Ethics and Compliance Program

Our Ethics and Compliance Program is an integral part of our daily business operations to ensure that all employees around the world understand and are committed to complying with all applicable laws and company values. We strive to make certain that every business decision is guided by the same commitment to operate with high ethical standards and integrity. To facilitate this commitment to integrity we have a(n):

  • Global, written Code of Business Conduct available in 7 languages
  • Supplemental Code of Conduct for our CEO and senior finance employees
  • Dedicated ethics helpline accessible from anywhere in the world at any time, and a strictly enforced "no retaliation policy" to promote reassurance in using the helpline
  • Ethics office e-mail address to receive questions and complaints as well as web-enabled reporting
  • Employee complaint procedure for accounting and auditing matters
  • Code of Conduct training required of all employees, including senior management
  • Annual ethics certification process that includes all senior management and officers

Annually, each salaried employee is required to read and certify compliance with our Employee Code of Business Conduct and Ethics. The code contains our anti-corruption policy, and in 2015, 100% of our employees read and certified their compliance to the code and all policies contained within.  Additional training on our anti-corruption policy is conducted annually to select departments, offices and employees. In 2015, 3.1% of employees in the Americas, 10% of those in Europe and 1% of those in Asia received additional training on our anti-corruption policies. Each year, our material agents and distributors are asked to certify their compliance with anti-corruption laws. In 2015, 100% of the Company's agents and distributors received communication on our anti-corruption policy.