GM has been named the fourth most transparent S&P 500 company for ESG disclosure by Agenda, a corporate governance newsletter. Agenda commissioned stock-ratings company HIP Investor to identify the S&P 500 companies that most fully — and least fully — report these important metrics that connect with financial value creation and risk reduction. A HIP analyst evaluated which companies had higher transparency by analyzing their CDP disclosures, company annual reports, corporate social responsibility reports, sustainability reports and the Thomson Reuters/Refinitiv database. From all of these sources, Nielsen gathered 300 raw ESG data points on items including water usage and efficiency, employee engagement and carbon emissions.
The integration of sustainability and climate change into our business continues to be a focus and both have been incorporated into our risk management process. This places both topics at the forefront of daily decision-making throughout the company and ensures continuous management and evaluation at the highest levels of the company. As an example of this management, we recently addressed climate change risks and opportunities through a scenario planning workshop.
The workshop was based on a key assumption that the world is on a path by 2030 to limit emissions so that temperatures increase no more than 2 degrees Celsius. Sponsored by GM’s corporate secretary and the head of GM’s product portfolio planning, the exercise — led by Strategic Risk Management and Sustainability organizations — brought together a broad, cross-functional team, from public policy to global propulsion systems to business intelligence. Goals included developing and understanding a range of different world scenarios; identifying risks, opportunities and success factors for GM; and making recommendations for GM to analyze, prepare, adapt and act.
The group considered four different scenarios in a maximum 2-degree warmer world and walked through a three-step process. The first step was to explore uncertainties and then to define success in this future world. Helping to shape each scenario were questions such as,
All four scenarios shared common themes. Within the vehicle market, for example, it was assumed that new passenger vehicles would be required to make faster and greater adjustments than other users of energy; significant changes in the vehicle ownership paradigm; and a decline in the proportion of single-person vehicle miles. Outside the transportation sector, we envisioned significant changes and investments in infrastructure, power grids and power sources; penalties and costs associated with manufacturing and supply chain emissions; and increased accountability in areas such as the mine-to-scrap life cycle of metal ore.
The exercise helped to clarify risks but also highlighted opportunities as well, many of which are already well underway at GM today. Some examples include:
All of these moves require GM, as never before, to think like a market entrant rather than an incumbent and to experiment and then quickly scale new technologies, business models and services.
The workshop underscored the reality that the need to limit global warming is influencing consumer choices and brand perception today. Climate change concerns also are likely to drive new policy and regulations, as well as political and economic pressures to reduce emissions throughout the manufacturing value chain. And, the exercise validated the need for GM to continue to develop and sustain a comprehensive climate change strategy that addresses the concerns of all stakeholders, while allowing the business to transform.
GM’s Code of Conduct, Winning with Integrity, is a cornerstone of our compliance program, serving not only as a statement of shared values but also as a guide to help employees make decisions that earn loyalty, trust and respect. It applies to everyone in the company at every level.
The Code of Conduct was updated in 2018 with GM’s new company Value: Seek Truth. We added this to our existing Values of Customers, Excellence and Relationships. Seek Truth means we use facts and data as a foundation for respectful dialogue that ultimately leads to better, smarter decisions for the business and for our customers. Guided by these values, GM employees are working as one team, building a safer, better and more sustainable future.
This update builds on a redesign of the Code in 2017 to include more reader-friendly content, better examples and explanations and supplementary decision trees and graphics. While the core underlying GM policies continue to be reflected in the Code, it also includes new subject areas such as cybersecurity and human rights, and provides guidance on many issues, including safety, speaking up and non-retaliation. Further, each section contains links to related GM policies and resources that can help employees to speak up or ask questions.
Beyond distributing our Code of Conduct and requiring annual training on ethics- and compliance-related topics, we also share information about how to act with integrity in an informal manner throughout the year. For example, GM’s Deputy General Counsel and Chief Compliance Officer, and others in GECC regularly publish articles on GM’s intranet. Articles reinforce topics contained in GM’s Code of Conduct, such as avoiding conflicts of interest, accepting gifts, and referring employees to individuals they can contact if they have questions or concerns.
