Hewlett-Packard Company

Based on public information, there is evidence that the company has published a statement from CEO and Chairman Meg Whitman, supporting the ethics and anti-corruption agenda of the company. In the 2014 Standards of Business Conduct she stresses the importance of a shared set of values that guide the company’s business practices. TI notes that statements in the 2013 Annual Report, 2013 Living Progress Report and 2012 Global Citizenship Report lack focus on the company’s ethics and anti-corruption. The company therefore scores 1. To score higher the company would need to provide evidence of at least two other statements from the last two years, which promote the company the company’s ethics and anti-corruption agenda, or one statement from the last two years that supports the company’s strong stance against corruption.

Based on public information, there is no readily available evidence that the CEO or the Chairman demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. However, evidence suggests that this engagement has been delegated. The Chief Ethics and Compliance Officer Ashley Watson, has written online articles on ethics and anti-corruption issues and the Global Manager of Supply Chain Social & Environmental Responsibility Bob Mitchell, is on the Board of the Eletronic Industry Citizenship Coalition (EICC). The company therefore scores 1. To score higher the company would need to provide evidence that the CEO has demonstrated active external engagement in anti-corruption matters on more than one occasion over the last two years.

Based on public information, there is no readily available evidence that the company’s CEO demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of ethical business conduct, including trust, integrity, honesty and openness. The Standards of Business Conduct provides a detailed explanation of integrity and trust, and clearly demonstrates how they are translated into company policies.

Based on public information, there is evidence that the company belongs to the Electronic Industry Citizenship Coalition (EIIC) and the United Nations Global Compact.

Based on public information, there is evidence that the company has appointed the Audit Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The Committee’s charter is publically available and states it oversees the Company’s ethics and compliance programmes, with respect to legal and regulatory requirements, and conducts reviews with management and the Director of Internal Audit.

Based on public information, there is evidence that the company has appointed Chief Ethics and Compliance Officer Ashley Watson, with responsibility for implementing the company’s ethics and anti-corruption agenda. The Chief Ethics and Compliance Officer has a direct reporting line to the Audit Committee.

Based on public information, there is evidence that the Audit Committee monitors the company’s ethics and anti-corruption agenda. The Audit Committee has responsibility to evaluate, with management and the Director of Internal Audit, the results of their review of compliance. Evidence suggests that this review process takes place at least annually, as the Committee meets at least six times a year. Further evidence suggests that the company conducts an annual review of the anti-corruption compliance programme.

Based on public information, there is evidence of a formal, clear, written plan, on which the review of the ethics and anti-corruption agenda by the Board is based. Evidence suggests that the Audit Committee reviews the company’s ethics and anti-corruption agenda at least annually. The specific plans and goals for the ethics and anti-corruption programme regard training, third party controls, policy improvements, and event and hospitality screening.

Based on public information, there is evidence that the company has a formal process to review and update its policies and practices, in response to actual or alleged instances of corruption. The company’s investigation process has five steps, including the review of investigation findings and the implementation of recommendations. In particular, in response to a recent corruption case it is seeking to improve its policies and practices.

Based on public information, there is some evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. It includes determining the risks associated with different geographies, interactions with government officials and internal procedures. The company therefore scores 1. To score higher the company would need to provide evidence on how the anti-corruption risk assessment is applied, who owns the mitigation plans and when they must be applied.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions. Evidence shows that the company conducts due diligence of potential acquisitions, which includes an assessment of its internal controls, as well as third parties such as agents and joint venture arrangements.

Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents. The company therefore scores 1. To score higher the company would need to provide evidence that it refreshes due diligence at least every 3 years and/or when there is a significant change in the business relationship.

Based on public information, there is evidence that the company has contractual rights and processes for the behaviour, monitoring, control and audit of agents with respect to countering corruption. The company has rights to monitor and audit agents’ activities, and terminate a contract if corrupt activities are found.

Based on public information, there is evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on corruption and the consequences of breaches to this stance. Suppliers agree to conform to the Supplier Code of Conduct and the company has the right to terminate a contract for violations.

Based on public information, there is no readily available evidence that the company explicitly addresses the corruption risks associated with offset contracting.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting its offset partners and offset brokers.

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms, including bribery, facilitation payments and kickbacks.

Based on public information, there is evidence that the company has an explicit zero tolerance stance to corruption.

Based on public information, there is evidence that the company’s ethics and anti-corruption policies are easily accessible to Board members, employees and third parties. The Anti-Corruption Policy, the Standards of Business Conduct, the Partner Code of Conduct, and the Supplier Code of Conduct are all available on the company website and most are provided in numerous languages.

Based on public information, there is evidence that the company’s ethics and anti-corruption policies are easily understandable and clear to Board members, employees and third parties. The policies are written in clear, comprehensible language.

