Codes of Conduct
Our Business Code of Conduct and Supplier Code of Conduct set clear expectations for our employees and business partners. Our codes outline how we do business and engage with each other and the community. They also affirm our commitment to integrity, ethical business practices, sustainable operations and regulatory compliance.
Does a situation make you uneasy? Are your instincts telling you something isn’t quite right? Pause and consider how to approach the situation before making a decision.
Is the behavior unethical or illegal? Is the approach consistent with our values and culture? Would you be uncomfortable talking about how the situation was handled? What are the consequences?
Speak up! Ask questions and help make the right decision. Talk it through with leadership, Human Resources, the compliance team or contact our Integrity Hotline.
Our codes apply to Board members, employees, contractors and suppliers, and each of us has a responsibility to know and abide by the defined expectations outlined in these documents. We also expect our leaders to lead by example. A violation of our codes— or related policies and practices — will result in disciplinary action, including termination of employment or contract if appropriate.
As we continue to grow in a complex and ever-changing environment, we all will encounter difficult situations where the path forward may not be absolutely clear. Our codes and related policies help us navigate in the right direction as we make ethical decisions on behalf of our company.
Annually, employees formally commit to follow our code, acknowledging their understanding of and compliance with key policies. We provide regular in-person code and compliance training at all levels of our organization.
Every employee or individual working with us has a duty to report suspected or actual wrongdoing that is illegal or in violation of our code. We have several resources available for guidance or to report a concern – leadership, Human Resources personnel, our ethics and compliance team and our Integrity Hotline. We do not tolerate any form of retaliation including threats, discrimination or discipline against anyone who reports a concern in good faith or participates in an investigation.
Our Integrity Hotline is managed by an independent third party and allows for anonymous reporting of potential violations. Our ethics and compliance team follows up to conduct investigations for appropriate resolution. Management regularly reports hotline activities and compliance investigations to the Board’s CRG Committee. Specific concerns are also reported to relevant committees, and the full Board is made aware of material items or investigations.