Communication and education
Our core principles and rules are communicated to employees in several ways, including a comprehensive digital training program, classroom training and compliance communications. Communication and training programs serve two purposes – to educate employees on the rules that apply to their role, and to inspire them to apply high ethical standards in the choices they make.
The Code of Conduct and Life-Saving Rules digital trainings are mandatory for every employee. Competition law, export control and sanctions, fraud, anti-bribery, information security and privacy digital trainings are mandatory for employees defined on the basis of their role. Digital training completion is monitored by the BU/function Compliance Committees on a quarterly basis. Digital trainings are periodically refreshed to increase engagement. In 2017, we introduced new digital trainings on information security (more than 38,000 employees) and competition law (over 15,000 employees). At the end of 2017, the completion rates for Code of Conduct and Life-Saving Rules were 90% and 87% respectively (82% and 78% in 2016), while the overall completion rate for all compliance digital trainings was 85% (82% in 2016).
Classroom training is provided on a variety of topics, including general compliance awareness training, the Code of Conduct, SpeakUp!, competition law, export control and sanctions, and discrimination and harassment.
The Compliance function issues newsletters and holds WebEx sessions on a quarterly basis. Bulletins on specific items of interest are also issued, and in 2017, subjects covered in these bulletins included conflict of interest, customer loyalty programs and privacy. In addition, the Compliance function started communicating (anonymized) examples of investigated violations and disciplinary sanctions through its newsletter. It also ensured that the importance of compliance was reflected in a variety of senior leadership business messages.
A comprehensive Compliance web portal is available to employees containing guidance, templates and references on various compliance topics.
Our Code of Conduct defines our core principles and how we work. It incorporates fundamental principles on issues such as business integrity, labor relations, human rights, health, safety, environment and security and community involvement.