Our Strategy & Approach

Our Global Code of Ethical Conduct (our Code), Global Anti-Corruption Policy, and Supplier Code of Conduct guide our ethical business practices, set corporate expectations for ourselves and our business partners, and lay the path for operational consistency in terms of responsibility and compliance with applicable laws, regulations, and standards.

Strong governance enables us to effectively manage risks, meet stakeholders’ expectations, and continuously improve our accountability and sustainability performance.

Plans, Programs & Initiatives

• Training is delivered annually to enhance employees’ understanding of our anti-corruption program and processes.
• Donation protocols, specific to each country, require that donations made align with our values, and that the Company does not derive direct or indirect benefits.
• Procurement protocols, customized by jurisdiction, include guidelines and controls for contract bidding and vendor selection processes, promoting fairness and transparency.

2025 Goals

• Establish a monitoring system to ensure that no less than 90% of corrective actions arising from Whistleblower compliance investigations are implemented within the defined timeframe.⁽¹⁾
• Train at least 850 employees across all sites on compliance issues.

⁽¹⁾ The timeframe for corrective actions, carried out by local teams, is determined at the conclusion of each investigation. It may vary based on the complexity of the case to ensure both clarity and accountability.