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FINAL ASSESSMENT

GE AVIATION

The following pages contain the detailed scoring for your company based on

public information.

The following table represents a summary of your scores:

Topic Number of

questions

% score based

on public

information

Leadership, Governance and

Organisation

10 60%

Risk Management 7 42.9%

Company Policy and Codes 12 79.2%

Training 5 40%

Personnel and Helplines 7 78.6%

Total 41 63.4%


A1:

Does the company publish a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company?

Score:

1

Comments:

Based on public information, there is evidence that the CEO Jeff Immelt has released one strong statement supporting the ethics agenda of the company. However, TI has found no evidence of a statement in the last two years supporting the company’s strong stance against corruption specifically, or several statements in the last two years promoting the ethics and anti-corruption agenda, under which it is clear that anti-corruption is a significant component. The company therefore scores 1.

References:

Public:

Message from David Joyce, President & CEO of General Electric Aviation (Unsure of publishing date):

‘We are a company of unyielding integrity and our worldwide reputation for honest and reliable business conduct, built by so many people, is tested and proved in everything we do’

‘Our quest for competitive excellence begins and ends with our commitment to lawful and ethical conduct. As a global company, we must create and follow a set of global rules’

‘I, and all GE leaders, have the additional responsibility of nurturing a culture in which compliance with our internal policies and applicable laws are at the very core of our business activities. Integrity is the way we work’

http://www.geaviation.com/ourcommitment/integrity/

http://www.gecareers.com/GECAREERS/jsp/india/workingatge/integrity.jsp

Integrity Guide for Suppliers, Contractors and Consultants (September 2009), p. 1:

‘A Message from GE


http://www.gecareers.com/GECAREERS/jsp/india/workingatge/integrity.jsp


The General Electric Company (“GE”) is committed to unyielding Integrity and high standards of business conduct in everything we do, especially in our dealings with GE suppliers, contractors and consultants (collectively “Suppliers”). For well over a century, GE people have created an asset of incalculable value: the company’s worldwide reputation for integrity and high standards of business conduct. That reputation, built by so many people over so many years, depends on upholding it in each business transaction we make.

GE bases its Supplier relationships on lawful, efficient and fair practices, and expects its Suppliers to adhere to applicable legal and regulatory requirements in their business relationships, including those with their employees, their local environments, and GE. The quality of our Supplier relationships often has a direct bearing on the quality of our customer relationships. Likewise, the quality of our Suppliers’ products and services

affects the quality of our own products and services.’

http://www.geaviation.com/company/doing-business-with-aviation/docs/GE_integrity_guide.pdf

Company video: ‘how do we drive accountability’

http://www.ge.com/ar2013/#/letter

Annual Report (2012), p.17: Jeff Immelt

‘Big companies fail when they lose a culture of accountability—accountability for outcomes. We must compete with purpose. And we must deliver outcomes for customers, investors, society and each other. We are building processes that drive speed, accountability and compliance.’

Annual Report (2013), p.32: Management discussion, Jeff Immelt & Jeffrey Bornstein

‘We believe that great companies are built on a foundation of reliable financial information and compliance with the spirit and letter of the law.’

‘Our global integrity policies—“The Spirit & The Letter”—require compliance with law and policy, and pertain to such vital issues as upholding financial integrity and avoiding conflicts of interest. These integrity policies are available in 29 languages, and are provided to all of our employees, holding each of them accountable for compliance. Our strong compliance culture reinforces these efforts by requiring employees to raise any compliance concerns and by prohibiting retribution for doing so. To facilitate open and candid communication, we have designated ombudspersons throughout the Company to act as independent resources for reporting integrity or compliance concerns. We hold our directors, consultants, agents and independent contractors to the same integrity standards.’

http://www.ge.com/ar2013/#/



http://www.ge.com/ar2013/#/letter



A2:

Does the company’s Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company?

Score:

2

Comments:

Based on public information, there is evidence that the CEO of GE Aviation displays a strong external facing commitment to the ethics and anti-corruption agenda of the company, as a member of the DII Steering Committee. In addition, the CEO of GE contributed to the magazine Ethisphere, in which he displayed a good engagement with the ethics engagement of the company.

References:

Public:

GE CEO Jeff Immelt Speaks at Columbia University (November 2008), Botwinick Prize in Ethics 2008:

Business ethics- make sure everyone knows what they are accountable for and responsible

Transparent inside and outside the company

Ethical behaviour throughout the organisation, giving back to the community, making money by solving big problems

‘Jeffrey Immelt, chairman and CEO of General Electric, visited Columbia Business School on October 24 to receive the Botwinick Prize in Business Ethics, which is organized under the auspices of the Sanford C. Bernstein & Co. Center for Leadership and Ethics’

http://www.youtube.com/watch?v=dsUv1bEWywg

http://www.youtube.com/watch?v=3cPOodEGrV0

Jeff Immelt announced in 2004 that virtue was one of the key things to keep the company on top:

http://books.google.co.uk/books?id=nMUExSMU-

http://www.youtube.com/watch?v=dsUv1bEWywg

http://www.youtube.com/watch?v=3cPOodEGrV0

http://books.google.co.uk/books?id=nMUExSMU-CcC&pg=PA158&lpg=PA158&dq=%22jeff+immelt%22+%22business+ethics%22&source=bl&ots=H0WogNm03T&sig=cGEdazeGu7ZRDGRSOeBsd6XZsvo&hl=en&sa=X&ei=17aWU87AEcK5O8ywgbAD&ved=0CCkQ6AEwAQ#v=onepage&q=%22jeff%20immelt%22%20%22business%20ethics%22&f=false


CcC&pg=PA158&lpg=PA158&dq=%22jeff+immelt%22+%22business+ethics%22&source=bl&ots=H0WogNm03T&sig=cGEdazeGu7ZRDGRSOeBsd6XZsvo&hl=en&sa=X&ei=17aWU87AEcK5O8ywgbAD&ved=0CCkQ6AEwAQ#v=onepage&q=%22jeff%20immelt%22%20%22business%20ethics%22&f=false

David L Joyce, President and CEO of GE Aviaiton, is on the DII steering committee.

Ethisphere Q2 Earning Your Reputation (June 2013), Jeffrey Immelt, Chairman and CEO, General Electric :

‘General Electric is deeply honored to participate in Ethisphere’s first-ever Trust Isssue. We are honored because a vital asset for good companies is the trust of customers, investors, governments and employees. Simply put, trust is to GE as air is to breathing.

In the wake of the financial crisis and at a time when people all over the world are still adjusting to a volatile economy, trust in large institutions, both governments and businesses, has suffered. So the task is a challenging one. We must “earn the right to be big.” And when you are a global, publicly traded company like GE, you have to work even harder to maintain that trust. Being big means that we must never let a tough environment be an excuse for failing to live up to our high standards of performance, governance and compliance. We recognize that the burden is with us to earn trust.

Still, recognizing the importance of trust is easy. Maintaining trust over the long term is hard work. We start with strong operating rigor, where risk and regulatory are embedded and ingrained in the way that we run the Company. Even so, we know we aren’t perfect. Trust has to be earned every day … and over the long term. That is why we work hard to sustain a culture that is the foundation for earning and keeping trust. GE’s operational rigor and culture of trust play an important role in our relationships with three of our most important stakeholders – customers, governments and employees.’

‘Maintaining trust over the long term is hard work. We start with strong operating rigor, where risk and regulatory are embedded and ingrained in the way that we run the Company. Even so, we know we aren’t perfect. Trust has to be earned every day … and over the long term. That is why we work hard to sustain a culture that is the foundation for earning and keeping trust’

‘Earning and maintaining trust also requires unswerving steadfastcommitment to compliance with regulatory and legal requirements.We honor that commitment through a deep and continuing investment in rigorous compliance programs and systems.’

‘GE’s improper payments compliance program is another example of our processes. GE’s policy against improper payments has been a key part of GE’s Spirit & Letter policies and procedures for more than 17 years. But our compliance efforts have not been limited to building an internal program. We recognized early on that the commitment to a corruption-free playing field for business required going beyond having an internal compliance program to demonstrate our commitment to transparency and integrity in the international






marketplace.’

http://ethisphere.com/magazine-articles/earning-your-reputation/

Trust, Ethicsphere magazine (2012):

~ Jeff Immelt: Earning your Reputation: Building Trust with Every Stakeholder’

http://www.gesustainability.com/wp-content/uploads/2014/05/GE__Ethisphere_Trust_Feature.pdf

David L. Joyce, GE representative on DII Steering Committee:

http://www.dii.org/dii-steering-committee

http://ethisphere.com/magazine-articles/earning-your-reputation/



http://www.dii.org/dii-steering-committee


A3:

Does the company’s Chief Executive Officer demonstrate a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the CEO demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. TI is aware of statements that the company’s ‘leaders’ play a strong role in engaging employees about ethics, but it is not clear if this relates to the CEO in particular.

References:

Public:

TI notes:

GE Complaince Employee Engagement (2012):

‘GE Works’ describes our culture: mission based; a belief in a better way; “we” versus “me” ; willingness to tacklehard problems. We believe that culture and resiliency count in a company. This is how we work. This is how we compete. GE Works. Jeff Immelt’

Company Website, Intergiry and Compliance: ‘GE infuses compliance and governance into every aspect of its business.

GE leaders set the tone by personally engaging in the compliance program through active oversight of compliance risks, participating in integrity events and leading by example’

http://www.gesustainability.com/how-ge-works/integrity-compliance/

http://www.gesustainability.com/how-ge-works/integrity-compliance/


A4:

Does the company publish a statement of values or principles representing high standards of business conduct, including honesty, trust, transparency, openness, integrity and accountability?