Based on public information, there is evidence that all employees and Board members are required to act in ways that are consistent with the Standards of Business Conduct.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest. The Conflicts of Interest Policy is not publically available, but via the Contingent Worker Code of Conduct and the Standards of Business Conduct, the company clearly defines conflicts of interest and provides examples. Evidence suggests that Board members have a separate conflicts of interest policy.

Based on public information, there is evidence that the company has a policy for the giving and receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. The policy is extremely detailed and provides comprehensive coverage. The policy lists the types of gifts that may never be given or received, sets clear upper values on the acceptable value of a gift, and specifies thresholds that when exceeded will require senior management authorisation.

Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. The policy is extremely detailed and provides comprehensive coverage. The policy lists the nature of hospitality that may never be given or received, sets clear upper values on the acceptable value of hospitality, and specifies thresholds that when exceeded will require senior management authorisation.

Based on public information, there is evidence that the company has a policy that explicitly prohibits facilitation payments, except in circumstances of duress and possible physical harm. The company provides guidance on how this policy is to be implemented in practice.

Based on public information, there is evidence that the company regulates political contributions, in order to prevent undue influence or other corrupt intent. The Government Relations department manages all political contributions, which must be authorised by the Vice President of HP Government Relations. The HP Political Action Committee (HP PAC), a separate legal entity from the company, makes contributions to U.S. congressional and state candidates where corporate contributions are not allowed. The company list recipients of political contributions on its website and provides the total amount in the 2013 Living Progress Report.

Based on public information, there is evidence that the company has a policy that regulates lobbying activity. All employees must obtain approval from Corporate Affairs before lobbying a government official or engaging a lobbyist. In the 2013 Living Progress Report the company provides an overview of the policy areas it seeks to influence and its approach.

Based on public information, there is evidence that the company regulates charitable contributions, in order to prevent undue influence or other corrupt intent. The Sustainability & Social Innovation Organisation administers the company’s charitable contributions and grant-making protocols, to ensure they are fair, transparent and comply with anti-corruption laws. The company therefore scores 1. To score higher the company would need to provide evidence that recipients of charitable contributions are publically declared.

Based on public information, there is evidence that the company provides written guidance to help Board members and employees understand and implement the company’s ethics and anti-corruption agenda. In particular, the Standards of Business Conduct and the Anti-Corruption Poilcy are well organised, unambiguous and suitably illustrated.

Based on public information, there is evidence that the company has an explicit anti-corruption module as part of its ethics and compliance training programme. Anti-corruption is a key element of the annual Standards of Business Conduct refresher training course and sales employees take an additional anti-corruption course annually.

Based on public information, there is evidence that anti-corruption training is provided in all countries where the company operates or has company sites. Specific anti-corruption training modules are provided to employees globally and in 2013, 99.7% of active employees completed an annual Standards of Business Conduct refresher course.

Based on public information, there is some evidence that the company provides anti-corruption training to Board members. However, it is not clear how often this training is refreshed. The company therefore scores 1.

Based on public information, there is evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions. This includes specific training for employees who work in sales, conduct business with the US government and work in high-risk countries.

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest. The company instructs employees to discuss any potential conflicts of interest with their manager. To score higher the company would need to provide evidence that employees are instructed to declare conflicts of interest, either to a manager in writing or to an independent department.

Based on public information, there is evidence that the Standards of Business Conduct and Anti-Corruption Policy state that violations of either policy ‘may’ result in disciplinary action. The company therefore scores 1. To score higher the company would need to provide evidence of an explicit commitment to apply disciplinary procedures to those found to have violated either policy, or examples of discplinary procedures being taken in response to corrupt activites.

Based on public information, there is evidence that the company has multiple, well-publicised, accessible channels, that allow employees to report instances of suspected corrupt acitivty confidentially. Channels include the HR department, local SBC teams, regional SBC liasons, and the company’s Ethics and Compliance Office. In particular, the hotline and corporate compliance email allow anonymous reporting. The company therefore scores 1. To score higher the company would need to provide evidence that employees can report to independent sources.

Based on public information, there is evidence that the company has whistleblowing channels available to all employees globally. Channels include an employees’ local SBC team, the region SBC liason and the company’s Ethics and Compliance Office. In particular, the Ethics and Compliance Officer has a global 24-hour toll-free hotline with translators available.

Based on public information, there is some evidence that the company has formal and comprehensive mechanisms, to assure itself that whistleblowing by employees is not deterred and that whistleblowers are treated supportively. The company encourages employees in policies and on the company website to raise any concerns or questions. The company monitors whistleblowing channel usage statistics using a global case management system and recently conducted a review of the investigation process. The company therefore scores 1. To score higher the company would need to provide evidence of other practices to ensure whistleblowing is encouraged, such as independent employee surveys or follow ups with whistleblowers.

Based on public information, there is evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues. Resources include a local SBC team, a business group or region SBC liason or the company’s Ethics and Compliance Office.

Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. The company therefore scores 1. To score higher the company would need to provide evidence that disciplinary measures are applied to employees who breach this policy.