Management Responsibilities

All management associates are responsible for creating an environment that encourages compliance with our Statement of Ethics. Supervision of responsible business practices is as important as supervision of performance. To help us maintain the highest ethics, you should:


  • Contact Global Ethics if you are made aware of an ethics issue covered by the Immediately Reportable Criteria on page 9 or for assistance handling an ethics question or concern.
  • Meet with your direct reports periodically to review Our Beliefs and our Statement of Ethics.
  • If there is a conflict between our ethics and business objectives, ensure our ethics always come first.
  • Lead by example and encourage your associates to act with integrity in all dealings to avoid even the appearance of a violation of our ethical standards.
  • If an ethics issue arises with one of your associates, make sure other associates in your area are not making the same mistake.
  • Ensure open communication by encouraging associates in your department or division to ask questions concerning our Statement of Ethics.
  • Never cover up or ignore any ethical conduct problem. Address the matter timely and seek guidance if necessary.
  • Appreciate associates who raise issues.
  • Never retaliate against anyone for raising an ethics issue, assisting in an investigation or participating in any proceeding relating to an alleged violation of any government regulation, law or rule or alleged fraud against shareholders.
  • Once an ethical concern is raised, do not interfere with any investigation into the matter.
  • Encourage self-reporting of business conduct violations. If an associate voluntarily reports he or she was involved in an ethics violation, self-reporting may be considered when determining the appropriate disciplinary action to be taken.
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