Score:

1

Comments:

Based on public information, there is limited evidence that the company publishes a statement of values representing high standards of business conduct. TI recognises some of the values are present in the short Code of Conduct, with ‘integrity’ appearing across General Electric publications, however these are not presented as a clear statement of company values. The company therefore scores 1.

References:

Public:

The Spirit & The Letter (2014), p.1 : The Code of Conduct

‘Be honest, fair and trustworthy in all of your GE activities and relationships.’‘A strong culture of integrity’

http ://www.gesustainability.com/how-ge-works/integrity-compliance/a-strong-culture-of-integrity/

Company Website, The Spirit and the Letter :

‘GE’s commitment to perform with integrity is instilled in every employee as a nonnegotiable expectation of behavior. This expectation is guided by our integrity policy, The Spirit & The Letter, and is underscored by an extensive system of policies, processes, training and communications.’

http://www.gesustainability.com/how-ge-works/integrity-compliance/the-spirit-the-letter/

GE Aviation CEO statement on Integrity:


http://www.gesustainability.com/how-ge-works/integrity-compliance/a-strong-culture-of-integrity/





A5:

Does the company belong to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption?

Score:

2

Comments:

Based on public information, there is evidence that the company belongs to the United National Global Compact and the Defense Industry Initiative on Business Ethics and Conduct (DII).

References:

Public:

GE Sustainable Growth(2011), p.36: Signatory to the United Nations Global Compact in 2008

OECD, an active partner of the G20 and B20 in the global fight against corruption

‘In this regard, I have to congratulate the B20, under the leadership of General Electric and Fluor Corporation and with the support of the World Economic Forum and the International Chambre of Commerce, for the breadth and depth of their proposals throughout the year. In fact, the B20 Task Force on Anti-Corruption has shared dialogue with its G20 counterparts more effectively than any other B20 group.’

http://www.oecd.org/g20/topics/anti-corruption/oecdanactivepartneroftheg20andb20intheglobalfightagainstcorruption.htm

Sustainable Growth (2012), p.6: ‘For the second consecutive year, GE co-chaired the B20 Working Group on Improving Transparency and Anticorruption, which provided G20 recommendations for measures to reduce both the supply and the demand side of corruption.’

http://www.dii.org/signatories



http://www.dii.org/signatories


A6:

Has the company appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda?

Score:

2

Comments:

Based on public information, there is evidence suggesting that the Audit Committee has responsibility for oversight of the company’s ethics and anti-corruption agenda. The Audit Committee charter states the Audit Committee will review and investigate any matters pertaining to the integrity of management or adherence to standards of business conduct as required in the policies of the Company.

References:

Public:

Company Website, The Board:

Audit committee responsibities include to ‘oversee the company’s compliance and integrity activities and programs’

http://www.ge.com/investor-relations/governance/board-of-directors

Audit Committee Charter (2014), p.2:

‘To review and investigate any matters pertaining to the integrity of management or adherence to standards of business conduct as required in the policies of the Company. This should include regular reviews of the compliance processes and programs in general and the corporate ombudsman process in particular. In connection with these reviews, the committee will meet, as deemed appropriate, with the general counsel and other Company officers or employees.’

http://www.ge.com/sites/default/files/AC_charter.pdf

Governance and Public Affairs Committee Charter (2014), p.1:

‘The committee’s responsibilities include ‘furtherance of its corporate social responbility,




including considering the impact of Company procedures and processes on employees, citizens and communities.’

http://www.ge.com/sites/default/files/GPAC_charter.pdf



A7:

Has the company appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda, and who has a direct reporting line to the Board?

Score:

1

Comments:

Based on public information, there is some evidence that the company has appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda, and who has a direct reporting line to the Board. This individual is Senior Vice President and General Counsel, Brackett B. Denniston. However, the scope of his role and duties is not clear. The company therefore scores 1.

References:

Public:

Brackett B. Denniston III, Senior Vice President and General Counsel, GE

http://www.ge.com/about-us/leadership/profiles/brackett-b-denniston-iii

http://www.ge.com/about-us/leadership/profiles/brackett-b-denniston-iii


A8:

Is there regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda?

Score:

1

Comments:

Based on public information, there is evidence that the Audit Committee regularly reviews compliance processes and programmes. However, the scope of the review appears to be more of a continuous monitoring than a major periodic review, and its focus is broader than the ethics and anti-corruption agenda. TI notes that the company provided internal information for the 2012 CI which was openly published in the survey report with the company’s permission. However, the public assessment score remains 1 as this part of the survey is seeking to understand company transparency.

References:

Public:

Company Website, The Board:

Audit committee responsibities include to ‘oversee the company’s compliance and integrity activities and programs’


Audit Committee Charter (2014), p. 2:

‘To review and investigate any matters pertaining to the integrity of management or adherence to standards of business conduct as required in the policies of the Company. This should include regular reviews of the compliance processes and programs in general and the corporate ombudsman process in particular. In connection with these reviews, the committee will meet, as deemed appropriate, with the general counsel and other Company officers or employees.’





A8(a):

Is there a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, and evidence of improvement plans being implemented when issues are identified?

Score:

0

Comments:

Based on public information, there is no readily available evidence of a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based.

References:

Public:

NA


A9:

Does the company have a formal process for review and where appropriate update its policies and practices in response to actual or alleged instances of corruption?

Score:

2

Comments:

Based on public information, there is evidence that the company has a process to review and where appropriate update its policies in the event of an actual or alleged instance of corruption.

References:

Public:

Company Website, Integrity and Compliance:

‘Prompt corrective action and discipline are elements of a strong integrity culture at GE. Confirmed violations of Company policies and procedures result in corrective actions such as training, strengthening routines, and simplifying or updating processes. Although many policy nonconformances result from unintended mistakes, disciplinary actions are taken in appropriate cases involving intentional wrongdoing.’





A9(a):

Does the company have a formal anti-corruption risk assessment procedure implemented enterprise-wide?

Score:

2

Comments:

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. There are regular (annual) management risk assessments forcode of conduct and regulatory compliance. There is evidence of implementation processes and risk ownership.

References:

Public:

Company Website, The Board: ‘Audit committee responsibilites include to ‘discuss with management the company’s risk assessment and risk management practices’


Risk Committee Charter (2014), p.2:

‘The purpose of the committee shall be to assist the board in its oversight of the Company’s risk-management framework, including key strategic and operational risks’

‘Risk assessment and risk management are the responsibility of the Company’s management. The committee has an independent oversight role’

http://www.ge.com/sites/default/files/RC_charter.pdf

Risk Committee Key Practices (2014), p.1:

‘The committee shall periodically undertake comprehensive in-depth reviews of significant enterprise risks affecting the Company and GECC.’

http://www.ge.com/sites/default/files/RC_key_practices.pdf

Distributed Compliance Strategy:


http://www.ge.com/sites/default/files/RC_charter.pdf

http://www.ge.com/sites/default/files/RC_key_practices.pdf


‘GE performs an annual risk assessment for approximately 1,400 sites based on common internal and external risk indicators. GE Industrial businesses and GE Internal Audit partner to review these risk-assessment results and develop risk management plans such as on-site audits. Additionally, sites identified as having an elevated level of risk are audited on a three-year rotational basis by the Corporate Audit Staff team. Site reviews and audit results are monitored and reviewed by our business controllers.’

http://www.gesustainability.com/how-ge-works/integrity-compliance/distributed-compliance-strategy/

Annual Report (2012), p.39: Global Risk Management Strategy

Annual Report (2013), p.39:

‘The GE Board of Directors (Board) has oversight for risk management with a focus on the most significant risks facing the Company, including strategic, operational, financial and legal and compliance risks. At the end of each year, management and the Board jointly develop a list of major risks that GE plans to prioritize in the next year.’

‘The GE Board’s risk oversight process builds upon management’s risk assessment and mitigation processes, which include standardized reviews of long-term strategic and operational planning; executive development and evaluation; code of conduct compliance under the Company’s The Spirit & The Letter; regulatory compliance; health, safety and environmental compliance; fi nancial reporting and controllership; and information technology and security. A vice chairman of GE and GE’s CRO are responsible for overseeing and coordinating risk assessment and mitigation on an enterprise-wide basis. They lead the Corporate Risk Function and are responsible for the identification of key business risks, providing for appropriate management of these risks within GE Board guidelines, and enforcement through policies and procedures. In 2013, the Company combined its risk evaluation process with its quarterly operating reviews to simplify the Company’s operating rhythm and added a vice chairman position with responsibility for both enterprise risk and operations. The Policy Compliance Review Board is a management-level committee that further assists in assessing and mitigating risk.’

Company Website, Governance and Controllership:

‘The Board has oversight for risk management, with a focus on the most significant risks facing the Company, including strategic, operational, financial, and legal and compliance risks. At the end of each year, management and the Board jointly develop a list of major risks that GE plans to prioritize in the next year. Throughout the year, the Board and the committees to which it has delegated responsibility dedicate a portion of their meetings to review and discuss specific risk topics in greater detail. Strategic, operational and reputational risks are presented and discussed in the context of the CEO’s Report on Operations to the Board at regularly scheduled Board meetings and at presentations to the Board and its committees by vice chairmen; GE and GECC chief risk officers (CROs); general counsel; and other employees.




