Ethics and integrity
Our commitment to ethical conduct
We are committed to conducting business ethically and following the highest standards of integrity. We consult both internal and external resources to ensure that our actions are lawful and align with our values.
Our Code of Business Conduct and Ethics outlines our policies and standards for ethical behavior. This includes guidelines for conflicts of interest, corporate opportunities, confidentiality, fair competition, gifts and entertainment, company assets, financial reporting, compliance with laws and regulations, and employment practices.
Our Code of Conduct establishes guidelines for labor and human rights and aligns with the Universal Declaration of Human Rights and the International Labour Organization’s principles. It applies to all our employees, full-time and part-time, regardless of location. All employees are required to acknowledge and comply with the Code annually through our annual attestation program. For more details on our Corporate Governance, including management structure, Board of Directors, committee charters and policies, please visit our Investors page.
Setting high standards for ethics and integrity
We have a zero-tolerance policy on corruption and bribery. We comply with the US Foreign Corrupt Practices Act, the UK Bribery Act, the UK Modern Slavery Act 2015, the German Criminal Code, and other applicable laws. Our Foreign Corrupt Practices Act (FCPA) and Anti-Corruption Compliance Policy is administered by the General Counsel.
All employees are required to review and complete training on our Insider Trading Policy, FCPA and Anti-Corruption Compliance Policy, and anti-money laundering compliance during our annual attestation period. This applies to all members of our Board of Directors as well.
All employees are required to report questionable ethical behavior or violations of the Code of Conduct. Information can be reported to their supervisor or senior management, or employees can send communications anonymously via a confidential hotline.
We expect our suppliers, their employees, agents, and subcontractors to adhere to the same high standards of ethics and integrity as we do. Our Supplier Code of Conduct lays out our company's core principles and sets expectations for suppliers to maintain a professional, respectful, and safe working environment when working with us.
We work with government bodies at the federal, state, and local level in the U.S. and internationally on issues that are important to our business. We disclose information about our membership in major trade associations and expenses related to direct lobbying in our annual Proxy Statement.