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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 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 also 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.

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. 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. In addition, we provide ongoing compliance training to various employee groups throughout the world on important topics. This training is delivered in-person, via webcast, and online. In 2012, for example, live and webcast programs were held for employees in China, India, South Africa, Russia, United Kingdom, United States, Brazil, Mexico, Colombia, and Argentina, among other countries.

EMC actively encourages its employees and other parties to report concerns either directly to the company 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 by 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 here.

In 2012, EMC significantly expanded the capabilities of its third-party maintained hotline to allow people to report concerns in their local languages.

HUMAN RIGHTS

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 & 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 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 core human rights issues, such as freely chosen employment, child labor avoidance, working hours, wages and benefits, humane treatment, non-discrimination, and freedom of association. In 2012, we revised the Principles to reflect our commitment to freedom of expression and state clearly that we will not tolerate misuse of our products. We also incorporated the United Nations Guiding Principles on Business and Human Rights into EMC’s Principles and as guidance for our actions internally, upstream (throughout the supply chain), and downstream (with respect to product-in-use). EMC has been participating in discussions with NGOs, the European Commission, and our peers to clarify how best to apply these Principles to the Information Technology industry.

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.

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, and requiring periodic certifications of compliance with those laws.

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