Risk assessment and risk management are the responsibility of management and are carried out through risk managers who are operationally integrated into each of our businesses. These risk managers have acquired deep domain expertise through their long careers and through proximity to the business’ operations and core processes. Both risk managers and business leadership teams have specific, risk-focused goals and objectives that are aligned with our overall risk framework.

The Board’s risk-oversight process builds upon management’s risk assessment and mitigation processes, which include standardized reviews of long-term strategic and operational planning; executive development and evaluation; Code of Conduct compliance under the Company’s The Spirit & The Letter; regulatory compliance; health, safety and environmental (EHS) compliance; financial reporting and controllership; and information technology and security. A vice chairman of GE and GE’s CRO are responsible for overseeing and coordinating risk assessment and mitigation on an enterprise-wide basis. They lead the Corporate Risk function and are responsible for the identification of key business risks, providing for appropriate management of those risks within GE Board guidelines, and enforcement through policies and procedures.

In 2013, the Company combined its risk-evaluation process with its quarterly operating reviews to simplify the Company’s operating rhythm. The Policy Compliance Review Board is a management-level committee that further assists in assessing and mitigating risk. This Review Board, which conducted four compliance operating reviews and met seven times in 2013, is chaired by the Company’s general counsel and includes the chief financial officer and other senior-level functional leaders. It has principal responsibility for monitoring compliance matters across the Company.

Risks identified through our risk-management processes are prioritized and, depending on the probability and severity of the risk, escalated to the CRO. These risks are discussed and responsibility for them is assigned to the business or functional leader most suited to manage the risk in connection with the quarterly operating reviews. Assigned owners are required to continually monitor, evaluate and report on risks for which they bear responsibility. Enterprise risk leaders within each business and corporate function are responsible to present to the CRO risk assessments and key risks at least annually. We have general response strategies for managing risks, which categorize risks according to whether the Company will avoid, transfer, reduce or accept the risk. These response strategies are tailored to ensure that risks are within acceptable GE Board general guidelines.’

http://www.gesustainability.com/how-ge-works/governance/governance-and-controllership/




A10:

Does the company have a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied?

Score:

0

Comments:

Based on public information, there is insufficient evidence that the company has an anti-corruption risk assessment procedure for assessing proposed business decisions. The level of available detail is assessed to be low with, for example, no information on the the degree of formality or the circumstances under which such a procedure should be applied.

References:

Public:

TI notes:

Company Website, Governance and Controllership:

‘In 2013, the Company combined its risk evaluation process with its quarterly operating reviews to simplify the Company’s operating rhythm and added a vice chairman position with responsibility for both enterprise risk and operations..’





A11:

Does the company conduct due diligence that minimises corruption risk when selecting or reappointing its agents?

Score:

1

Comments:

Based on public information, there is some evidence that the company conducts due diligence that minimises corruption risk when selecting agents. However, there is no evidence that the company refreshes the due diligence at least every 3 years and / or when there is a significant change in the business relationship. The company therefore scores 1.

References:

Public:

Improper Payments:

‘Extensive controls over third-party intermediaries such as commercial agents and representatives, distributors and service providers, including thorough due diligence, careful screening and training on GE policies.’

http://www.gesustainability.com/how-ge-works/integrity-compliance/improper-payments/

The Spirt and The Law (2014), p.7:

Improper payments section, ‘Follow your business due diligence procedures and require that any third party representing GE be carefully selected and comply with this policy.’

(p.10): ‘Collect and understand documentation about prospective customers, agents and business partners to ensure that they are involved in legitimate business activities and that their funds come from legitimate sources.’

http://www.gesustainability.com/wp-content/uploads/2014/05/English_Spirit-Letter-Booklet.pdf





A12:

Does the company have contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption?

Score:

1

Comments:

Based on public information, there is evidence that the company has contractual rights and processes for the control of agents with respect to countering corruption. However, TI has found no readily available evidence that the company has the right to monitor and audit agents. The company therefore scores 1.

References:

Public:

Integrity Guide for Suppliers, Contractors and Consultants:

‘GE’s commitment to total, unyielding Integrity is set forth in GE’s compliance handbook, The Spirit & The Letter. The policies set forth in The Spirit & The Letter govern the conduct of all GE employees and are supplemented by compliance procedures and guidelines adopted by GE business components. All GE employees must not only comply with the “letter” of the Company’s compliance policies, but also with their “spirit.”. The “spirit” of GE’s Integrity commitment is set forth in the GE Code of Conduct, which each GE employee has made a personal commitment to follow:

• Obey the applicable laws and regulations governing our business conduct worldwide.

• Be honest, fair and trustworthy in all of your GE activities and relationships.

• Avoid all conflicts of interest between work and personal affairs.

• Foster an atmosphere in which fair employment practices extend to every member of the diverse GE community.

• Strive to create a safe workplace and to protect the environment.

• Through leadership at all levels, sustain a culture where ethical conduct is recognized, valued and exemplified by all employees.

No matter how high the stakes, no matter how great the challenge, GE will do business only


by lawful and ethical means. When working with customers and Suppliers in every aspect of our business, we will not compromise our commitment to integrity

………

Improper Payments

• Always adhere to the highest standards of honesty and integrity in all contacts on behalf of GE. Never offer bribes, kickbacks, illegal political contributions or other improper payments to any customer, government official or third party. Follow the laws of the United States and other countries relating to these matters.

• Do not give gifts or provide any entertainment to a customer or supplier without prior approval of GE management. Make sure all business entertainment and gifts are lawful and disclosed to the other party’s employer.

• Employ only reputable people and firms as GE representatives and understand and obey any requirements governing the use of third party representatives.

Conflicts of Interest

• Financial, business or other non-work related activities must be lawful and free of conflicts with one’s responsibilities to GE.

• Report all personal or family relationships, including those of significant others, with current or prospective suppliers you select,

manage or evaluate.

• Do not use GE equipment, information or other property (including office equipment, e-mail and computer applications) to conduct personal or non-GE business without prior permission from the appropriate GE manager. …………

Responsibilities of GE Suppliers

As stated above, GE requires and expects each GE Supplier to comply with all applicable laws and regulations. Unacceptable practices by a GE Supplier include:

Code of Conduct. Failure to maintain and enforce GE policies requiring adherence to lawful business practices, including a prohibition against bribery of government officials.

• Business Practices and Dealings with GE. Offering or providing, directly or indirectly, anything of value, including cash, bribes, gifts, entertainment or kickbacks, to any GE employee, representative or customer or to any government official in connection with any GE procurement, transaction or business dealing. Such prohibition includes the offering or providing of any consulting, employment or similar position by a Supplier to any GE employee (or their family member or significant other) involved with a GE procurement. GE also prohibits a GE Supplier from offering or providing GE employees, representatives or customers or any government officials with any gifts or entertainment, other than those of nominal value to commemorate or recognize a particular GE Supplier business transaction or activity. In particular, a GE Supplier shall not offer, invite or permit GE employees and representatives to participate in any Supplier or Supplier-sponsored contest, game or promotion.

• Business Entertainment of GE Employees and Representatives. Failure to respect and


comply with the business entertainment (including travel and living) policies established by GE and governing GE employees and representatives. A GE Supplier is expected to understand the business entertainment policies of the applicable GE business component or affiliate before offering or providing any GE employee or representative any business entertainment. Business entertainment should never be offered to a GE employee or representative by a Supplier under circumstances that create the appearance of an impropriety.

• Use Subcontractors or Third Parties to Evade Requirements. The use of subcontractors or other third parties to evade legal requirements applicable to the Supplier and any of the standards set forth in this Guide.

The foregoing standards are subject to modification at the discretion of GE. Please contact the GE manager you work with or any GE Compliance Resource if you have any questions about these standards and/or their application to particular circumstances. Each GE Supplier is responsible for ensuring that its employees and representatives understand and comply with these standards. GE will only do business with those Suppliers that comply with applicable legal and regulatory requirements and reserves the right, based on its assessment of information available to GE, to terminate, without liability to GE, any pending purchase order or contract with any Supplier that does not comply with the standards set forth in this section of the Guide.’

http://www.gesupplier.com/html/SuppliersIntegrityGuide/download/GE%20Integrity%20Guide%20for%20Suppliers%202013_ENGLISH.pdf

Spirit of the Letter (2014), p.2:

‘GE employees working with third parties such as consultants, agents, sales representatives, distributors and independent contractors must:

• Require these parties to agree to comply with relevant aspects of GE’s compliance policies.

• Provide these parties with education and information about policy requirements.

• Take action, up to and including terminating a contract, after learning that a third party failed to abide by GE’s compliance policies.’


Ethisphere Q2 (2012), p.23:

‘The company makes sure that dealers that facilitate the sale of GE products and services also receive compliance training. GE Healthcare in China has a rigorous dealer qualification program that includes quarterly evaluations, Duan says, which ensures that dealers are up to the company’s ethical standards’






A13:

Does the company make clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance?

Score:

2

Comments:

Based on public information, there is evidence that company employees working with third-parties must require parties to agree to comply with compliance policies. There is also sufficient evidence of contractual rights for disciplinary action to be taken when needed, for example when offering gratuities to Government officials.

