At GM, our business is guided by our purpose and values. They drive our business decisions and activities worldwide and are our road map for sustainability.
Our business is more than making great products; it’s about building trust with our customers and stakeholders, and trust is fundamental to our business success.
It starts with our core values: Customers, Relationships and Excellence. Excellence means we act with integrity and are diligent to "do the right thing" in every situation, in every region, across the globe.
We all want to work for a company we can be proud of, a company that encourages and supports its employees to do the right thing. Winning With Integrity, GM's Code of Conduct, reinforces our commitment to a work environment founded on mutual respect, trust and accountability and outlines the policies and obligations that guide our business conduct. High ethical standards begin with the Board of Directors at GM, which is committed to upholding the highest legal and ethical conduct in fulfilling its responsibilities. All Board members, officers and employees are expected to act ethically at all times and to adhere to GM’s policies and the law, as set forth in Winning With Integrity.
Winning With Integrity applies to all staffs, divisions and subsidiaries of GM (their salaried employees globally) in which GM, directly or indirectly, owns more than 50 percent of the equity interest or which GM otherwise controls. Where GM owns 50 percent or less and does NOT exercise management control, a case-by-case determination is made. This Code also applies to consultants, agents, sales representatives, distributors, independent contractors and contract workers (collectively, “GM Representatives”) when they act on behalf of GM, to the extent sections of the Code are applicable to the services the GM Representatives provide. The GM employee(s) who engage the GM Representatives must ensure that the GM representatives follow the applicable sections of the Code.
On an annual basis, all salaried employees are required to review Winning With Integrity and certify that they agree to comply with the Code of Conduct and have reported any violations of the Code or vehicle or workplace safety issues. Additionally, all salaried employees, regardless of role or location, are required to disclose actual and potential conflicts of interest as part of the Winning With Integrity certification process. Board members who are not employees provide written disclosure of any actual or potential conflicts of interest at least once a year.
Winning With Integrity governs how our employees are expected to act: displaying integrity in the workplace, in the marketplace and in their communities when representing GM. Additionally, Winning With Integrity directs all employees to be good stewards of the environment as embodied in our Environmental Principles, which guide the conduct of our daily business practices worldwide.
Winning With Integrity also outlines what is considered misconduct, including what constitutes misuse of company property, discrimination, harassment, conflicts of interest, unethical behavior or misuse of information or computer systems. Additionally, Winning With Integrity provides guidance about what may constitute unfair competition or insider trading and guidance on export compliance, privacy, anticorruption and interactions with government officials.
GM is committed to maintaining a culture that promotes the prevention, detection and resolution of misconduct. All salaried GM employees complete global anti-corruption training on an annual basis and have an obligation to report any potential misconduct. Corruption of any kind undermines GM’s commitment to integrity and is not tolerated. Even the appearance of impropriety in giving or receiving gifts, entertainment or things of value can jeopardize GM’s interests and is inconsistent with this commitment.
In cases where an individual is uncomfortable reporting through established internal channels, reports can be made using the GM Awareline (a toll-free hotline). The Awareline is operated by a third party and allows employees and others to report concerns of misconduct by the company, its management, supervisors, employees or agents. Reports can be made in over a dozen languages 24 hours per day, 7 days per week, by phone, web, email, postal service or fax. For potential vehicle or workplace safety-related issues, a special Speak Up for Safety hotline has been established. GM employees and contract workers may also communicate with our independent Monitor anonymously, as permitted by law, or otherwise at any time. The Monitor maintains an independent toll-free phone number for reporting any violation of law or unethical conduct, as well as a globally available online web form. The Monitor’s role supplements but does not replace, existing established global employee reporting tools, such as GM Awareline and Speak Up For Safety. (Click here for information on the independent Monitor.)
Speak Up!, GM's Non-Retaliation Policy, is intended to protect GM employees from retaliation as a result of raising concerns in good faith, but individuals filing reports can also remain anonymous if they choose.
To help ensure that GM complies with anti-corruption laws and its Code of Conduct, Winning With Integrity, GM utilizes a due diligence process for certain covered third parties, which includes anti-corruption checks, as well as checks against restricted party lists of the U.S. and other countries.
GM’s compliance training program was robust in 2015. Employees are required to complete the following corporate required courses every year to build upon their awareness of the Code of Conduct and to ensure every employee has a basic understanding of GM policies and procedures:
To support our global employees, courses are available in a variety of languages. Last year, GM achieved an overall completion rate of approximately 99.9 percent for these courses.
In addition to GM’s online courses, GM’s Regional Compliance Officers and local compliance lawyers conducted numerous in-person training sessions globally, training approximately 7,000 employees in 2015. These in-person training sessions included anti-corruption, general compliance, third-party due diligence, the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, export control and sanctions, data privacy, antitrust, IT security, and GM’s obligations under its Deferred Prosecution Agreement.
General Motors is a member of the Automotive Compliance Roundtable, a group of automotive original equipment manufacturers (OEMs) and suppliers that meet regularly to share best practices and lessons learned; identify resources helpful in developing and managing a compliance program; identify compliance risks in the automotive sector; and benchmark concerning the structure of a compliance program.
As we strive to win in the changing global marketplace, Winning With Integrity remains the cornerstone of our corporate values. We are committed to maintaining a corporate culture that promotes trust. We strive to create diverse work environments that accept and tolerate differences while promoting productivity and teamwork.