Zero Tolerance Policy

Monitoring and enforcement are integral to our corporate governance program. We have a publicly stated formal policy of zero tolerance for corruption or serious violations of our Code of Business Ethics. This policy supports our commitment to work against corruption in all its forms, including bribery and extortion. We actively encourage reporting of suspected Code violations through multiple channels, including through management, Human Resources, Legal and our 24/7 confidential Business Ethics Line, all without fear of retaliation.

As a global company, we acknowledge that we have a higher risk in doing business in certain industries and locations. Therefore, we focus on having a robust compliance program to enable corporate-wide compliance with both the spirit and letter of all antibribery and anticorruption laws everywhere we conduct business. Our internal compliance, training and awareness programs are designed to prevent, detect and remedy policy and Code violations worldwide.

Our senior management is responsible and accountable for implementing our policy. Our director of Anticorruption Law reports to an associate general counsel, and ultimate program oversight resides with our general counsel and compliance officer. Our Global Management Committee provides management oversight to the anticorruption program and the Audit Committee of our board of directors oversees the Ethics & Compliance program as a whole.

To ensure that our anticorruption compliance program and our business practices are up to date, we review them annually, both at the geography level and, for high-risk countries, at the global level.

We are also involved in a number of industry initiatives designed to combat corruption, including the World Economic Forum's Partnering Against Corruption Initiative, which brings together companies through a universal commitment to having a zero-tolerance policy toward bribery and to developing, implementing and maintaining broad-based anticorruption programs.