References:

Public:

Terms and Conditions of Purchase:

‘Integrity Guide. Seller represents and warrants that it shall act in a manner consistent with Purchaser’s Integrity Guide for Suppliers, Contractors and Consultants’

http://www.geaviation.com/documents/supprelations/C64_20140325.pdf

Integrity Guide for Suppliers, Contractors and Consultants:

‘GE’s commitment to total, unyielding Integrity is set forth in GE’s compliance handbook, The Spirit & The Letter. The policies set forth in The Spirit & The Letter govern the conduct of all GE employees and are supplemented by compliance procedures and guidelines adopted by GE business components. All GE employees must not only comply with the “letter” of the Company’s compliance policies, but also with their “spirit.”. The “spirit” of GE’s Integrity commitment is set forth in the GE Code of Conduct, which each GE employee has made a personal commitment to follow:

• Obey the applicable laws and regulations governing our business conduct worldwide.

• Be honest, fair and trustworthy in all of your GE activities and relationships.

• Avoid all conflicts of interest between work and personal affairs.

• Foster an atmosphere in which fair employment practices extend to every member of

http://www.geaviation.com/documents/supprelations/C64_20140325.pdf


the diverse GE community.

• Strive to create a safe workplace and to protect the environment.

• Through leadership at all levels, sustain a culture where ethical conduct is recognized, valued and exemplified by all employees.

No matter how high the stakes, no matter how great the challenge, GE will do business only by lawful and ethical means. When working with customers and Suppliers in every aspect of our business, we will not compromise our commitment to integrity

………

Improper Payments

• Always adhere to the highest standards of honesty and integrity in all contacts on behalf of GE. Never offer bribes, kickbacks, illegal political contributions or other improper payments to any customer, government official or third party. Follow the laws of the United States and other countries relating to these matters.

• Do not give gifts or provide any entertainment to a customer or supplier without prior approval of GE management. Make sure all business entertainment and gifts are lawful and disclosed to the other party’s employer.

• Employ only reputable people and firms as GE representatives and understand and obey any requirements governing the use of third party representatives.

Conflicts of Interest


• Report all personal or family relationships, including those of significant others, with current or prospective suppliers you select,

manage or evaluate.

• Do not use GE equipment, information or other property (including office equipment, e-mail and computer applications) to conduct personal or non-GE business without prior permission from the appropriate GE manager. …………

Responsibilities of GE Suppliers

As stated above, GE requires and expects each GE Supplier to comply with all applicable laws and regulations. Unacceptable practices by a GE Supplier include:

Code of Conduct. Failure to maintain and enforce GE policies requiring adherence to lawful business practices, including a prohibition against bribery of government officials.

• Business Practices and Dealings with GE. Offering or providing, directly or indirectly, anything of value, including cash, bribes, gifts, entertainment or kickbacks, to any GE employee, representative or customer or to any government official in connection with any GE procurement, transaction or business dealing. Such prohibition includes the offering or providing of any consulting, employment or similar position by a Supplier to any GE employee (or their family member or significant other) involved with a GE procurement. GE also prohibits a GE Supplier from offering or providing GE employees,


representatives or customers or any government officials with any gifts or entertainment, other than those of nominal value to commemorate or recognize a particular GE Supplier business transaction or activity. In particular, a GE Supplier shall not offer, invite or permit GE employees and representatives to participate in any Supplier or Supplier-sponsored contest, game or promotion.

• Business Entertainment of GE Employees and Representatives. Failure to respect and comply with the business entertainment (including travel and living) policies established by GE and governing GE employees and representatives. A GE Supplier is expected to understand the business entertainment policies of the applicable GE business component or affiliate before offering or providing any GE employee or representative any business entertainment. Business entertainment should never be offered to a GE employee or representative by a Supplier under circumstances that create the appearance of an impropriety.

• Use Subcontractors or Third Parties to Evade Requirements. The use of subcontractors or other third parties to evade legal requirements applicable to the Supplier and any of the standards set forth in this Guide.

The foregoing standards are subject to modification at the discretion of GE. Please contact the GE manager you work with or any GE Compliance Resource if you have any questions about these standards and/or their application to particular circumstances. Each GE Supplier is responsible for ensuring that its employees and representatives understand and comply with these standards. GE will only do business with those Suppliers that comply with applicable legal and regulatory requirements and reserves the right, based on its assessment of information available to GE, to terminate, without liability to GE, any pending purchase order or contract with any Supplier that does not comply with the standards set forth in this section of the Guide’


Improper Payments :

‘Extensive controls over third-party intermediaries such as commercial agents and representatives, distributors and service providers, including thorough due diligence, careful screening and training on GE policies.’


Spirit of the Letter (2014), p.2:









(p.8):‘GE only does business with suppliers that comply with all applicable legal requirements and GE guidelines relating to labor, employment and environment, health and safety and that treat workers and others fairly and with respect.’

Company Website, Supplier Expectations:

‘GE suppliers must maintain and enforce a Company policy requiring adherence to ethical

business practices, including a prohibition on bribery of government officials’

Integrity Guide for Suppliers, Contractors and Consultants, rev 2009, (from the General Electric Aviation website) p2 :

‘All GE employees are obligated to comply with the requirements —the “letter”—of GE’s compliance policies set forth in The Spirit & The Letter. These policies implement the GE Code of Conduct and are supplemented by compliance procedures and guidelines adopted by GE business components and/or affiliates.’

http://www.gesustainability.com/building-things-that-matter/supply-chain/supplier-expectations/

Available in numerous languages here:

http://www.gesupplier.com/html/SuppliersIntegrityGuide.htm

GE Customs-Trade Partnership Against Terrorism (C-TPAT) Supply Chain Security Guidelines for International Suppliers or Shippers, p. 3:

‘A security training program must be in place to educate and build employee awareness of proper security procedures as outlined in these security guidelines including training on the threat posed by terrorists and contraband smugglers at each point in the supply chain, training on ethical conduct, avoidance of corruption, fraud and exploitation. Additional training on effective supply chain security controls should be given to employees in the shipping and receiving areas.’

GEA Supplier Letter Gratuities

‘This letter relates to your obligations under your GE Aviation Purchase Agreements and/or Purchase Orders and compliance with GEA Standard Terms and Conditions of Purchase, Remark C64, and its Appendix I incorporated in the Agreement(s) or Order(s). In particular, we call your attention to Remark C64 Article 25 (k), Gratuities, as well as FAR Clause 52.203-3, Gratuities, incorporated by reference in Appendix I. These clauses prohibit GEA suppliers from offering gratuities to Government or GEA employees, and prohibit GEA employees from soliciting and accepting such offers. Integrity





is the cornerstone of GEA’s procurement system, and both clauses appropriately allow for the termination of agreements where violations occur.’

Supplier Integrity Guide (in multiple languages):


Doing Business with Aviation:

http://www.geaviation.com/company/doing-business-with-aviation/

Supply Chain Webcenter:

https://www.supplychainwebcenter.com/loginform/scwc/basic.fcc?TYPE=33554433&REALMOID=06-0004d3e8-dd86-126f-a924-834265eb0008&GUID=&SMAUTHREASON=0&METHOD=GET&SMAGENTNAME=-SM-Fmen%2fMIUlak79SimnymVpQh%2fmC6Dt%2fbP6y8umTgETZxLYO7Ok6IatO2An9bQOtId&TARGET=-SM-HTTP%3a%2f%2fwww%2esupplychainwebcenter%2ecom%2fscwc_home%2findex%2ejsp


http://www.geaviation.com/company/doing-business-with-aviation/








A13(a):

Does the company explicitly address the corruption risks associated with offset contracting?

Score:

0

Comments:

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

References:

Public:

Member of the Global Offset and Countertrade Association:

http://www.globaloffset.org/regularmembers.php



A13(b):

Does the company conduct due diligence that minimises corruption risk when selecting its offset partners and offset brokers?

Score:

0

Comments:

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.

References:

Public:

Member of the Global Offset and Countertrade Association:




A15:

Does the company have an anti-corruption policy that prohibits corruption in its various forms?

Score:

2

Comments:

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits the giving and receiving of bribes, and is explicit on the various forms corruption can take.

References:

Public:

Spirit & The Letter (2014), p.7:

‘Do not permit or engage in bribery or corruption of any kind.’

‘Our Policy:

GE prohibits bribery in all business dealings, in every country around the world, with both governments and theprivate sector.

GE prohibits even small facilitation payments to expedite routine administrative actions, except in extraordinary circumstances and with the prior approval of a GE compliance or business general counsel, or where an employee’s safety or security is at stake. our goal is to eliminate all facilitation payments.

We maintain strong controls aimed at preventing and detecting bribery. This includes a rigorous process for appointing and managing third parties acting on GE’s behalf in business dealings.

We maintain accurate books, records, and accounts that correctly reflect the true nature of all transactions your role

• Never offer, promise, make, or authorize a payment or the giving of anything of value to anyone in order to obtain an improper business advantage.

• Remember that providing gifts, entertainment or anything else of value to government employees is highly regulated and often prohibited. do not provide such gifts and


entertainment unless you have received prior GE counsel approval.

• Follow Corporate and business guidelines regarding gifts and entertainment and other business courtesies.

• Never contribute Company funds or other GE assets for political purposes without obtaining prior approval from Corporate Government Affairs, a Company officer

or GE counsel, as applicable.

• Follow your business due diligence procedures and require that any third party representing GE be carefully selected and comply with this policy.

• Treat with extreme caution a demand from a third party to receive its commission payment prior to winning a deal/contract.

• Be wary of any suggestion to direct GE business through a specific representative or partner due to a “special relationship.”

• Be suspicious of any request to make a payment to a person who is not related to the transaction being discussed — or a request that payments be made in another country.

• watch out for commissions that seem too large in relation to the services provided.’





A16:

Is the anti-corruption policy explicitly one of zero tolerance?

