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Compliance and Ethics

Leadership promotes a culture of integrity

Integrity is one of our core values and it provides a strong moral and ethical foundation for all that we do. Our leadership team and Board of Directors believe that good corporate governance and the highest ethical standards are essential to our long-term success. Our Senior Vice President and General Counsel also serves as our Chief Compliance Officer and provides the Board with regular reports on our Compliance and Ethics program.

We maintain a Corporate Compliance Committee composed of members of the global executive leadership team and other senior leaders within the company. The Committee promotes integrity and compliance leadership throughout the organization and provides strategic guidance, oversight, and support of our Compliance and Ethics program. To build on our existing practices, during 2020 we created and resourced a new, dedicated function focused exclusively on Compliance and Ethics, which will bring an additional level of focus and expertise to this area.

Compliance and Ethics program

Our Corporate Compliance and Ethics program is dynamic and continually improving to ensure alignment with emerging areas of risk for our business, government and legal requirements, and lessons learned in our own business operations. Our executive leadership plays an active role in setting the right tone at the top, and we have focused in recent years on management-development programming to ensure we have the right ‘tone at the middle’ as well. Executives and managers have a responsibility for making sure that we all live up to our core values and promote a workplace that fosters a ‘do the right thing’ mentality.

We measure the impact of our program through employee surveys such as our anonymous Culture of Integrity survey. Through tools like this, we gain a better understanding of employee perceptions of important topics, including:

  • Tone at the top
  • Comfort speaking up
  • Ethical expectation-setting by leadership
  • Openness of communication
  • Managing with integrity
  • Organizational justice

We use this data in assessing the effectiveness of our program and informing its continuous improvement.

We have also adopted many policies and procedures and established related training intended to promote awareness and set expectations for ethical and responsible conduct among our workforce.

Code of Business Conduct and Ethics

Our Code of Business Conduct and Ethics is an extension of our core values. It establishes the standards of conduct that we expect from one another and owe to our customers, business partners, and stockholders. Signed by our President and CEO, the Code serves as a guide for conducting business ethically and making decisions that align with our core values. Our Code is available in nine languages to ensure its broad accessibility across our workforce. Every employee, officer, and member of the Board of Directors is responsible for upholding our Code of Business Conduct and Ethics.

We strive to create innovative and engaging compliance initiatives, including training and awareness materials, that bring our Code to life and resonate with our workforce. For example, in recent years we have utilized a ‘gamification’ approach to our annual code of conduct test and affirmation, achieving a global workforce completion rate over 99 percent in fiscal 2020. And, among other things, we previously engaged a prominent outside compliance speaker to discuss the real-world consequences of improper payments at our global sales and marketing conference.

Business partners and improper payments

Honesty, a strong commitment to ethical behavior, and compliance with applicable law are the keys to successful business dealings. Accordingly, we expect our suppliers, service providers, and other business partners to adhere to the same high standards that we do. In 2019, we implemented our Code of Conduct for Business Partners and a related training course for parties that support our sales efforts—including managed service providers, value-added resellers, systems integrators, distributors, influencers, service partners, and technology alliance partners. This document, along with our Supplier Guidelines, sets forth our expectations for ethical behavior, including a zero-tolerance policy for any and all forms of bribery, corruption, and other improper payments to gain a commercial advantage.

In addition to our outward-facing Code of Conduct for Business Partners and our Supplier Guidelines, we deploy numerous tools internally to support a culture of integrity. We emphasize the accessibility of our policies, including the translation of certain key anticorruption policies in multiple languages. In recent years, we have also introduced a number of advancements to our third-party risk management practices, and we periodically reassess these for continuous improvement.

Reporting concerns without fear of retaliation

We consider open and honest communication to be a vital part of a positive work environment and our authentic culture. We maintain a number of easily accessible internal and external methods by which our employees, business partners, and investors can report concerns relating to the ethical operation of our business, including anonymously where permitted. We are committed to maintaining a workplace in which employees can report concerns without fear of retaliation, and we have implemented communications initiatives to our managers—and also broadly across our global workforce—that reinforce this. We take reported concerns about unethical and illegal conduct seriously and conducts prompt and thorough investigations.

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