Fostering a Culture of Ethical Conduct

The company’s Compliance and Ethics program is designed to foster a culture of ethical conduct and ensure compliance with company policies and applicable laws.

The company’s Compliance and Ethics organization comprises (i) the Compliance and Ethics Executive Committee, whose members are the company’s Chief Legal Officer, Controller, Senior Vice President of Internal Audit, Chief Compliance and Ethics Executive, Senior Vice President of Operations and Senior Vice President of HR Services, and (ii) the Office of Compliance and Ethics, which is managed by the Chief Compliance and Ethics Executive who reports to the Chief Legal Officer.

The company’s Compliance and Ethics program seeks to achieve continuous improvement through a holistic approach that emphasizes our company’s core value of "Integrity." It has many components, including communications and training on the company’s Code of Conduct, legal compliance training, external third-party hotline and web reporting services, periodic legal compliance risk assessments and culture surveys, as well as periodic Compliance and Ethics reporting to the Audit Committee of the board of directors.