Score:

2

Comments:

Based on public information, there is evidence of a zero-tolerance anti-corruption policy, with the integrity policy stressing bribery or corruption of any kind is not permitted.

References:

Public:

The Spirit and the Letter (2014):

‘GE’s commitment to perform with integrity is instilled in every employee as a nonnegotiable expectation of behavior.’


Spirit & The Letter (2014), p.7 : ‘Do not permit or engage in bribery or corruption of any kind.’






A17:

Is the company's anti-corruption policy easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company?

Score:

2

Comments:

Based on public information, there is evidence that the company has an anti-corruption policy easily accessible to the Board and employees. The Integrity policy and the Simple Reference Guide are available in 29 different languages and can be accessed on the public website and intranet website. GE employees working with third parties must provide information on the policy.

References:

Public:

The Spirit and the Letter (2014):

‘In 2013, a new version of The Spirit & The Letter was made available to employees, including a simplified Code of Conduct, ethical decision-making guidance and plain-language “Rules to Remember.” We also updated the online integrity training for new employees to make it simpler, shorter, more global and more interactive. We have redesigned these resources with a goal of making our compliance communications and training more modern and effective, thereby helping employees understand why integrity matters and how to “do the right thing” in their jobs.’

‘GE employees can access The Spirit & The Letter in an interactive eBook format on an employee intranet website, together with additional resources including a database of frequently asked questions, compliance stories, videos and links to online training.’

‘A summary of the most critical elements of The Spirit & The Letter is available as a downloadable two-page Simple Reference Guide, including a simplified Code of Conduct and key “Rules to Remember.”’

The Spirit and the Letter and the Simple Reference Guide are available in 29 different languages



The Spirit & The Letter (2014), p.2:










A17(a):

Is the company’s anti-corruption policy easily understandable and clear to Board members, employees and third parties?

Score:

2

Comments:

Based on public information, there is evidence that the company’s anti-corruption policy is understandable and clear to Board members, employees and third parties. While the integrity policy could be better structured with clear definitions and examples, the company provides a simplified form of the document, as well as an interactive eBook format of the integrity policy on the company’s intranet website.

References:

Public:

The Spirit and the Letter:



‘A summary of the most critical elements of The Spirit & The Letter is available as a downloadable two-page Simple Reference Guide, including a simplified Code of Conduct and key “Rules to Remember.”’


The Spirit & The Letter, (201), p.7:

‘Well organised section on key forms of corruption, with some definitions provided.



However, few examples’





A18:

Does the anti-corruption policy explicitly apply to all employees and

members of the Board?

Score:

2

Comments:

Based on public information, there is evidence that the anti-corruption policy explicitly applies to all employees and members of the Board. It is clearly stated that anyone who works for the company, including directors, must follow its integrity policy.

References:

Public:

Governance Principles(2014), p.5:

‘The board expects GE directors, as well as officers and employees, to act ethically at all times and to acknowledge their adherence to the policies comprising GE’s code of conduct set forth in the Company’s integrity manual, “The Spirit & The Letter”.’

‘The board will not permit any waiver of any ethics policy for any director or executive officer. If an actual or potential conflict of interest arises for a director, the director shall promptly inform the CEO and the lead director. The governance and public affairs committee shall resolve any such conflicts. If a significant conflict exists and cannot be resolved, the director should resign. All directors will recuse themselves from any discussion or decision affecting their personal, business or professional interests. The governance and public affairs committee shall resolve any conflict of interest question involving the CEO, a vice chairman or a senior vice president, and the CEO shall resolve any conflict of interest issue involving any other officer of the Company.’

http://www.ge.com/investor-relations/governance/principles

Audit Committee Key Principles (2014), p.3:

‘GE’s integrity manual applies to all of the Company’s directors, officers and employees, including the CEO and senior financial officers. Annual acknowledgement of the integrity manual is required of all salaried employees’

http://www.ge.com/investor-relations/governance/principles


http://www.ge.com/sites/default/files/AC_key_practices.pdf


‘The Spirit & The Letter must be followed by anyone who works for or represents GE. This includes GE directors, officers and employers’‘


http://www.ge.com/sites/default/files/AC_key_practices.pdf



A20:

Does the company have a policy on potential conflicts of interest, and does it apply to both employees and board members?

Score:

2

Comments:

Based on public information, there is evidence that the company has a policy on potential conflicts of interest providing a definition and guidance.

References:

Public:


‘OUR POLICY:

You have a duty to ensure that nothing interferes with your ability to make all business decisions in the best interest of GE. This means that nothing you do should interfere, or appear to interfere, with your responsibility for objective and unbiased decision-making on behalf of the Company.

No activity at work or home should harm GE’s reputation or good name.

You have a duty to disclose if your personal or financial activities may interfere or have the potential of interfering with your allegiance toward the Company.

Misusing GE resources or influence is prohibited. Even when nothing wrong is intended, the perception of a conflict of interest may have negative effects.’

‘YOUR ROLE :

• Obtain prior approval from your manager, HR and Company legal counsel before hiring, promoting or directly supervising a family member or close friend.

• Obtain prior approval before accepting officer or director positions with an outside business or not-forprofit organization. This excludes religious or school (non- University) affiliations.

• Disclose financial interests you may have in a company where you could personally affect GE’s business with that company.


• Do not accept gifts other than those of nominal value from suppliers, customers or competitors.

• Do not accept personal discounts or other benefits from suppliers or customers if they are not available to the general public or your GE peers.

• While incidental use may be acceptable, do not use GE resources, intellectual property, time or facilities for personal gain. Avoid any activity which creates the potential perception of a conflict between your personal interests and the interests of GE.’

‘What you should know :

A conflict of interest is not necessarily a violation of GE policy; failing to promptly disclose a conflict is always a violation. Disclosing potential conflicts of interest allows your management team to mitigate risks which may influence your business decisions. You can access the COI disclosure tool at integrity.ge.com.’


Integrity guide for suppliers, contractors and consultants, (September 2009), p.3:

‘Conflicts of Interest


• Report all personal or family relationships, including those of significant others, with current or prospective suppliers you select, manage or evaluate.

• Do not use GE equipment, information or other property (including office equipment, e-mail and computer applications) to conduct personal or non-GE business without prior permission from the appropriate GE manager.’


Company Website, Conflicts of Interest:

‘WHAT AN EMPLOYEE IS URGED TO KNOW

On the job or in an employee’s free time, nothing an employee does should conflict with their responsibilities to GE. No activity at work or at home should hurt GE’s reputation or good name. Misusing GE resources or influence is also prohibited. Even when nothing wrong is intended, the appearance of a conflict can have negative effects. It is crucial to consider how an employee’s actions might appear, and to avoid the perception of a conflict of interest.

WHAT AN EMPLOYEE IS URGED TO DO

DISCLOSE (in writing to an employee’s manager and to company legal counsel) all outside activities, financial interests or relationships that may either present a conflict or the appearance of one.

USE GOOD JUDGMENT in all personal and business dealings outside GE.

AVOID ACTIONS OR RELATIONSHIPS that may cause potential conflicts or create the





appearance of a conflict with an employee’s job or GE’s interests.

DO NOT MISUSE or use for personal gain GE resources, intellectual property, time or facilities — this includes office equipment, e-mail and computer applications.

DO NOT TAKE personally any opportunities that GE could have an interest in that are discovered through the use of GE position, information or property.

GET APPROVALS before accepting officer or director positions with an outside business while employed by GE.

GET YOUR MANAGER’S APPROVAL when accepting not-for-profit board positions, particularly if the organization has a GE relationship or might expect GE financial or other support.

WHAT AN EMPLOYEE IS URGED TO WATCH OUT FOR

FINANCIAL INTERESTS in a company where an employee could personally affect GE’s business with that company (for example, a customer, supplier or investment)

PART-TIME JOBS which are performed using GE hours or GE equipment or materials

GIFTS of other than nominal value from suppliers, customers or competitors, particularly if the recipient is making decisions (on GE’s behalf) that involve them

PERSONAL DISCOUNTS or other benefits from suppliers, service providers or customers that the public or GE peers do not receive

DIRECTING BUSINESS to suppliers when an employee knows they are owned or managed by your family members or close friend

MISUSING GE RESOURCES, position or influence to promote or assist an outside activity

HIRING, PROMOTING OR DIRECTLY SUPERVISING a family member or close friend

PERSONAL RELATIONSHIPS that may conflict with an employee’s GE responsibilities or compromise company interests’

http://www.ge.com/en/citizenship/govcomp-jun20/spirit/conflict.htm

http://www.ge.com/en/citizenship/govcomp-jun20/spirit/conflict.htm


A21:

Does the company have a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery?

Score:

1

Comments:

Based on public information, there is evidence of a statement on the giving and receipt of gifts. TI notes that it is prohibited to give gifts without proper GE counsel approval. However, the policy is less clear about the receipt of gifts by GE employees. For example, employees appear to be allowed to accept gifts of ‘nominal value’; however, it is not made clear what the company means by this. The company therefore scores 1.

References:

Public:


‘Remember that providing gifts, entertainment or anything else of value to government employees is highly regulated and often prohibited. Do not provide such gifts and entertainment unless you have received prior GE counsel approval’

‘Follow Corporate and business guidelines regarding gifts and entertainment and other business courtesies.’

(p.8): ‘Avoid potential conflicts of interest when you select a supplier, and never accept improper gifts or other items of value.’

(p.19): ‘Do not accept gifts other than those of nominal value from suppliers, customers or competitors.’


