Business ethics and integrity

Our core ethical principles—honesty, respect, and fairness—are at the heart of how we operate. 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 & Group Chief Compliance Officer, who reports to PMI’s Group Chief Legal Officer 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 annually.

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 2025, we continued implementing our global Code of Conduct annual certification process. To date, 97 percent of targeted employees have completed the 2025 PMI Code of Conduct certification.

The Compliance team launched a series of six e-learning courses (available in 32 languages) in 2025. Approximately 40,000 employees received training in the following key compliance risk areas: anti-corruption, Code of Conduct (which is an annual requirement and included training on sexual harassment, speaking up, conflicts of interest, Marketing Code, and antitrust/competition, among others), ethical decision-making, fiscal compliance, manager compliance responsibilities, and privacy. 

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 400,000 Compliance training courses in 2025 (2024: over 400,000).

Also, in 2025, we continued to enhance and regularly update our Compliance intranet site, including publishing information on relevant compliance topics for our employees.

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, including, most recently, in 2024.

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 Corporate Speak Up Policy, the principles of which are reinforced by the PMI Code of Conduct and all PMI compliance policies.

There is a robust speak up culture at PMI. Most employees who speak up do so directly with the Compliance department and voluntarily disclose their identity when doing so. 

The Compliance team regularly communicates to employees about PMI’s speak up program. For example, the Compliance team publishes quarterly statistics about Speak 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 Compliance Speak 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 have also implemented a targeted Retaliation Check program to detect, remedy, and prevent retaliation against people who speak up, as well as those involved in investigations.

We received 1,735 reports through Compliance Speak Up channels in 2025 (2024: 1,444). Around 35 percent of the matters that were closed in 2025 were investigated because they involved at least one compliance allegation. The remaining 65 percent were resolved through Compliance advisory services or referred to line management or appropriate departments, such as our People & Culture teams, for further action. 

In 2025, we investigated and closed 540 reports that involved at least one compliance allegation (2024: 541). At least one violation was substantiated in 61 percent of these cases (2024: 53 percent).

The appropriate parties implemented corrective measures and disciplinary sanctions following these investigations. Specifically, in 2025, termination of employment accounted for 42 percent of the disciplinary actions arising from these cases, while suspension accounted for 11 percent, written warnings for 25 percent, and verbal warnings or counseling for the remaining 22 percent.

Preventing bribery and corruption

Our policy 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.

Our Corporate Anti-Corruption Policy is available here. This policy, together with additional Standards, sets specific principles, rules, and review-and-approval procedures for providing gifts, travel, and hospitality, providing contributions, engaging business intermediaries, hiring government officials, and conducting due diligence in M&A transactions.

We publicly disclose here the political contributions we make, and we adhere to lobbying regulations.