We clearly define the ethical and compliance expectations to which we hold ourselves and the third parties with whom we work, and we back up these expectations with governance and management systems to ensure we deliver on them.
Our Compliance program is led by our Vice President, Associate General Counsel & Chief Compliance Officer, who reports to PMI’s Senior Vice President & General Counsel and, periodically, to the Audit Committee of the Board of Directors.
PMI’s Code of Conduct sets clear standards and expectations and is closely aligned with our business transformation strategy and industry best practices. Its mandatory provisions apply to all PMI employees, officers, and directors. Key risk areas addressed in this document include, but are not limited to, anti-bribery and anti-corruption, anti-competitive practices, conflicts of interest, information protection security and data privacy, responsible marketing and sales, scientific integrity, supply chain responsibility, and workplace integrity, among others. Internal PMI Policies provide more-specific guidance on these and other topics.
The PMI Code of Conduct is reviewed and updated annually.
A glance at our path to integrate Swedish Match
In 2023, PMI began its Legal & Compliance integration efforts with Swedish Match to ensure that PMI’s standards and requirements are also applied across Swedish Match entities. Employee communication and training
At PMI, we use training and communication to help employees understand the compliance-related standards and rules that are relevant to their roles and how to apply them in their daily work.
In 2023, we continued implementing our global Code of Conduct annual certification process. To date, 95 percent of eligible employees, including 100 percent of senior leaders, have completed the 2023 PMI Code of Conduct certification.1
In addition to the PMI Code of Conduct certification, the Compliance team launched a series of six e-learning courses (available in 31 languages) in 2023. Approximately 40,000 employees received training in the following key compliance risk areas: Anti-harassment/sexual harassment (which is an annual requirement), Code of Conduct (which is an annual requirement), competition, and know your customer/anti-diversion. A targeted subset of this population also received training on intellectual property and PMI's Marketing Codes.
Regional and local compliance officers supplemented these e-learning courses with in-person training sessions to address compliance risk topics specific to their respective region(s) and market(s). Overall, employees and third parties completed a total of over 500,000 Compliance training courses in 2023 (2022: Over 350,000).
Also, in 2023, we continued to enhance and regularly update our Compliance intranet site, including publishing information on relevant compliance topics for our employees.
1 For the purposes of the 2023 PMI Code of Conduct Annual Certification, “senior leaders” are defined as employees at a salary grade of 17 and above.
Evaluating our compliance culture
We evaluate our compliance culture periodically, including, for example, via a global online survey to understand employee experiences and attitudes related to ethical business conduct. For the past 15 years, PMI has conducted this type of global employee survey every two to three years.
In addition, from time to time, we work with external advisers and consultants to assess elements of our compliance program.
Speaking up
At PMI, individuals may ask questions, raise concerns, or report instances of observed or suspected misconduct by contacting any of the following:
- The individual’s supervisor, department head, or affiliate or function leadership
- Compliance key contacts (e.g., Regional and Local Compliance Officers)
- PMI Global Compliance confidential email address
- PMI Compliance Help Line (online or by telephone), which is a third-party operated reporting channel available 24 hours a day, seven days a week, in all languages spoken at PMI. Individuals may use the Compliance Help Line anonymously, subject to local laws and regulations.
PMI has also implemented a Global Speaking Up Policy, the principles of which are reinforced by the PMI Code of Conduct and all PMI compliance policies.
There is a robust speaking-up culture at PMI, with most employees communicating directly with the Compliance department and voluntarily disclosing their identity when doing so. Specifically, in 2023, only 19 percent of the reports received by Compliance were submitted anonymously (2022: 16 percent).
The Compliance team regularly communicates to employees about PMI’s speaking-up program. For example, the Compliance team publishes quarterly statistics about speaking-up reports, compliance violations, and disciplinary actions, and shares with employees anonymized real-life examples of misconduct and advisory guidance.
Compliance investigations
At PMI, we take all reports received through our speaking up channels seriously and are committed to following up objectively and in a timely manner. We investigate all reports that raise compliance concerns, and we involve other functions or line management as warranted. We implement corrective measures to address investigation findings and calibrate disciplinary actions against past outcomes to keep the process fair. When investigating suspected compliance violations, trained personnel adhere to PMI Investigations Standards, which are designed to ensure an equitable and respectful process. We run a post-investigation quality assurance program to get feedback on how well we met these standards. We have also implemented a Retaliation Check program to detect, remedy, and prevent retaliation against people who speak up, as well as those involved in investigations.
We received 1,258 reports through Compliance Speak Up channels in 2023 (2022: 990). Around 53 percent of the matters that were closed in 2023 did not involve a compliance allegation and were resolved through Compliance advisory services or referred to line management or appropriate departments, such as our People & Culture teams, for further action.
In 2023, we investigated and closed 591 reports that involved at least one compliance-related allegation (2022: 429). At least one violation was substantiated in 55 percent of these cases (2022: 52 percent), with “workplace integrity” accounting for 32 percent of substantiated violations (2022: 33 percent); “theft and fraud” accounting for 18 percent of substantiated violations (2022: 28 percent); and substantiated violations related to speaking up (such as failure to speak up or obstructing an investigation) accounting for 18 percent (2022: 10 percent).
The appropriate parties implemented corrective measures and disciplinary sanctions following these investigations. Specifically, in 2023, termination of employment accounted for 31 percent of the disciplinary actions arising from these cases, while suspension accounted for 7 percent, written warnings for 25 percent, and verbal warnings or counseling for the remaining 37 percent.
Preventing bribery and corruption
Our standard is clear: We do not bribe anyone, anywhere, for any reason. We recognize that our refusal to participate in corrupt activities may make conducting business more difficult in some markets, but bribery is unacceptable at PMI.In 2023, we published our Global Anti-Corruption Policy on our external-facing website, PMI.com. This policy, together with additional Anti-Corruption Standards, regulates our interactions with government officials and government entities, as well as with private individuals, both directly and through third parties. PMI’s policy prohibits all forms of bribery and facilitation payments. Our Standards set specific rules and review-and-approval procedures for giving and receiving gifts, travel and hospitality, providing contributions, engaging business intermediaries, hiring government officials, and conducting due diligence in M&A transactions.
We publicly disclose on PMI.com the very limited political contributions we make, and we adhere to lobbying regulations.