Integrity guide for suppliers, contractors and consultants, (September 2009), p.2 :

‘Do not give gifts or provide any entertainment to a customer or supplier without prior approval of GE management. Make sure all business entertainment and gifts are lawful and disclosed to the other party’s employer.’



(p.3): ‘Offering or providing, directly or indirectly, anything of value, including cash, bribes, gifts, entertainment or kickbacks, to any GE employee, representative or customer or to any government official in connection with any GE procurement, transaction or business dealing. Such prohibition includes the offering or providing of any consulting, employment or similar position by a Supplier to any GE employee (or their family member or significant other) involved with a GE procurement. GE also prohibits a GE Supplier from offering or providing GE employees, representatives or customers or any government officials with any gifts or entertainment, other than those of nominal value to commemorate or recognize a particular GE Supplier business transaction or activity’


Gift and Gratuities Policy for Suppliers:

http://site.ge-energy.com/about/suppliers/en/policy_reminder.htm





A22:

Does the company’s anti-corruption policy include a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery?

Score:

1

Comments:

Based on public information, there is evidence of a statement on the giving of hospitality (entertainment). TI notes that it is prohibited to give hospitality without proper GE counsel approval. However, the policy does not clearly address the receipt of hospitality by GE employees. The company therefore scores 1.

References:

Public:


‘Remember that providing gifts, entertainment or anything else of value to government employees is highly regulated and often prohibited. Do not provide such gifts and entertainment unless you have received prior GE counsel approval’

‘Follow Corporate and business guidelines regarding gifts and entertainment and other business courtesies.’

(p.8): ‘Avoid potential conflicts of interest when you select a supplier, and never accept improper gifts or other items of value.’

(p.19): ‘Do not accept gifts other than those of nominal value from suppliers, customers or competitors.’


Integrity guide for suppliers, contractors and consultants, (September 2009), p.2 :

‘Do not give gifts or provide any entertainment to a customer or supplier without prior approval of GE management. Make sure all business entertainment and gifts are lawful and disclosed to the other party’s employer.’

p3:



‘Offering or providing, directly or indirectly, anything of value, including cash, bribes, gifts, entertainment or kickbacks, to any GE employee, representative or customer or to any government official in connection with any GE procurement, transaction or business dealing. Such prohibition includes the offering or providing of any consulting, employment or similar position by a Supplier to any GE employee (or their family member or significant other) involved with a GE procurement. GE also prohibits a GE Supplier from offering or providing GE employees, representatives or customers or any government officials with any gifts or entertainment, other than those of nominal value to commemorate or recognize a particular GE Supplier business transaction or activity’


Gift and Gratuities Policy for Suppliers:






A23:

Does the company have a policy that explicitly prohibits facilitation payments?

Score:

1

Comments:

Based on public information, there is evidence that the company has a policy that explicitly prohibits facilitation payments. However, the company provides minimal supplementary information on how the policy is to be implemented in practice. The company therefore scores 1.

References:

Public:

The Spirit & The Law (2014), p.7:

‘GE prohibits even small facilitation payments to expedite routine administrative actions, except in extraordinary circumstances and with the prior approval of a GE compliance or business general counsel, or where an employee’s safety or security is at stake. Our goal is to eliminate all facilitation payments.’




A24:

Does the company prohibit political contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent? Does the company record and publicly disclose all political contributions?

Score:

2

Comments:

Based on public information, there is evidence that the company’s political contributions must be authorised by the vice president for Government Affairs & Policy, with the compliance counsel ensuring all contributions comply with laws and regulations. The Corporate Oversight Board meets on a regular basis to review this expenditure and the controls in place. Recipients of General Electric corporate political contributions for the last 6 years are listed on the website.

References:

Public:


‘The committees responsibilities include: to consider the manner of the Comapny’s policies and guidelines regarding political contributions and lobbying activities ; review the policies and practices related to political and campaign contributions ; issue an annual report on the Company’s political spending’



‘Never contribute Company funds or other GE assets for political purposes without obtaining prior approval from Corporate Government Affairs, a Company officer or GE counsel, as applicable.’


Political Activites:

http://www.gesustainability.com/enabling-progress/political-activities/



http://www.gesustainability.com/enabling-progress/political-activities/


‘GE participates in the political process through contributions from the GE Political Action Committee (GEPAC) and through company contributions, where legal and appropriate under state and local law.’

‘GE and GEPAC make bipartisan contributions to political candidates and initiatives that support strong public policy, promote sustainable growth and robust markets, and, at the same time, promote innovation and the interests of the industries in which GE operates.’

‘As part of its oversight role in public policy and corporate social responsibility, the Corporate Governance and Public Policy Committee of the Board of Directors reviews annually the Company’s policies and practices related to political contributions, contributions to campaigns, and contributions to trade associations and other tax-exempt and similar organizations that may engage in political activity.’

‘As described in the Company’s Code of Conduct, The Spirit & The Letter, any contribution of Company funds or other assets for political purposes in the U.S. must be approved in advance by the GE vice president for Government Affairs & Policy. GE’s compliance counsel works to ensure that contributions comply with the spirit and letter of applicable laws and regulations. Political contributions made with Company funds outside the U.S. must be approved by the GE vice president and senior counsel, Global Government Affairs & Policy. GE’s foreign political contributions are currently limited to Canada.’

‘The Corporate Oversight Board meets on a regular basis to review GE’s expenditures and ensure that controls are in place for compliance with its political spending policies and that the expenditures and activities advance GE’s objectives. GE’s political contributions are overseen by a multifunctional team comprising senior executives and representatives from Government Relations, Legal, Finance and other relevant functions. The relevant state government affairs regional manager, corporate finance manager, government compliance counsel and the vice president for Government Affairs & Policy review and approve all corporate political contributions. Contributions over $5,000 may not be made without the approval of the Corporate Oversight Board.’

‘In 2013, GE contributed $459,650 to political candidates; political organizations such as governors’ associations and state political parties; gubernatorial inaugural events; and ballot initiatives. The recipients and amounts of those contributions are detailed in our political contributions report.’

‘GE has a long-standing practice against using corporate resources for the direct funding of independent expenditures expressly advocating for or against candidates in elections for public office. In 2010, the Public Responsibilities Committee adopted this practice as a formal policy.’

‘GEPAC is an independent, nonpartisan, voluntary fund supported by GE employees who choose to participate in the political process by pooling their resources to support the candidacy of candidates who share the values and goals of the Company and its employees.’

‘In 2013, GEPAC raised just over $1.8 million from more than 4,400 employees and contributed $1,828,000 to candidates and committees in federal elections and $319,250 to candidates and committees in state elections in the United States. The Federal Election Commission (FEC) regulates GEPAC’s activities. Reports detailing its activities are available


on the FEC website, www.fec.gov.’

‘In February 2011, GE established a PAC supported exclusively by GE employees who are subject to the U.S. Securities and Exchange Commission (SEC), The Municipal Securities Rulemaking Board (MSRB) and/or other rules that affect political contributions by certain financial professionals. In 2013, this PAC collected contributions from approximately160 employees and made total contributions of $114,500. The GEPAC Board governs and oversees this “federal only” PAC and works with counsel to ensure compliance with the spirit and letter of all applicable laws and regulations.’

On the website is the General Electric Corporate Political Contributions For 2013, as well as an archive of previous years data.

http://www.fec.gov/


A25:

Does the company have a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, and discloses the issues on which the company lobbies?

Score:

2

Comments:

Based on public information, there is evidence that the company has a policy that clearly regulates lobbying activity and discloses the issues on which it lobbies.

References:

Public:


‘The committees responsibilities include : to consider the manner of the Comapny’s policies and guidelines regarding political contributions and lobbying activities ; review the policies and practices related to political and campaign contributions ; issue an annual report on the Company’s political spending’


‘The company spent more than $39 million on lobbying efforts last year alone, making it the third-biggest spender in the city, according to the Center for Responsive Politics.’

http://fortune.com/2011/07/06/jeff-immelt-ge-ceo-or-obama-advisor/

Company Website, Grassroots and Lobbying:

‘All advocacy done by GE employees on pending U.S. legislation is included in our Lobbying Disclosure Act filings.’

‘GE conducts lobbying activities in compliance with applicable laws and regulations governing such activities. In the U.S., certain communications with federal, state and/or local government officials or government employees may be reportable as lobbying communications included in GE’s Lobbying Disclosure Act (LDA) reports and/or state or local lobbying disclosure reports. Certain countries outside the U.S. may also require disclosure of


http://fortune.com/2011/07/06/jeff-immelt-ge-ceo-or-obama-advisor/


lobbying activities. Before engaging in lobbying activities, employees are asked to contact the Vice President of Government Affairs & Policy; the Vice President and Senior Counsel, Global Government Affairs & Policy; or their designee. GE regularly trains employees on what types of activities and communications constitute reportable lobbying activities. Prior approval from the Vice President, Government Affairs & Policy or the Vice President and Senior Counsel, Global Government Affairs & Policy is required before GE may retain an outside entity to engage in lobbying activities.’

‘In limited circumstances, when an issue is of particular strategic importance, the Company may use advertisements or other public communications to urge support for specific legislation or public policy. These expenses are also included in our Lobby Disclosure Act filings.’

Lobbying reports are provided for each financial quarter:

http://www.gesustainability.com/enabling-progress/grassroots-lobbying/

http://www.gesustainability.com/enabling-progress/grassroots-lobbying/


A25(a):

Does the company prohibit charitable contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company regulates charitable contributions to prevent undue influence or other corrupt intent. The difference between corporate charitable contributions and GE Foundation contributions is unclear. While the recipients for the two forms of contribitions for the last year is on the website, the lack of evidence regarding regulations prevents the company from scoring higher.

