Governance & Integrity
Ethics
Ethical conduct builds relationships of trust among employees, customers, partners, shareholders, communities, and other stakeholders. EMC’s corporate compliance program educates employees about our ethical standards and monitors compliance with those standards. The Audit Committee of the Board of Directors oversees the corporate compliance program.
Business Conduct Guidelines
The keystone of the corporate compliance program is our Business Conduct Guidelines. The guidelines are reviewed at least annually. We offer language translations for our global employees in Chinese, French, German, Hebrew, Italian, Japanese, Korean, Polish, Portuguese, Russian, and Spanish. The Business Conduct Guidelines are available on EMC’s corporate website and the translations are available on EMC’s intranet.
The Business Conduct Guidelines provide guidance and link to EMC’s policies on key topics, including anti-bribery, insider trading, equal employment, anti-harassment, privacy and information security, confidentiality, antitrust and competition, environmental sustainability, trade compliance, and financial reporting.
Human Rights
EMC is a member of the Electronic Industry Citizenship Coalition (EICC), a collaboration of the world’s leading information and communications technology companies, whose aim is to improve efficiency and social responsibility in the global supply chain.
We have adopted the EICC’s Supplier Code of Conduct (the “EICC Code”) for ourselves and our suppliers, and added supplemental requirements, including provisions against trafficking in persons. We ask all Tier 1 direct suppliers and managed Tier 2 direct suppliers to acknowledge the EICC Code and consider each supplier’s conduct vis-à-vis the EICC Code when awarding and/or renewing business with the supplier.
To learn more, visit Supply Chain Engagement.
Consistent with the EICC Code, we have adopted principles that demonstrate our commitment to upholding workers’ human rights. Areas covered by these principles include: freely chosen employment, child labor avoidance, working hours, wages and benefits, humane treatment, non-discrimination and freedom of association.
Our Human Rights and Global Labor Principles are based on the United Nations Global Compact, International Labour Organization standards and similar doctrines. These principles reinforce our commitment to the rights of our employees, as well as workers throughout our supply chain and our global community. We updated the principles in May 2011 and make them publicly available on our website.
There is a process in place for clear and accurate communication of our policies, practices, and performance expectations to workers, suppliers and customers. We encourage worker feedback and regularly review results of audits and assessments.
Ethics Training
All new hires are required to complete corporate compliance training. This online training covers numerous topics, including the Business Conduct Guidelines, as well as EMC’s anti-bribery, insider trading, equal opportunity, anti-harassment, privacy and information security, confidentiality, and antitrust and competition policies.
We also provide online and live compliance training to existing employees tailored to their particular organization or geographic region. In 2011, for example, we provided online or live training sessions to various groups of employees, including sessions on export compliance and supply chain integrity, information security and protecting personal information, discrimination and sexual harassment, the Fair Labor Standards Act, the UK Bribery and U.S. Foreign Corrupt Practices Acts, and numerous health and safety-related topics. All Global Supply Chain Management employees, as well as additional employees from other organizations, are required to undergo training on the EICC Code.
Investigations
EMC takes seriously any reports of misconduct or unethical behavior, and offers multiple avenues for employees or others to raise concerns. These include a confidential website and a confidential hotline. Questions, concerns or reports of a potential violation of law, regulation, the Business Conduct Guidelines, or other EMC policies can be reported in any of the following ways:
- Contact the Office of the General Counsel by telephone (508-435-1000, extension 77267), facsimile (508-497-8079), or email (General_Counsel@EMC.com).
- Contact the Audit Committee of the Board of Directors by email (AuditCommitteeChair-man@emc.com) or by mail (Alertline, PMB 3767, 13950 Ballantyne Corporate Place, Charlotte, NC 28277).
- Contact EMC’s hotline by telephone (877-764-0557) or via a secure web report to https://emccorporation.alertline.com
Resources
Reports
Human Rights and Global Labor Principles
Political Contributions Policy
December 2011 Corporate Political Contributions Disclosure Statement