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; and
- 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.
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 2014, EMC updated its Guidelines to reflect updates to various EMC policies and to enhance readability. 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. In 2014, EMC expanded the training required for all new hires to include enhanced content on data privacy and security. As in previous years, more than 90 percent of new hires with access to EMC’s system had completed the training by the end of 2014.
EMC also provides ongoing compliance training to select employee groups throughout the world on various topics. In 2014, for example, all employees were required to participate in at least two compliance trainings, and more than 60 live or webcast training sessions were delivered to employees in countries including Canada, China, England, France, Germany, Israel, Mexico, Poland, Portugal, Russia, South Africa, Spain, Switzerland, and the United States. The training addressed various topics, including EMC’s Business Conduct Guidelines, bribery, data privacy and security, conflicts of interest, trade compliance, workplace harassment, and more.
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.
Partner Compliance Program
In 2014, EMC continued to take steps to enhance its 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, as well as EMC’s Human Rights and Global Labor 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. Examples of enhancements to EMC’s partner compliance program from 2014 include the debut of EMC’s Partner Code of Conduct and the creation of the first-ever online training module for EMC partners on bribery.