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 eleven languages including Chinese, French, German, Hebrew, Italian, Japanese, Korean, Polish, Portuguese, Russian and Spanish. 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 2015, all employees were required to certify that they read and understood their responsibilities under the Guidelines.
The Guidelines provide guidance on and links 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 2015, EMC updated our Guidelines and introduced FAQs to address various commonly-asked compliance questions, including recurring inquiries regarding data privacy and information security issues. 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 required to complete a comprehensive online training module on the Guidelines and EMC’s policies on key topics. As of November 1, 2015, more than 90 percent of employees hired in 2015 with access to EMC’s system had completed the training within the time allotted.
EMC maintains an active training program for employees worldwide, offering both online and in-person sessions on topics of particular relevance. In 2015:
- More than 90 percent of EMC employees participated in at least two compliance trainings during the course of the year
- EMC conducted more than 50 live and/or webcast training sessions for key employees throughout the world, including in Argentina, Brazil, Canada, Chile, China, India, Mexico, Peru and the United States
In 2015, all EMC employees were required to complete two online training courses, one on the Guidelines and the other on anti-bribery. This is in addition to any other online and live training courses that employees were required to take.
EMC actively encourages its employees and other parties to report concerns 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 policy 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 and in the Guidelines.
In 2015, an Ethics and Compliance link providing this reporting information was added to the Emc.com “Contact Us” page, which is available in 11 languages.
Partner Compliance Program
EMC expects the partners with whom we do business to act ethically, which includes following all anti-bribery and export control laws. EMC achieves this through various methods, including:
- Requiring partners to certify that they are in compliance with anti-bribery and export control laws;
- Implementing a new third party compliance platform to facilitate the compliance of onboarding and monitoring partners;
- Expanding its onboarding and monitoring processes;
- Reminding all partners of EMC’s Partner Code of Conduct and the fact that they are required to comply with anti-bribery, antitrust, and export laws, and to act with financial integrity at all times; and
- Conducting audits of partner Marketing Development Funds and Co-Op submissions to ensure financial integrity.