Immediately Reportable Criteria

Associates may raise concerns regarding conduct that may violate the Global Statement of Ethics through the various channels listed in the Raising Concerns & Speaking Up section. However, there are certain types of allegations that must immediately be reported to Global Ethics. They are:


  • Providing, offering, promising, requesting, or receiving any improper or unearned benefit
  • Any violation of the company’s Global Anti-Corruption Policy or related procedures
  • All suspected violations of anti-bribery laws should also be reported, including any violations of the anti-bribery restrictions in the U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act.

Officer Misconduct

  • Violations of the Global Statement of Ethics by company officers or direct reports to any company CEO

Fraud or Theft Greater Than $100,000 and Involving an Associate

Incorrect Records and Accounts

  • Interfering with audits or internal controls, falsifying, misrepresenting, or destroying financial records, reports, or data, or improperly concealing, altering, or manipulating financial records, reports, or data

Information System Hacking

  •  Any conduct involving an associate maliciously gaining unauthorized access to company information systems

Global Corporate Brand Reputation Risks

  • Threats to human life, slave or forced labor, human trafficking, or child labor
  • Serious criminal misconduct, such as:
    • Bid rigging, price fixing, market or customer division or allocation, or other anti-competitive collusion
    • Insider trading
    • Trade sanctions and export regulation violations
    • Money laundering
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