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 cornerstone of the corporate compliance program is our Business Conduct Guidelines. The Guidelines apply to all EMC employees and contractors worldwide and are organized around five principles:
- Act honestly and ethically
- Treat others with dignity and respect
- Conduct business fairly and responsibly
- Safeguard EMC’s assets and information
- Ensure the integrity of EMC’s business records
The Guidelines are reviewed at least annually and are translated into Chinese, French, German, Hebrew, Italian, Japanese, Korean, Polish, Portuguese, Russian, and Spanish for our global employees. The Guidelines are distributed to all employees and contractors on an annual basis, and are always available on EMC’s corporate website and intranet. All new employees are required to acknowledge and agree to abide by the Guidelines when they join EMC. In 2013, EMC required existing employees to certify that they had read and understood the Guidelines.
The Guidelines provide guidance on and link to EMC’s policies on key topics, including anti-bribery, insider trading, equal employment, workplace violence prevention, anti-harassment, privacy and information security, confidentiality, antitrust and competition, environmental sustainability, trade compliance, and financial reporting. In 2013, EMC updated its Guidelines to reflect changes in the laws and its internal policies with respect to privacy and information security. The Guidelines also provide information about the several methods that are available to report concerns, which are kept confidential to the maximum extent possible and may be made anonymously where local law allows. The Guidelines specify that EMC will not retaliate against anyone who makes a report in good faith.
All new employees are also required to complete a comprehensive online training module on the Guidelines and EMC’s policies on key topics. This module was completely refreshed in 2013 to include additional topics and ensure that employees were receiving the most up-to-date guidance. More than 90 percent of new hires with access to EMC’s systems had completed the training by the end of 2013. Employees hired as a result of acquisitions, who therefore do not have immediate access to EMC’s training system, either complete the online module once they gain access or receive equivalent live training.
EMC also provides ongoing compliance training to various employee groups throughout the world on important topics. In 2013, for example, EMC developed and implemented an online training module for employees in its Asia Pacific and Japan (APJ) region. This module covered a variety of topics, including the Guidelines, anti-bribery, export control, protecting EMC’s confidential information, and the importance of financial integrity. Approximately 90 percent of employees in APJ completed that training in 2013.
EMC also developed an online training module in its EMEA (Europe, Middle East, and Africa) region and Latin America regions on anti-bribery and export control, with more than 90 percent of the target audience completing that training in 2013. In addition, EMC continued to deliver in-person and webcast training to employees throughout the world in 2013, including in the United States, South Africa, Germany, France, Russia, Turkey, the United Kingdom, Ireland, and multiple countries within Latin America. Those live sessions covered a broad range of audiences and topics, and included scenario-based training, roundtable discussions, and traditional classroom-styled training. Among other subjects, training was provided on insider trading, antitrust and competition law, the Trade Agreements Act, export control, pay-to-play laws, and selling to government customers.
EMC actively encourages its employees and other parties to report concerns either directly or through EMC’s hotline, which is maintained by a third-party provider. The different ways through which reports can be made are included in the Guidelines, corporate compliance training materials, and elsewhere. Specifically, questions and guidance regarding a potential violation of law, regulation, the 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 EMC Board of Directors by email (AuditCommitteeChairman@emc.com) or mail (Alertline, PMB 3767, 13950 Ballantyne Corporate Place, Charlotte, NC 28277).
- If you are located within the United States, contact the EMC hotline, which is monitored by an independent third-party provider, by telephone (877-764-0557), or via a secure web report to https://emccorporation.alertline.com. A list of country-specific dialing and web-reporting information can be found on EMC’s intranet.
EMC supports and respects the protection of internationally proclaimed human rights for all, including our employees, workers within our supply chain, and people impacted by the use of our products.
In furtherance of its commitment to 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 dedicated to improving social and environmental responsibility in the global supply chain through collaboration and common tools and standards. We have adopted the EICC’s Supplier Code of Conduct, which sets standards for labor, ethics, environment, health and safety, and management systems. All direct materials suppliers are required to acknowledge the Code, and compliance with the Code is part of our standard contract language for all EMC vendors. To learn more about how we monitor suppliers’ compliance to the Code, assess risk, engage with suppliers to drive positive change, and create incentives for improvement, visit Supply Chain Social and Environmental Responsibility.
EMC’s commitment to human rights is also reflected in its Human Rights and Global Labor Principles. EMC’s Principles, which are based on the United Nations Global Compact, the United Nations Guiding Principles on Business and Human Rights, International Labour Organization standards, and other respected standards, reflect the company’s commitment to cor e human rights issues, such as freely chosen employment, child labor avoidance, working hours, wages and benefits, humane treatment, non-discrimination, freedom of association, and freedom of expression. Those Principles also state clearly that we will not tolerate misuse of our products. In 2013, EMC continued its discussions with NGOs, the European Commission, and our peers to clarify how best to apply these Principles to the information technology industry.
We have 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.
EMC expects the partners with whom we do business to act ethically, which includes following all anti-bribery and export control laws, as well as EMC’s Principles. EMC achieves this through various methods, including strict contractual requirements, a robust trade compliance program, requiring periodic certifications of compliance with those laws, and training. In 2013, we prepared several enhancements to our partner program, including the creation of a code of conduct for partners and enhanced on-boarding and due diligence capabilities that are in the process of being implemented.