The foundation of GM’s business is:
A World with Zero Crashes, Zero Emissions and Zero Congestion
Our Core Values
Customers, Excellence, Relationships and Seek Truth
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 Core Behaviors help drive our business decisions and activities worldwide. GM is committed to creating and maintaining an ethical culture and conducts ethical culture surveys across our global workforce to monitor our progress every few years. Our 2020 third-party survey results show that internal perceptions of GM’s ethical culture continue to increase and are higher than the third-party’s 2018–2019 benchmark, which includes responses from over 500,000 individuals across 32 companies. In 2022, for the third year in a row, General Motors was also the only original equipment manufacturer automaker recognized as one of the World’s Most Ethical Companies® by Ethisphere, a global leader in defining and advancing the standards of ethical business practices.
Winning with Integrity is one of our Core Behaviors, and the World’s Most Ethical designation is a testament to our ethical leadership as we continue to transform our company and industry. An ethical business starts at the top. Chair 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. The Board 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 any applicable company policies. The Board, in addition to our eligible salaried employees (e.g., everyone other than those on excused leave), also completes GM’s Code of Conduct training. The Board’s Audit Committee has oversight responsibility for GM’s ethics and compliance program, which promotes a culture of high performance with high integrity by advocating and helping 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 of global public policy, general counsel and corporate secretary, and indirectly to the Board’s Audit Committee. The chief compliance officer provides regular updates to the Audit Committee. The chief compliance officer meets with the Audit Committee in private sessions without other members of management present at least once per year.
The Role of Ethics Compliance Liaisons
In 2021, we launched a new Compliance Liaison program to help further localize compliance into business units and to serve as an additional knowledgeable resource for identifying compliance issues. Compliance liaisons are GM team members supporting business units and regions who help detect, prevent and resolve potential compliance issues across the company.
The GECC prevents, detects and helps correct violations of law and corporate policies and helps promote our ethical business culture. The GECC seeks to align GM’s ethics and compliance program with the recognized elements of an effective compliance program and primarily manages GM’s Code of Conduct; Non-Retaliation Policy; conflict of interest disclosure process; investigations; ethics and compliance training and communications; global policy development; compliance assurance; risk-based third-party due diligence; whistleblower line; anti-corruption compliance assurance in GM strategic transactions; and other anti-corruption risk areas.
Regional compliance officers are established in each of GM’s operating regions to help ensure compliance and ethics globally. We also have 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. Additional global structures and oversight 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—Winning with Integrity—reinforces our commitment to a work environment founded on mutual respect, trust and accountability. It outlines the policies and obligations that guide our business conduct, and includes employee guidance on various reporting mechanisms available to report safety and other concerns (e.g., Speak Up For Safety, Awareline). Our Code of Conduct also emphasizes GM’s Non-Retaliation Policy. It applies across our company, at every level, including supervisors, senior leaders and Board members, and extends to subsidiaries that GM controls. We expect third parties, including suppliers, to act in a manner 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 GM employees working with our third parties to hold third parties accountable. Our Code of Conduct is available in nine languages (including English); our Supplier Code of Conduct is available in 13 languages (including English); and certain compliance policies are available in multiple languages to ensure they are understood by employees and third parties in all locations where GM does business.
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 it guides the conduct of our daily business practices worldwide. In 2022, we refreshed the Code of Conduct to add our “Be Inclusive” behavior, a new CEO leadership message and other relevant and timely content.
To ensure the effectiveness of our Code of Conduct, we regularly conduct independent third-party assessments of GM’s compliance program against the Department of Justice and other applicable laws, regulations and rules. We also regularly conduct compliance risk assessments. Our Code of Conduct publicizes various points of contact for employees with questions or concerns, including local leadership, Human Resources, labor representatives, the GECC, Legal Staff, GM Audit Services and our Awareline.
GM maintains a robust conflict of interest disclosure process that applies to all salaried employees and members of the Board. 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 GECC team develops compliance and ethics messages on a regular basis, underscoring the importance of these topics.
