|INTEGRATED REPORT 2020
For PMI, conducting business with integrity means complying with the law, our Guidebook for Success (PMI’s Code of Conduct), and other company commitments. Our Guidebook for Success defines the rules we follow and describes the values that form the foundation of good ethical judgment.
The business case
Our customers and employees expect us to operate ethically and with integrity. The Ethics & Compliance department plays a key role in our efforts to do so, and in ensuring that our company transformation succeeds by supporting and enabling a working environment where speaking up is normal and easy.
The right thing to do
While following the rules is critical, it is sometimes not enough. It can be possible to behave in an unethical way while still complying with the law or other rules. Good ethical judgment helps us to guard against such failures and builds lasting business success.
Achieving our aims
We understand that PMI’s reputation comes from the sum of our individual actions. We want to ensure that we conduct business ethically and with integrity. To help us achieve this, we maintain an Ethics & Compliance (E&C) program.
Our E&C program is led by our VP and Chief Ethics & Compliance Officer, who reports to PMI’s General Counsel and also reports regularly to the Board of Directors and its Audit Committee.
Our code of conduct, known in PMI as our Guidebook for Success, sets clear standards and expectations. Its mandatory provisions apply to all PMI employees, officers, and directors. Key risk areas include 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. Our Principles & Practices (P&P) provide more specific guidance on the Guidebook topics.
Our Responsible Sourcing Principles (RSP) set clear standards for our suppliers in line with internationally recognized standards on human rights, environmental management, and business integrity. Read more in our chapter on sustainable supply chain management.
We evaluate our E&C program periodically, using a census to understand employee opinions and experiences related to E&C matters. Our last census was completed in 2018 and reported on in last year’s sustainability report. While the next census was initially scheduled for 2020, we postponed it to 2021, due to the special circumstance resulting from the outbreak of the COVID-19 pandemic. We periodically conduct third-party-led assessments of our E&C program, with the most recent run in 2019.