Firm and Comprehensive Rules and Procedures Shape Behavior
Emerson demands the highest business and personal standards of ethics. Recognizing that Emerson’s reputation is priceless, we lack tolerance for any ethical compromise in our operations as well as in service to our customers, communities and other stakeholders. We formalize our requirements in the Emerson Business Ethics Program , a set of policies and practices honed over the past two decades that defines standards for every Emerson employee in his or her business practices. Emerson’s leaders continuously communicate the roles and responsibilities of employees on the full scope of ethics-related issues, including compliance with the laws, rules and regulations, and accepted practices of each country in which we do business; handling of proprietary data and information; financial reporting; securities trading; and reporting of ethical violations.
This program requires our businesses and more than 140,000 employees to operate fully within these dictates. The Emerson Board of Directors, in conjunction with a senior management committee, oversees the program and bears final responsibility for its prosecution.
Emerson sets standards aligned with different levels and dimensions of our organization. Senior management and Emerson’s Board of Directors regularly review the Emerson Business Ethics Program standards and the CEO and Senior Financial Officer Code of Ethics to consider if updates are necessary or appropriate. The following documents define the elements of Emerson’s Business Ethics Program:
Corporate Governance Principles and Practices
Our Statement of Governance Principles and Practices establishes the guidelines for ethical conduct by members of Emerson’s Board of Directors. This statement articulates the ways in which Emerson must govern for full compliance with the law and in the best interests of our constituencies. The document provides comprehensive rules and criteria for Board roles and responsibilities, from management oversight and performance reporting to director independence standards.
CEO and Senior Financial Officer Code of Ethics
This document clearly conveys the roles, responsibilities and expectations for top corporate officers in exhibiting and promoting integrity and in providing accurate and timely financial reporting.
Ethics Program Handbook for All Employees
Emerson’s Business Ethics Program Handbook sets forth the detailed elements of our ethics program and forms the core of our annual employee ethics training programs. The handbook and our formal ethics training cover topics such as:
• The company’s commitment to conducting business with honesty, integrity and in compliance with applicable laws and regulations.
• Our uncompromising standards for all dealings with customers, suppliers, governments, the public, and each other.
• A stipulation that no employee may have a personal, business or financial interest that conflicts with his or her responsibilities to our company.
• The rules forbidding payments in money, products, gifts or services – either directly or indirectly – to any foreign government representative to induce favorable business treatment or to affect governmental decisions in violation of the U.S. Foreign Corrupt Practices Act (FCPA) or other U.S. or local country laws. Our accounting practices are consistent with the requirements of the FCPA and related regulations.
• The importance of being alert and sensitive to situations that may be illegal, unethical, in violation of the ethics program and supporting policies and procedures, or that are otherwise improper. Additionally, we reinforce our employees’ obligation to report any questionable situations or suspicious activity.
Throughout the world, Emerson operations afford employees easy and routine access to our ethical guidelines. To reinforce the critical importance of these requirements and deal with evolving challenges and interpretations, all employees undergo annual training on Emerson’s ethics requirements. Further, we provide many reporting avenues including a confidential ethics hotline, to promote open communications about ethical concerns.
Annual Ethics Training Outline
We educate each employee with several purposes in mind. First, the consistent attention comprehensively affirms the ethical standards required of every employee. From year to year and region to region, new challenges emerge and we find it necessary to clarify how we interpret the requirements and expect employees to adhere to them. These sessions further encourage dialogue that helps Emerson leaders to identify and address emerging issues. Finally, and most important, we use the interaction to ensure that every employee understands how to report any ethical concern without apprehension or fear of retaliation.
Ethics Hotline for Timely Reporting
To facilitate reporting of ethical concerns, we provide an employee Ethics Compliance Hotline to our employees in the more than 80 countries in which we operate. Reports to the hotline are anonymous if requested. We tolerate no form of reprisal against employees who report concerns.
Ethics hotline calls are received by an independent company, which reports the information to Emerson management for investigation and response. The corporate Human Resources Department maintains a listing of all allegations and ensures that the company investigates and resolves each one. The appropriate managers from Human Resources, Legal, Environmental and Finance conduct the investigations depending on the nature of the issue. The Audit Committee of the Board of Directors reviews hotline calls and their resolution when related to accounting, internal accounting controls and auditing.