Our Commitment & Accountability
We are committed to living by our values.
Leading With Values
We are committed to living by our values, doing what’s right and acting with integrity everywhere we do business regardless of the circumstances. We all have a responsibility to comply with the law and follow the Code and other company policies. If you violate the law, our Code or other company policies, you may be subject to disciplinary action which may include terminating your employment, even if the violation occurred off company premises or off-the-clock.
Additional Responsibilities for Leaders
All managers and senior leaders are responsible for creating an environment that encourages compliance with our Code of Conduct and other company policies. Supervision of responsible business practices is as important as supervision of performance and business results. To help us uphold our values and maintain a culture of compliance, you should:
- act as a role model and encourage your teams to act with integrity at all times;
- encourage open communication so associates can ask questions and raise concerns;
- ensure your teams understand and follow the Code and complete all training;
- promote an inclusive environment that welcomes and values differences;
- actively support and follow the No Retaliation Policy;
- report incidents of misconduct or potential violations of the law or policy;
- and escalate reports and get help from Human Resources or Global Ethics & Compliance when needed.
Our Code is approved by our Board of Directors. The Human Capital and Compensation Committee of the Board of Directors must approve a waiver of any provision of the Code for any executive in the position of Senior Vice President and above. All other requests for waivers of the Code must be approved by the Chief Legal Officer. Any waivers granted must be in writing.
Speak Up: Ask Questions and Raise Concerns
The Code cannot anticipate every situation, but you can avoid most problems by checking the Code, using good judgment and asking for help before acting. We expect you to talk openly with us about work-related ideas, questions, problems and concerns so they can be resolved. If you have concerns about a work-related situation, or you see something you think is wrong, talk to your manager, Human Resources partner, Global Ethics & Compliance or contact the Ethics Hotline.
How do I know when to seek guidance?
- Is there a chance this course of action is illegal?
- Is it inconsistent with our values, Code or policies?
- Could it be considered unethical or dishonest?
- Could it hurt the company’s reputation?
- Do I need to get approval to do it?
- Would this be embarrassing or look bad if it were reported in the media?
If the answer to any of these questions could be “yes,” talk about the situation with a manager, Human Resources partner or Global Ethics & Compliance.
Our Open Communications Advantage
We have a tradition of success built primarily on agility and teamwork. We believe we are more productive, more efficient and better able to deliver on our brand promises when our associates have a close, collaborative relationship with one another. Our associates have grown their careers and the business on a platform of collaboration and cooperation and by retaining the power to work freely and directly with one another. As part of our commitment, associates are assured:
- equal opportunity and treatment;
- career-advancement opportunities;
- equitable and competitive wages;
- excellent benefits;
- open and honest communication;
- and a rewarding and safe working environment.
You will not be subject to retaliation, disciplinary action or any career disadvantage for raising a concern. We strictly prohibit retaliation for good faith reporting under the Code or for participating in an investigation. “Good faith” means making a report with honest intentions and providing all relevant information. If you believe you’ve been retaliated against, you should report it immediately to Human Resources or Global Ethics & Compliance.
What Happens When you Contact the Ethics Hotline
You may report potential instances of unethical conduct and potential violations of law or company policies to the Ethics Hotline 24 hours a day, 7 days a week.
The Ethics Hotline is operated by an independent third party and allows associates to report concerns anonymously (where permitted by law) and provides translation services to support associates who make reports in a language other than English. Information reported to the Ethics Hotline is only shared with departments with a need to know, such as Global Ethics & Compliance, Human Resources or the Legal Department. We are committed to undertaking a fair, prompt and, when possible, confidential review of concerns reported to the Ethics Hotline.
For dedicated phone lines in countries where we operate, or to make a report online, visit lb.ethicspoint.com.
When should I report a suspected violation of the Code?
As soon as you become aware of it.
What if I’m uncertain if a situation or incident violates the Code?
You should talk to your manager, Human Resources partner, Global Ethics & Compliance or contact the Ethics Hotline. It’s better to raise a concern about a potential problem than to wait and risk harm to others or to the company. Reporting in “good faith” means you are coming forward honestly with information that you believe is true, even if it turns out you were mistaken.
What if my manager asks me to do something that I think is illegal or violates the Code of Conduct or other company policies? What should I do?
If possible, you should first discuss your concern openly and honestly with your manager. If you are not satisfied with your manager’s response or are not comfortable speaking with your manager, you should seek out your next-level manager or Human Resources partner. If that’s not possible or if you’re uncomfortable going directly to your manager, next-level manager or Human Resources, you should report the issue to the Ethics Hotline or Global Ethics & Compliance. You should never knowingly violate our Code or policy – even if a manager directs you to do so.