The foundation of GM’s business is our vision—seeing a world with zero crashes, zero emissions and zero congestion; our core values—Customers, Excellence, Relationships and Seek Truth; and our eight core behaviors— Be Inclusive, Think Customer, Innovate Now, Look Ahead, One Team, Be Bold, It’s On Me, and Win With Integrity.
Our behaviors drive our business decisions and activities worldwide. GM takes its ethical culture seriously and regularly conducts ethical culture surveys across all levels of our global workforce to monitor our progress. Our most recent third-party survey results show that perceptions of GM's ethical culture continue to increase and are higher than the third-party's 2018-19 global benchmark, which includes responses from over 500,000 individuals across 32 companies. In 2021, for the second year in a row, General Motors was also the only Original Equipment Manufacturer (OEM) automaker recognized by Ethisphere, a global leader in defining and advancing the standards of ethical business practices, as one of the World’s Most Ethical Companies.
Winning with integrity is one of our core behaviors, and this honor is a testament to our ethical leadership as we continue to transform our company and industry. An ethical business starts at the top. Chairman and CEO Mary Barra and other members of our senior leadership team regularly issue messages to all employees emphasizing the importance of our Code of Conduct and their expectation that every employee strive to do the right thing, even when it is difficult. Our Board of Directors is also 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 the law and our Code of Conduct and any applicable company policies. Our Board also completes GM’s Code of Conduct training. The Audit Committee of the Board of Directors has oversight responsibility for GM’s ethics and compliance program, which promotes a culture of high performance with high integrity by advocating and helping to implement the principles of GM’s Code of Conduct—Winning with Integrity.
The Global Ethics and Compliance Center (GECC) is led by the Assistant General Counsel and Chief Compliance Officer, who reports to the Executive Vice President and General Counsel, and indirectly to the Audit Committee of the Board of Directors. The Chief Compliance Officer provides regular updates to the Audit Committee of GM’s Board of Directors. The GECC prevents, detects and helps correct violations of law and corporate policies or ethical business culture. The GECC seeks to align GM’s compliance program with the recognized elements of an effective compliance program and primarily manages GM’s Code of Conduct, conflict of interest disclosure process, investigations, ethics and compliance communications, global policy development, compliance training, compliance assurance, risk-based third-party due diligence, whistleblower line and anti-corruption risk areas. Regional Compliance Officers are established in each of GM’s operating regions to help ensure compliance globally. Additional global structures are in place for safety, export compliance, antitrust compliance, data/cybersecurity compliance, records management compliance and other risk areas.
Code of Conduct
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. It applies to everyone in our company, at every level, including employees, supervisors, Board members and subsidiaries that GM controls. We expect third parties, including suppliers, to act in a way that is consistent with the principles and values outlined in our GM Supplier Code of Conduct when conducting business with, and on behalf of, GM. We expect employees working with our third parties to hold them accountable.
GM maintains a robust conflict of interest disclosure process that applies to all salaried employees and directors. Employees are required to complete an electronic conflict of interest questionnaire at least once during their employment and keep it updated as their personal circumstances change. Board members who are not employees provide written disclosure of any actual or potential conflicts of interest at least once a year. To ensure compliance awareness continues throughout the year, our Global Ethics and Compliance Communications team develops and communicates compliance and ethics messages on a regular basis, underscoring the importance of these topics.
Our Code of Conduct governs how our employees are expected to act: displaying integrity in the workplace, in the marketplace and in their communities when representing GM, and guides the conduct of our daily business practices worldwide. We update the Code of Conduct periodically to ensure it remains relevant and meets the needs of our employees.
To ensure the effectiveness of our Code of Conduct, we periodically use independent firms to evaluate our compliance program. We also have regional compliance officers and a network of compliance liaisons, as well as other compliance personnel located throughout GM who provide guidance to employees and answer ethics and compliance questions. In addition, our Code of Conduct clearly publicizes in multiple places a list of contact points, which include local leadership, Human Resources, labor representatives, the GECC, Legal staff and Awareline, to answer employee questions.
GM encourages our employees to speak up and provides resources to do so. A "Report Concerns" site has been created to make it easy for employees to identify the most effective way to quickly report their concern. In cases where an individual is uncomfortable reporting through established internal channels, we maintain a global toll-free hotline. The Awareline is operated by an independent 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 more than a dozen languages, 24 hours per day, 7 days per week, by phone, web or email. Reports may be made anonymously, where permitted by law.