GM encourages our employees to speak up and provides resources to do so. An internal “Report Concerns” site makes it easy for employees to identify the most effective way to quickly report their concern. In cases where an individual is uncomfortable reporting through other 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 confidentially report concerns of misconduct by the company, our 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.
Supplier Due Diligence
GM’s success depends in part on building positive business relationships with reputable and ethical suppliers that meet our business needs. GM maintains a Supplier Code of Conduct that sets forth our expectations for ethical conduct as well as a risk-based due diligence program for our suppliers and business partners. GM’s due diligence activities consider, among other things, safety, reputation, human rights, integrity, business requirements, compliance with laws and GM’s expectations for adherence to Winning with Integrity. We engage in continuous risk assessment, using a variety of tools and cross-functional resources to better understand and mitigate risk. We provide resources to our suppliers through our GM SupplyPower portal and other channels to ensure open communication and to help suppliers understand our expectations and improve their operations. Learn more in Supporting Supplier Responsibility.
In 2021, GM received 4,170 reports to the Awareline, of which 3,048 were classified as allegations, and the remaining reports were suggestions, inquiries or other miscellaneous issues. 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 compliance trend analysis. The case management system allows GM to follow up with individuals who submit Awareline reports anonymously, while preserving the reporter’s anonymity, to help GM 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 or Audit Committee, as well as processes in case a particular allegation requires more immediate reporting. The chief compliance officer also provides regular updates to the Audit Committee on key GECC priorities and accomplishments and trends in Awareline submissions and Investigations.
Speak Up!, GM’s Non-Retaliation Policy, protects GM employees from retaliation when they raise a concern in good faith. GM’s most recent Ethical Culture Survey, as well as industry benchmarking data, shows that the majority of misconduct reports are made to an employee’s manager. To help our GM managers in such circumstances and to provide additional guidance regarding GM’s Non-Retaliation Policy, the GECC has developed a website that provides helpful compliance tools for managers, including compliance toolkits on various topics, compliance moments to use at meetings, quick reference compliance guides and other materials. GM also makes available a scenario-based “What Would You Do?” course for managers. In 2021, the GECC developed and is piloting a post-investigation antiretaliation survey to initiate outreach to known reporters following an investigation to identify and respond to potential retaliation and improve the investigative process. These materials help GM managers create a safe and open reporting environment for their teams.
2021 Types of Allegations Received
|Accounting, Auditing and Financial Reporting
Fraud relating to accounting procedures, internal controls or auditing matters
Examples: Fraud, conflicts of interest, corruption
|Human Resources, Diversity and Workplace Respect
Examples: Interpersonal conflicts, harassment, discrimination, retaliation
|Environment, Health and Safety
Examples: Threats and violence, substance abuse, environmental concerns, workplace safety
|Misuse, Misappropriation of Corporate Assets
Examples: Theft, property damage, information or IP loss, computer misuse
Ethics Training and Education
Training is a critical aspect of reinforcing our ethical culture because it educates our employees on how to apply the standards and principles set forth in our policies in their work activities. Every year, all eligible salaried employees are required to review the Code of Conduct and complete CRT. All CRT courses are available to global employees in eight languages (including English). New or refreshed courses are deployed annually, often with new content, new scenarios and exercises. 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, a cross-functional group that includes senior leaders from human resources, 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 ensure courses are relevant to our employees’ roles, keeping courses concise and setting consistent content standards.
CRT in 2021 included:
- GM Code of Conduct: Winning with Integrity
- Export and Sanctions Compliance
- Antitrust and Competition Law Compliance
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 2021, 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 live and/or “virtual” 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, antitrust, Foreign Corrupt Practices Act, privacy, working with third parties, winning in the marketplace without sacrificing our values and other relevant compliance topics. The GECC also utilizes on-demand microlearning modules so that employees can access refresher training on gifts and entertainment and conflicts of interest processes as needed. Finally, we recognize a companywide Compliance and Ethics Week in which we engage employees through interactive games, leadership messages, compliance toolkits, employee recognitions and other measures to promote our Winning with Integrity behavior. By keeping ethical behaviors top of mind for all GM employees throughout the year, we continue to win with integrity in our dealings with suppliers, governments and other third parties.