In many cases, real-world examples of ethics violations at other companies provide teachable moments. An article about the 2017 data breach at Equifax allowed for a refresh on insider trading laws. An account of United Technologies Corporation’s compliance failures offered a cautionary tale about the importance of not only avoiding corruption, but also speaking up when something doesn’t seem right. By keeping ethical behaviors top of mind for all GM employees, we will continue to win with integrity in dealings with suppliers, governments and other third parties.
Doing the right thing is a significant responsibility for everyone at GM. That’s why we take time out each year to focus on ethics and compliance. During the 2018 Ethics and Compliance Week, GM leaders shared messages on key aspects of compliance, emphasizing why all team members should be bold and report potential compliance issues.
The Global Ethics and Compliance Center (GECC) announced several challenges to encourage GM employees to live our values. For example, we reviewed employee recognitions submitted during the year for the behavior “Win with Integrity.”Later in the year, we chose three Integrity Champions after reviewing more than 50 recognition submissions. Each Integrity Champion received 10,000 points through the GM Recognition program. GECC also challenged functions to have the most employees complete Corporate Required Training by a certain date. The winning team received a “traveling trophy” that they are allowed to display until the next winner is chosen the following year.
At GM we encourage ethical behavior year-round; the true purpose of Ethics and Compliance Week is to reinforce the importance of acting with integrity and being in compliance with policies, laws and regulations everywhere and every time we conduct GM business. Our commitment to compliance positively benefits our company’s reputation and business results, creating a better place for all of us to work.
Training is a critical aspect of fostering an ethical culture. In 2018, GM made significant updates to its Compliance Training and Certification program. We restructured the Corporate Required Training (CRT) program with five new courses, combining the annual Winning with Integrity Certification program with the training program. These changes were made in response to employee feedback. Having two separate programs—training and certification—was perceived as redundant and confusing, and some content in training courses was not relevant to all employees’ job roles. Employees also wanted more consistent user interaction with the courses. Going forward, the courses will have a common look and feel, similar navigation procedures and consistent GM branding.
To develop the new training and certification program, we looked at the big picture of GM’s risk profile. We identified four major areas that need to be emphasized every year: the topics found in GM’s Code of Conduct, guidelines for protecting GM’s informational assets, respectful workplace (anti-harassment, diversity, non-discrimination) and safety (including both product and workplace safety). These topics will be covered every year as part of CRT, but the courses will be updated every year with new content, new scenarios and new exercises.
CRT will also include courses on specific legal and regulatory risks, including Anti-Corruption, Antitrust, Data Privacy, Cybersecurity, International Trade and Information Lifecycle Management. These will be rotated in and out of CRT every two to three years and will use adaptive technology that tailors the courses to an individual’s job responsibilities. Required training in 2018 included:
Shawn Rogers is Lead Counsel, Compliance Training and Communications within the Global Ethics & Compliance Center at GM. He explains what it takes to create a compliance program that does much more than check a box, but rather builds an ethical culture.
It starts with how we communicate. As far as I know, at other companies there isn’t a position quite like mine, which was created specifically to look at key elements of the compliance program related to training and communications. Another mental shift we’ve made is viewing compliance training as an opportunity to reinforce our ethical culture. If you don't implement your training program strategically, learners begin to view it as a task that they have to do just to satisfy lawyers. But when we trust that our employees are committed to our Code of Conduct and eager for more information, training programs can become so much more.
It’s important to start with the end in mind. A common mistake is jumping right to tactical questions like which courses you want and how to deploy them. Instead, we chose to begin by drafting design objectives, a set of course standards and a list of the exact risks that we wanted the training program to address. We also came up with three foundational principles that guided our efforts: Trust, Respect and Accountability.
We rely on these principles when we select our vendors, when we decide how many courses should be required each year, when we pick the languages for translations, when we set training completion deadlines, when we send out reminders, when we could grant exceptions and so on.
The principle of Respect refers to the respect we show for employees’ time and intellect. We do this by not requiring employees to take courses that are not relevant to their role, keeping courses short and to the point and setting content standards so that employees don’t have to learn a new method every time they take a new course.
Just as GM employees are united by a shared set of behaviors, our guiding principles have become the measuring stick for our compliance training program. From there, we’ve created a framework for a training program that’s strategic, approachable and flexible enough to accommodate emerging risks and trends.