In 2020, GM received 3,654 reports to the Awareline, of which 2,732 were classified as allegations, 301 were inquiries, 112 were suggestions and 509 were duplicates or “log only” case types. GM tracks all reports of misconduct—whether made to the Awareline or through some other channel—in a case management system that facilitates efficient investigation, follow-up and trend analysis. The system allows GM to follow up with individuals who submit Awareline reports anonymously, while preserving the reporter's anonymity. This functionality enables GM to better investigate and remediate anonymous allegations.
Allegations of misconduct are reviewed and prioritized based on a number of factors, including the type of misconduct, the position of the alleged wrongdoer within the company and whether the allegation entails any potential violations of law. High-priority cases receive special scrutiny and review; a cross-functional committee meets monthly to discuss their investigative progress and resolution. There is also a quarterly review process to determine which cases, if any, require reporting to the Board of Directors or Audit Committee, as well as processes in case a particular allegation requires more immediate reporting.
Speak Up!, GM's Non-Retaliation Policy, protects GM employees from retaliation as a result of raising concerns in good faith. Industry benchmarking data shows that the majority of misconduct reports are made to an employee’s manager. To help our own GM managers in such circumstances and to provide additional guidance regarding GM’s nonretaliation policy, the GECC and Global Security teams developed a tool kit on how to address workplace retaliation, and also added nonretaliation scenarios to the live “What Would You Do?” course available to managers.
Ethics Training and Education
Training is a critical aspect of reinforcing an ethical culture. Every year, all eligible salaried employees are required to review the Code of Conduct and complete Corporate Required Training (CRT). The CRT emphasizes four areas: the topics found in GM’s Code of Conduct, guidelines for protecting GM’s informational assets, maintaining a respectful workplace (e.g., antiharassment, diversity, equity and inclusion and nondiscrimination) and product and workplace safety. Although these topics are covered every year as part of CRT, the courses are updated annually with new content, new scenarios and exercises.
CRT also includes courses on specific legal and regulatory risks, including Anti-Corruption, Antitrust, Data Privacy, Cybersecurity, International Trade and Information Lifecycle Management. These detailed courses are rotated in and out of the CRT every two to three years. We use adaptive technology that tailors the courses to an individual’s job responsibilities.
GM’s Compliance Training and Communications Group within the GECC oversees the process of regularly updating the CRT. Once the annual program and policy certification requirements are approved by the CRT Governance Board, the course owners and subject matter experts draft the course objectives and content based on company risk analysis and any new compliance regulations. We follow guiding principles of trust, respect and accountability as we select vendors, determine how many courses to offer, set completion deadlines and make other course-related decisions. For example, we show respect for our employees by ensuring courses are relevant to their role, keeping courses concise and setting consistent content standards. Required training in 2020 included:
- GM Code of Conduct: Winning with Integrity
- Workplace Harassment: A Global Perspective
- Privacy Basics
- Litigation Hold and ILM Compliance
- Get Secure—Stay Secure
Once employees complete the Code of Conduct training, they are required to certify that they agree to comply with the policies contained in the Code; that they have disclosed any new potential conflicts of interest; and that they have reported any violations of the Code and any vehicle or workplace safety issues. In 2020, GM achieved a 100% completion rate among eligible salaried employees for both our CRT and Code of Conduct Certification Program.
Beyond distributing our Code of Conduct and requiring annual training on ethics- and compliance-related topics, we use risk-based principles to provide in-person training to thousands of employees each year. For example, the Compliance team conducted live training sessions to targeted audiences on topics that included export compliance, antiharassment and other relevant compliance topics. The GECC also utilizes on-demand microlearning models so that employees can access refresher training on gifts and entertainment, anticorruption or conflicts of interest processes as needed. We also recognize Corporate Compliance and Ethics Week, organized each year by the Society of Corporate Compliance and Ethics & Health Care Compliance Association (SCCE and HCCA). By keeping ethical behaviors top of mind for all GM employees, we will continue to win with integrity in our dealings with suppliers, governments and other third parties.
2020 Ethics Training By-the-Numbers
1 Excludes 57,128 online training (non-GM LMS) SGM/SGMW Joint Venture sessions.
2 Includes 20,380 SGM/SGMW Joint Venture sessions.
Third-Party Due Diligence
GM's success depends in part on building positive business relationships with reputable and ethical suppliers that meet our business needs. To that end, GM conducts appropriate due diligence to help us identify such suppliers and protect the company and our employees from potential legal, financial and reputational harm. For those business partners who interact with non-U.S. government (i.e., foreign) officials on GM’s behalf, GM also requires third-party acknowledgment of and compliance with GM’s Supplier Code of Conduct as a contractual requirement of doing business with our company.