look on the front page of the newspaper?
SPEAK UP Q&A
WHAT HAPPENS WHEN I CONTACT CONVERCENT?
- Convercent calls are answered by an independent third party with expertise in handling hotline calls. An Interview Specialist will ask you questions and send a report to Compliance for a conﬁdential review. Appropriate professionals designated by Compliance will investigate concerns, and, if warranted, remedial actions will be taken.
ARE THERE ANY RESTRICTIONS ON SIGNING “SIDE LETTERS” AT A CUSTOMER’S REQUEST?
- You should never sign any other document or side letters that modiﬁes or interprets an existing customer agreement that relates to customer payments or that waives customer performance without the prior review and approval of the Legal Department.
WHAT IS “ANYTHING OF VALUE”?
- Corruption may involve the exchange of “anything of value.” “Anything of value” is very broad and could include goods, services or merchandise, such as gift cards, event tickets, retail certiﬁcates, entertainment, travel perks, use of vacation homes, free airfare or accommodations, special favors or a promise of future to pay.
WHAT IS A KICKBACK?
- A kickback is a form of corruption that involves two parties agreeing that a portion of sales or proﬁts will be improperly given, rebated or kicked back to the purchaser in exchange for making the deal.
- For example, a kickback might involve a supplier who oﬀers an associate a monthly payment equaling 5% of the Company’s purchases as an inducement to the associate to retain the supplier’s services.
- Kickbacks, like other forms of corruption, are unethical and prohibited under our Code, policies and the law.
DETERMINE IF YOU HAVE A CONFLICT OF INTEREST THAT SHOULD BE DISCLOSED, ASK YOURSELF THESE QUESTIONS:
- Do my outside interests inﬂuence, or appear to inﬂuence, my ability to make sound business decisions?
- Do I stand to beneﬁt from my involvement in this situation?
- Does a friend or relative of mine stand to beneﬁt?
- Could my participation in this activity interfere with my ability to do my job?
- Is the situation causing me to put my own interests ahead of the Company’s interests?
- If the situation became public knowledge, would I be embarrassed?
- Would the Company be embarrassed?
WHAT ARE EXAMPLES OF A “GOVERNMENT OFFICIAL UNDER ANTI-BRIBERY LAWS?
Government oﬃcials” may include:
- Government employees of environmental, licensing, tax and custom agencies, commissions or departments
- Representatives of public international organizations, such as the World Bank
- Mayors or other local city oﬃcials who issue permits
- Members of law enforcement, including the military, local police and other enforcement agencies
- Purchasing managers of government-run airlines, universities, school systems or hospitals
- Members of royal families
- Employees of companies that are owned by the government
- Employees of public international charities such as UNICEF
IF YOU ARE UNSURE ABOUT THE ANSWERS TO ANY OF THESE QUESTIONS, YOU SHOULD SEEK ADDITIONAL GUIDANCE IN MAKING THE RIGHT DECISION.