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 truth; and our seven core behaviors — 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, and are our road map for sustainability. General Motors was recognized by Ethisphere, a global leader in defining and advancing the standards of ethical business practices, as one of the 2020 World’s Most Ethical Companies.
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 desire 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, our Code of Conduct and our 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. The Global Ethics and Compliance Center (GECC) is led by the Deputy General Counsel and Chief Compliance Officer, who reports to the Executive Vice President and General Counsel, Legal and indirectly to the Audit Committee of the Board of Directors. The Deputy General Counsel provides regular updates to the Audit Committee of GM’s Board of Directors. The GECC prevents, detects and corrects violations of law and corporate policies and promotes a culture of business ethics. 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, special investigations, ethics and compliance communications, policy development, compliance training, global 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 key compliance 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. 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 various compliance and ethics 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. It directs all employees to be good stewards of the environment as embodied in our Guiding Environmental Commitments, which guide 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 GM 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 other compliance personnel located throughout GM who provide guidance to employees and answer ethics and compliance questions. In addition, our Code clearly publicizes in multiple places a list of contact points, which include human resources, security, legal and audit staff, to answer employee questions.
GM encourages our employees to speak up and provides resources to do so. 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 2019, GM received 4,263 reports to the Awareline, of which 3,483 were classified as allegations, 234 were inquiries, and 15 were suggestions. 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 current system was implemented in late 2018 and improves upon the prior system in many ways, most notably in that it allows GM to follow up with individuals who submit Awareline reports anonymously while preserving those reporters’ anonymity. This new functionality has significantly improved GM’s ability to investigate and remediate anonymous allegations.
|Category||Proportion of Allegations|
|Accounting, Auditing and
|Human Resources, Diversity and Workplace Respect||38%|
|Environment, Health and Safety||26%|
|Misuse, Misappropriation of Corporate Assets||31%|
Numbers do not total 100 percent due to rounding.
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.
For potential vehicle safety issues, a special Speak Up For Safety hotline was established in May 2014.
Speak Up!, GM’s non-retaliation policy, is intended to protect 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 non-retaliation policy, the GECC and Global Security teams developed a tool kit on how to address workplace retaliation, and also added non-retaliation 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. Corporate Required Training emphasizes four areas: the topics found in GM’s Code of Conduct, guidelines for protecting GM’s informational assets, respectful workplace (anti-harassment, diversity, nondiscrimination) and safety (including both product and workplace safety). Although these topics are covered every year as part of Corporate Required Training, the courses are updated annually with new content, new scenarios and new exercises.
Corporate Required Training 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 Corporate Required Training 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 Corporate Required Training. To develop new content, we begin by drafting design objectives, course standards and a list of the exact risks that a training program must address. 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 2019 included:
- GM Code of Conduct: Winning with Integrity
- Product and Workplace Safety Training: Never Forget
- GM Information Security: Think Before You Click, Share or Post
- Workplace Harassment: A Global Perspective
- Global Anti-Corruption Compliance
- Get Secure — Stay Secure
Once employees complete training, they are required to certify that they agree to comply with the policies contained in the Code of Conduct, and that they have reported any violations of the Code and any vehicle or workplace safety issues. In 2019, GM achieved a 100 percent completion rate among eligible salaried employees for both our Corporate Required Training 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, anti-harassment and other relevant compliance topics. The GECC also launched on-demand microlearning models in 2019 so that employees can access refresher training on gifts and entertainment, anti-corruption 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 the 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.