References:

Public:

TI notes:

Governance and Public Affairs Committee Charter (2014) p. 2:

The committees responsibilities include reviewing the Company’s support of charitable, educational and business organisations


Company Website, Philanthropic Contributions:

On the website is the data for 2013 GE Foundation Contributions above $10,000 and 2013 Corporate Contributions above $10,000.

‘In 2013, the entire GE family—including businesses, employees, retirees and the GE Foundation—contributed more than $214 million to community and educational programs, $125 million of which came from the GE Foundation.’

‘The GE Foundation, the philanthropic organization of GE, is committed to building a world that works better.’

GE Foundation website www.gefoundation.com


http://www.gefoundation.com/


http://www.gesustainability.com/enabling-progress/philanthropic-contributions/

http://www.gesustainability.com/enabling-progress/philanthropic-contributions/


A26:

Does the company provide written guidance to help Board members and

employees understand and implement the firm’s ethics and anti-corruption

agenda?

Score:

2

Comments:

Based on public information, there is evidence that employees have access to a simplified Code of Conduct, decision-making guide and rules to remember document. Evidence also suggests that employees have access to an interactive eBook format of the integrity policy, along with additional resources including a database of frequently asked questions, compliance stories, videos and links to online training.

References:

Public:




‘In 2014, GE will enhance the new compliance portal through the addition of new, interactive videos on key compliance risks and will provide access to newly developed interactive training.’

‘A summary of the most critical elements of The Spirit & The 55ette ris available as a downloadable two-page Simple Reference Guide, including a simplified Code of Conduct


and key “Rules to Remember.”’


The Spirit and the Letter Booklet (2014), p.2:

‘About This guide

This guide provides an introductory summary to these policies — not the full policies themselves. Go to integrity.ge.com for detailed policy information and resources to help you.’

(p.3): ‘The Cost of Noncompliance

Employees and leaders who do not fulfill their integrity responsibilities face disciplinary action up to and including the termination of their employment. The following examples of conduct can result in disciplinary action. Examples >>

Violating law or ge policy or requesting that others do the same.

Retaliating against another employee for reporting an integrity concern.

Failing to promptly report a known or suspected violation of GE’s integrity policies.

Failing to fully and honestly cooperate in GE investigations of possible policy violations.

Failing as a leader to diligently ensure compliance with GE’s integrity principles, policies and law.’

(p.7): ‘What You Should Know

Bribery means giving, offering or promising anything of value to gain an improper business advantage.

Facilitation payments are small customary amounts paid to government employees to expedite routine clerical or administrative actions such as issuing permits.’

(p.19): ‘What You Should Know

A conflict of interest is not necessarily a violation of GE policy; failing to promptly disclose a conflict is always a violation. Disclosing potential conflicts of interest allows your management team to mitigate risks which may influence your business decisions. You can access the COI disclosure tool at integrity.ge.com.’


The Spirit and the Letter, Simple Reference (2014):

‘Easy rules to remember

Our Guide To “Doing Things Right” GE’s integrity policies explain our commitment and your role. See more at integrity.ge.com and learn the details of any policy that is relevant to your job:





IMPROPER PAYMENTS Don’t bribe; don’t permit bribes; watch third parties.

INTELLECTUAL PROPERTY Identify and protect GE innovations; don’t take or use IP without authorization.

INTERNATIONAL TRADE COMPLIANCE Never let GE goods, technology or services go to prohibited persons or places; know the risks and follow the rules for cross-border transfers.

WORKING WITH GOVERNMENTS Never take shortcuts when dealing with government; never deviate from the contract.

COMPETITION LAW Never agree with competitors to fix prices, rig bids, or allocate customers, projects or territories.

FAIR EMPLOYMENT PRACTICES Treat all employees fairly; respect the right to associate; base decisions on merit; don’t harass or discriminate.

CONTROLLERSHIP Documents, communications and accounting must be 100% accurate and honest.

CYBER SECURITY & PRIVACY Respect privacy rights and protect against cyber risks to GE information, networks and products.

ENVIRONMENT, HEALTH AND SAFETY (EHS) Follow EHS procedures and be alert to EHS hazards in your workplace.’

http://www.gesustainability.com/wp-content/uploads/2014/05/GE_SnL_Bi-fold_8.5x11_CMYK_v19b1.pdf




A27:

Does the company have a training programme that explicitly covers anti-corruption?

Score:

1

Comments:

Based on public information, there is evidence that the company has an online training programme as part of its integrity systems but it is not clear if there is a specific anti-corruption training module. The company therefore scores 1.

References:

Public:


‘We also updated the online integrity training for new employees to make it simpler, shorter, more global and more interactive. We have redesigned these resources with a goal of making our compliance communications and training more modern and effective, thereby helping employees understand why integrity matters and how to “do the right thing” in their jobs.’






A28:

Is anti-corruption training provided in all countries where the company operates or has company sites?

Score:

1

Comments:

Based on public information, there is evidence that the company provides online integrity training. However, it is not explicitly clear that this is available in all countries where the company operates. The company therefore scores 1.

References:

Public:


‘We also updated the online integrity training for new employees to make it simpler, shorter, more global and more interactive. We have redesigned these resources with a goal of making our compliance communications and training more modern and effective, thereby helping employees understand why integrity matters and how to “do the right thing” in their jobs.’




A29:

Does the company provide targeted anti-corruption training to members of the Board?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

References:

Public:

NA


A30:

Does the company provide tailored ethics and anti-corruption training for employees in sensitive positions?

Score:

0

Comments:

Based on public information, there is limited evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions. TI notes that ‘employees in shipping and receiving areas’ are provided with ‘additional training on effective supply chain security controls’ but it is not clear that this includes specific ethics and anti-corruption training.

References:

Public:

TI notes:

GE Customs-Trade Partnership Against Terrorism (C-TPAT) Supply Chain Security Guidelines for International Suppliers or Shippers, unknown date, p. 3:

‘A security training program must be in place to educate and build employee awareness of proper security procedures as outlined in these security guidelines including training on the threat posed by terrorists and contraband smugglers at each point in the supply chain, training on ethical conduct, avoidance of corruption, fraud and exploitation. Additional training on effective supply chain security controls should be given to employees in the shipping and receiving areas.’

http://www.geaviation.com/company/doing-business-with-aviation/docs_supplier_security/C-TPAT_guidelines_intl_suppliers_shippers.pdf




A31:

Does the company have a clear and formal process by which employees declare conflicts of interest?

Score:

0

Comments:

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 Spirit and The Letter only provides general guidelines for employees to follow. TI is unable to access the Conflict of Interest disclosure tool to assess this.

References:

Public:

TI notes:


‘You have a duty to ensure that nothing interferes with your ability to make all business decisions in the best interest of GE. This means that nothing you do should interfere, or appear to interfere, with your responsibility for objective and unbiased decision-making on behalf of the Company.

No activity at work or home should harm GE’s reputation or good name.

You have a duty to disclose if your personal or financial activities may interfere or have the potential of interfering with your allegiance toward the Company.

Misusing GE resources or influence is prohibited.’

‘• Obtain prior approval from your manager, HR and Company legal counsel before hiring, promoting or directly supervising a family member or close friend.

• Obtain prior approval before accepting officer or director positions with an outside business or not-forprofit organization. This excludes religious or school (non- University) affiliations.

• Disclose financial interests you may have in a company where you could personally affect GE’s business with that company.

• Do not accept gifts other than those of nominal value from suppliers, customers or


competitors.

• Do not accept personal discounts or other benefits from suppliers or customers if they are not available to the general public or your GE peers.

• While incidental use may be acceptable, do not use GE resources, intellectual property, time or facilities for personal gain. Avoid any activity which creates the potential perception of a conflict between your personal interests and the interests of GE.’

‘A conflict of interest is not necessarily a violation of GE policy ; failing to promptly disclose a conflict is always a violation. Disclosing potential conflicts of interest allows your management team to mitigate risks which may influence your business decisions. You can access the COI disclosure tool at integrity.ge.com.’




A32:

Is the company explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities?

Score:

2

Comments:

Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities. The Spirit & The Letter states that employees and leaders who do not follow their integrity responsibilities ‘face’ disciplinary action.

References:

Public:

Governance Principles(2014), p.5:

‘The board expects GE directors, as well as officers and employees, to act ethically at all times and to acknowledge their adherence to the policies comprising GE’s code of conduct set forth in the Company’s integrity manual, “The Spirit & The Letter”.’

Audit Committee Key Principles (2014), p.3:

‘GE’s integrity manual applies to all of the Company’s directors, officers and employees, including the CEO and senior financial officers. Annual acknowledgement of the integrity manual is required of all salaried employees’

Company Website, A Strong Culture of Integrity:

‘Prompt corrective action and discipline are elements of a strong integrity culture at GE. Confirmed violations of Company policies and procedures result in corrective actions such as training, strengthening routines, and simplifying or updating processes. Although many policy nonconformances result from unintended mistakes, disciplinary actions are taken in appropriate cases involving intentional wrongdoing.’

http://www.gesustainability.com/how-ge-works/integrity-compliance/a-strong-culture-of-



integrity/


‘The Spirit & The Letter must be followed by anyone who works for or represents GE. This includes GE directors, officers and employers’‘

p.3:

‘employees and leaders who do not fulfill their integrity responsibilities face disciplinary action up to and including the termination of their employment.’



