Code of Conduct

Our Code of Conduct lays out our expectations for directors, officers, employees and contractors worldwide. It applies to our majority-owned affiliates and their employees as well as to business partners such as service providers and agents. We consider it an integral part of our governance structure and make it widely available as part of our commitment to transparency.

Both employees and external parties can report ethical concerns or ask questions via an externally managed, anonymous and confidential reporting mechanism, Noble Talk™. Accessible in multiple languages and at any time, Noble Talk offers toll-free or collect-call access and a web intake form. Employees are also encouraged to report matters internally to our Global Compliance, Human Resources or Legal departments.

In 2017, 32 cases were reported through Noble Talk. The most commonly reported observations involved discrimination or harassment, employee relations issues, and fraud or theft.

Alleged violations are tracked, assigned an investigator and managed in our case management database allowing categorization, streamlined workflow and internal reporting. All Noble Talk matters and dispositions of closed matters, including any disciplinary or remedial actions, are reported quarterly to the Audit Committee of the Board of Directors. In 2017, one case resulted in disciplinary action. Twenty-eight cases were resolved by yearend.