2021 Environmental Social Governance (ESG) Report
ETHICS AND COMPLIANCE We hold ourselves to high standards of integrity and strive to create a culture in which everyone acts out of personal accountability for protecting our business, our commitments to our Board of Directors, our clients and all those we serve. We aim to act ethically and uphold all applicable laws and regulations affecting our business around the world without exception. In doing this, we protect our stakeholders and position ourselves to lead. Our global Ethics and Compliance program is led by our Chief Ethics & Compliance Officer, who is supported by the Business Unit Compliance Vice President, Compliance Operations Manager, and the Global Privacy Lead. Regional compliance directors provide additional support and report to the Business Unit Compliance Vice President. Ethical Policies and Practices Our Global Code of Business Conduct (the “Code”), published in 21 languages, defines the conduct expected of all officers and employees of the company. Annual online training and certification to the Code is mandatory for all employees. The Code is updated annually to reflect new considerations that arise during the year. In 2021, the Code was updated to include a section on tax evasion; new rules around gifts, entertainment and hospitality; and a FIT (Frequency, Intent, Timing) decision tree to help employees use good judgement when giving or receiving gifts. All Ethics and Compliance policies are reviewed annually and updated as needed. Our Global Anti-Bribery & Corruption Policy defines limits on gifts, entertainment, and hospitality that protect against bribery and corruption. This global policy is supplemented by Regional/Local Gifts, Entertainment and Hospitality Policies in key regions, including India; Indonesia; Japan; Korea; Singapore, Malaysia and Philippines; Thailand; Vietnam; Australia and New Zealand; Mexico; and South America.
Global Ethics and Compliance Policies
Global Anti-Bribery & Corruption Policy Global Charitable Contributions and Sponsorships Policy Global Code of Business Conduct Global Economic Sanctions Policy Global Vendor/Supplier Integrity Policy Global Conflicts of Interest Policy
Global Due Diligence Policy
Global Whistleblower Policy Global Client/Third Party Privacy &
Confidentiality Policy Insider Trading Policy Code of Business Conduct for Members of the Board of Directors Global Policy Concerning Related Third-Party Transactions
UK Modern Slavery Act Statement Australia Modern Slavery Statement Global Workplace Privacy Policy
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