While our Code covers many specific topics, as a multinational company involved in numerous types of businesses with many different capabilities, we are not covering every potential legal or compliance requirement. All those requirements are critical as we operate in our principle-based approach. Along with the Governance Priorities in the Stewardship Framework, we also build our governance capability with our bottom-up approach of employees utilizing “stop, think, and ask” and our Risk Management System.
Stewardship & Compliance
Requirements for our Principle-Based Approach
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Current and Prior
“Our goal is to help move toward a society where everyone has the opportunity to realize their potential. What this requires is a society based on equal rights and mutual benefit, where people succeed by helping others improve their lives.”
Stop. Think. Ask.
Making Informed Choices
As employees and supervisors, we have a responsibility to uphold Our Values and our PBM culture. We must always be aware of the potential stewardship or compliance risks or questions that may arise in our work situations and act accordingly. This means always stop, think, and ask, if there is any uncertainty, before making decisions that could affect our company, our constituents, or ourselves.
Stop, think, and ask is a simple but effective way to ensure that we are making the best possible choices in any circumstances where there is a compliance risk or question that we are unfamiliar with or unclear how to best address. It is not always easy to determine the “right” thing to do in a particular business or work situation. Sometimes a law or policy clearly dictates the outcome, but often a situation will require interpretation to decide a course of action that is most aligned with Our Values and principles.
Thinking through a situation alone may not result in the same quality of decision making as when we seek the knowledge of others. The engagement of other knowledgeable resources in the decision-making process increases the likelihood that all the facts and alternatives are considered.
Stop, think, and ask is a simple but effective way to ensure that we are making the best possible choices in any circumstances where there is a compliance risk or question that we are unfamiliar with or unclear how to best address. It is not always easy to determine the “right” thing to do in a particular business or work situation. Sometimes a law or policy clearly dictates the outcome, but often a situation will require interpretation to decide a course of action that is most aligned with Our Values and principles.
Thinking through a situation alone may not result in the same quality of decision making as when we seek the knowledge of others. The engagement of other knowledgeable resources in the decision-making process increases the likelihood that all the facts and alternatives are considered.
When making decisions or fielding external inquiries, consider:
- Are there other resources that should or could contribute (such as business teams, Government Affairs, Compliance and Ethics, EHS, Legal, or HR)?
- Is the decision considered consistent with our Code and Our Values?
- Does the outcome of the decision advance stated business objectives?
- Are there alternatives that might create more value?
There are resources available to you to assist in resolving issues. You can ask your supervisor, any member of management, any local or corporate human resources leader, any compliance and ethics resource, or any lawyer in Legal.
By following the stop, think, and ask approach, we can demonstrate our commitment to our principles and responsible business practices and protect our company's reputation and integrity."
By following the stop, think, and ask approach, we can demonstrate our commitment to our principles and responsible business practices and protect our company's reputation and integrity."
Risk Management
Applying a Robust Risk Management Framework
Our company has adopted a seven-element Risk Management System (RMS) to help us conduct our business activities lawfully and with integrity. The RMS can help all employees with the identification and appropriate management of risks that may arise from operations, product use, or interactions with constituents.
The seven elements, all essential, required for
superior performance are:
superior performance are:
- Leadership Accountability
- Employee Responsibility
- Risk Assessment
- Risk Management
- Communications & Training
- Change Management
- Continuous Improvement
Our internal standards are built using this framework, as are new programs and methods for oversight. We have specific standards, policies, procedures, practices, guidelines, work rules, and other tools to help guide our actions, decision making, and behaviors. If you have questions about them, contact your supervisor, your EHS resource, or your compliance and ethics resource for more information regarding the risk management system and other programs or tools that have been implemented in our company.
Reported Concerns
Internal Investigation of Reports
The company is committed to identifying and correcting wrongdoing wherever it may occur. All reported concerns are promptly assessed and a determination made regarding the appropriate level of investigation and response. All employees are expected to cooperate fully with investigative efforts. This includes always giving truthful, accurate, and complete answers, even if those answers are uncomfortable or create more questions. Investigations must be conducted by a resource suited to investigate the concern, appropriately considering the need for independence and impartiality. To the extent possible, the company will maintain confidentiality consistent with our legal responsibilities.
Corrective Action
Corrective Action and Employee Discipline
Any employee who violates the law, the Code, or other company policies, standards, or work rules will be subject to appropriate corrective or disciplinary action, up to and including termination, consistent with any applicable law, employment contract, or bargaining agreement.
The specific action will depend on multiple factors, including, but not limited to:
The specific action will depend on multiple factors, including, but not limited to:
- The context during the incident.
- The nature, severity, and frequency of the violation.
- The degree of knowledge and responsibility regarding the violation and the effect of the behavior on others, both inside and outside the company.
- An employee’s degree of direct involvement.
- An employee’s voluntary self-reporting of a violation and acceptance of their responsibility.
- An employee’s history, including performance-related factors.