Corporate ethics

How we do things is as important as what we do. We are responsible for our actions, accountable for their consequences, and serious about our efforts. Our employees live our values through their everyday actions. We also use our scale and influence to encourage ethical behavior beyond our own operations, such as in our supply chain and towards human rights. Our Codes of Conduct detail our expectations for anyone doing business with us. These codes include:

Our Ethics and Compliance program requires employees, business partners, and suppliers worldwide to use lawful and ethical business practices when doing business with us. We have systems in place for reporting and swift resolution of ethical concerns, in line with our policies and local laws.

We operate with integrity, whatever the local culture, laws, and regulations might be. We do not tolerate corrupt behavior and prohibits bribes or kickbacks under any circumstances.

We earned high ratings in Transparency International’s Defence Companies Anti-corruption Index for 2013 External site, placing us in the top 8% of companies assessed.


We do not tolerate corrupt behavior and prohibits bribery or kickbacks in any circumstance. Corrupt behavior is an impediment to social and economic development. It undermines the values on which we are built, the principles of fair competition, and the rule of law.

Through our Anti-corruption Compliance Program, we promote compliance with anti-corruption laws and regulations, including the U.S. Foreign Corrupt Practices Act, the UK Bribery Act and similar national laws. During 2013, we simplified our anti-corruption policies to provide streamlined guidance to our workforce and introduced a new, stand-alone Anti-corruption Policy and a revised Global Business Amenities Policy. Employees must also abide by our Political Contributions Policy. In November 2013, we communicated the new Anti-corruption Policy and Global Business Amenities Policy to all employees globally, and in early 2014 successfully trained our sales force on these policies. We communicate regularly with employees worldwide to promote understanding and familiarity with all aspects of our Anti-corruption Compliance Program. We also have policies for Global Business Gifts, Travel, and Entertainment and Political Contributions.

We use internal data and Transparency International's Corruption Perceptions Index External site to identify countries at high risk for corrupt activity and raise employee awareness of potential issues in these higher-risk countries. We also benchmark our program with other companies to identify potential improvements.

In 2013, we expanded our Channel Reseller Partner Due Diligence Program to other types of third parties, including global logistics service providers and certain suppliers.

For complete information regarding our corporate ethics, please refer to our 2013 Living Progress Report.