A33:

Does the company have multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity?

Score:

1

Comments:

Based on public information, there is evidence that employees and third parties have access to multiple channels to report concerns or instances of suspected corrupt activity. Managers are trained to deal with ethical reports, while the contact details for the GE Corporate Ombudsman and GE Board of Directors are located in the Integrity Policy. A global network of ombuspersons allows all employees to report concerns or instances of corrupt activity, with the option of anonymity. However, TI found no readily available evidence that employees have access to independent channels. The company therefore scores 1.

References:

Public:


‘GE’s extensive ombudsperson process serves as a mechanism for individuals to ask questions and report integrity concerns without fear of retaliation. With a global network of approximately 600 ombudspersons, coverage is provided for every business and country in which GE operates. Employees know their local business and regional ombudsperson through frequent communications, articles and various Company intranet sites. Ombudspersons are introduced at all-employee meetings within the businesses and regions, including integrity events and trainings.’

‘know and use the channels available to them to report concerns, including managers, compliance officers and GE’s comprehensive network of approximately 600 ombudspersons’

‘trust that the process is confidential’





Spirit & The Letter (2014), p.5 :

‘GE offers several channels for raising concerns. You can choose to speak to someone about a potential integrity issue or put it in writing. Generally, your supervisor or manager will be in the best position to resolve an integrity concern, but other resources include:

• Your human resources leader.

• Your compliance leader or auditor.

• Company legal counsel.

• Next level of management.

• Your business or region GE ombudsperson or integrity helpline.

• A GE Corporate ombudsperson.

• The GE Board of Directors.’

Contact details provided on the same page for the GE Corporate Ombudsman and GEO Board of Directors

Company Website, Ombudsperson Process:

‘During 2012, 2,752 integrity concerns were reported through the ombudsperson process (38% anonymously) covering a variety of issues.’

http://www.ge.com/investor-relations/governance/ombudsperson-process

Ethisphere Q2 (2012), p.23:

‘GE offers five different pathways in which employees around the world can bring their concerns to management’s attention: Employees can talk to their direct managers; they can go to people in the compliance function; they can talk to someone in legal services; they can take their concerns to human resources; or they can report issues anonymously to an ombudsman through a variety of channels.’

‘The company also conducts annual surveys and focus groups to assess how well its employees think the system is working and how comfortable they feel reporting problems they perceive.’



A33(a):

Are the whistleblowing channels available to all employees in all geographies?

Score:

2

Comments:

Based on public information, there is evidence that the company has a global network of ombudspersons in every business and country in which GE operates.

References:

Public:


‘With a global network of approximately 600 ombudspersons, coverage is provided for every business and country in which GE operates. Employees know their local business and regional ombudsperson through frequent communications, articles and various Company intranet sites. Ombudspersons are introduced at all-employee meetings within the businesses and regions, including integrity events and trainings.’

‘All ombudspersons speak the local language and understand the culture and business environment of their locations.’





A33(b):

Does the company have formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively?

Score:

2

Comments:

Based on public information, there is 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 ombusperson global network is assessed to ensure it is operating effectively, while the provision of manager training has led to an increase in reporting concerning the ethics policy. Reporting figures are given, including types of disciplinary action.

References:

Public:

Company Website: A Strong Culture of Integrity :

‘The ombudsperson network is assessed and measured to ensure that it is operating with peak efficiency while providing the most comprehensive global coverage.’

‘Since mid-2011, as a result of the training and the creation and implementation of the new manager’s tool, reported concerns regarding The Spirit & The Letter policies have increased by 80% (+13% in 2013 over 2012).’

‘During 2013, 3,104 integrity concerns were reported through the open reporting & ombudsperson process (40% anonymously), covering a variety of issues. The 3,104 integrity concerns led directly to 960 disciplinary actions being taken. These included 228 employee separations, 664 warnings, 22 job changes and 46 financial measures taken. Disciplinary actions are up 16% over last year. Of all disciplinary actions, approximately 54% occurred outside the U.S. Ombudspersons monitor investigations to ensure timely closure and prompt feedback to those who have raised concerns. As of April 23, 2014, 98% of 2013 investigations had been closed, averaging approximately 42 days to complete (down 7 days from 2012).’

‘We recognize that it takes courage to raise an integrity concern. In 2013, GE Capital gave


out over 3,000 compliance awards. GE Capital’s reward program is one of many examples of GE’s efforts to drive integrity in action and to foster an open reporting culture across the Company by valuing and appreciating the courage of our employees in continuing to keep GE safe and secure.’


Company Website, Ombusperson Process :

‘Ombudspersons monitor investigations to ensure timely closure and prompt feedback to those who raise concerns.’

Has a detailed list of reports by area‘Ombuds Network

GE’s extensive ombudsperson process serves as a mechanism for individuals to ask questions and report integrity concerns without fear of retaliation. With a global network of approximately 600 ombudspersons, coverage is provided for every business and country in which GE operates. Employees know their local business and regional ombudsperson through frequent communications, articles and various Company intranet sites. Ombudspersons are introduced at all-employee meetings within the businesses and regions, including integrity events and trainings.

As GE employment and business activity has globalized, we have updated the ombudsperson appointment process to reflect our increased global activity. For example, all ombudspersons speak the local language and understand the culture and business environment of their locations. The ombudsperson network is assessed and measured to ensure that it is operating with peak efficiency while providing the most comprehensive global coverage. GE ombudspersons are trained in procedures for receiving concerns, initiating investigations, and monitoring case progress and closure. Training for ombudspersons is digitized to allow for self-directed course instruction. In 2013, a total of 134 ombudspersons were trained. Digitized refresher courses are available to all trained ombudspersons.

Prompt corrective action and discipline are elements of a strong integrity culture at GE. Confirmed violations of Company policies and procedures result in corrective actions such as training, strengthening routines, and simplifying or updating processes. Although many policy nonconformance’s result from unintended mistakes, disciplinary actions are taken in appropriate cases involving intentional wrongdoing.’

‘In 2011, GE launched an initiative that has become known as “Open Reporting”—communicating to colleagues around the world the channels through which they can raise concerns. In parallel, we created a new “Manager Open Reporting Tool,” whereby any management, HR, Compliance, Legal or Corporate Audit Staff professional is able to submit a compliance concern that has been raised with him or her directly and not through the ombuds channel. Since June 2011, we have trained over 20,000 GE professionals via the Manager Open Reporting Tool on their responsibility in managing compliance concerns that are raised with them. By the end of 2013, an additional 22,000+ managers were trained on




this simple yet very important process. Since mid-2011, as a result of the training and the creation and implementation of the new manager’s tool, reported concerns regarding The Spirit & The Letter policies have increased by 40% (+13% in 2013 over 2012).

During 2013, 3,104 integrity concerns were reported through the open reporting & ombudsperson process (40% anonymously), covering a variety of issues. The 3,104 integrity concerns led directly to 960 disciplinary actions being taken. These included 228 employee separations, 664 warnings, 22 job changes and 46 financial measures taken. Disciplinary actions are up 16% over last year. Of all disciplinary actions, approximately 54% occurred outside the U.S. Ombudspersons monitor investigations to ensure timely closure and prompt feedback to those who have raised concerns. As of April 23, 2014, 98% of 2013 investigations had been closed, averaging approximately 42 days to complete (down 7 days from 2012).’


Ethisphere Q2 (2012), p.23 :

‘The company also conducts annual surveys and focus groups to assess how well its employees think the system is working and how comfortable they feel reporting problems they perceive.



A34:

Does the company have well-publicised resources available to all employees where help and advice can be sought on corruption-related issues?

Score:

2

Comments:

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. This includes trained managers and a global network of ombudspersons. Employees are made aware of these resources via frequent comminications such as articles and Company intranet sites.

References:

Public:

A Strong Culture of Integrity:

‘With a global network of approximately 600 ombudspersons, coverage is provided for every business and country in which GE operates. Employees know their local business and regional ombudsperson through frequent communications, articles and various Company intranet sites. Ombudspersons are introduced at all-employee meetings within the businesses and regions, including integrity events and trainings.’

‘“Manager Open Reporting Tool,” whereby any management, HR, Compliance, Legal or Corporate Audit Staff professional is able to submit a compliance concern that has been raised with him or her directly and not through the ombuds channel. Since June 2011, we have trained over 20,000 GE professionals via the Manager Open Reporting Tool on their responsibility in managing compliance concerns that are raised with them. By the end of 2013, an additional 22,000+ managers were trained on this simple yet very important process.’





A35:

Is there a commitment to non-retaliation for bona fide reporting of corruption?

Score:

2

Comments:

Based on public information, there is evidence that there is a commitment to non-retaliation for bona fide reporting of corruption, with the company explicitly stating disciplinary measures may be taken in response to retaliation against an employee.

References:

Public:

A Strong Culture of Integrity:

‘GE’s extensive ombudsperson process serves as a mechanism for individuals to ask questions and report integrity concerns without fear of retaliation.’

‘trust that the process is confidential and has no tolerance for retaliation.’



‘Any retaliation — whether direct or indirect — against employees who raise a concern is grounds for discipline up to and including dismissal.’







Information Sources:

Company websites:

www.geaviation.com

www.ge.com

www.gesustainability.com

The Spirit and the Letter, The GE Code of Conduct (2014):


Integrity Guide for Suppliers, Contractors and Consultants (September 2009)


Annual Report (2013)


http://www.geaviation.com/

http://www.ge.com/

http://www.gesustainability.com/




