Business Ethics

We adopt a proactive and comprehensive approach to ethics and compliance that underscores the importance of behaving in an ethical manner at all times. Our Code of Conduct lays out our expectations for directors, officers, employees and contractors worldwide. The Code applies to our majority-owned affiliates and their employees as well as to business partners such as service providers and agents.

We consider our Code of Conduct an integral part of our governance structure and make it widely available as part of our commitment to transparency. In addition to our general Code of Conduct, we also maintain a Code of Ethics for our Chief Executive and senior financial officers. Our Codes of Conduct are publicly available on our Corporate Governance webpage.

All employees, contractors, business partners and other external stakeholders can report ethical concerns or suspected violations or ask questions via an externally managed, anonymous and confidential reporting mechanism called Noble Talk™.


Accessible in multiple languages at all times, Noble Talk offers toll-free or collect-call access, as well as an online presence for users to access. We also encourage our employees to report matters internally to our Global Compliance, Human Resources or Legal departments.

In 2018, 62 cases were reported through Noble Talk. The most commonly reported observations involved discrimination or harassment, conflict of interest and bribery. We assign an investigator to all suspected violations, and we categorize and track each case in our management database. Once per quarter, we report all Noble Talk matters and dispositions of closed matters, including any disciplinary or remedial actions, to the Audit Committee of the Board of Directors. In 2018, we resolved 57 cases, including 7 that resulted in disciplinary action.  

We maintain an active global training program with our employees and contractors to combat corruption. In 2018, more than 2,800 employees and contractors were trained on our Code of Conduct. We also held our ninth annual NobleWay Summit where more than 150 employees gathered to hear subject matter experts speak on the topics of ethics, leadership, innovation and inclusion.

As part of our responsibility to uphold and champion our values and ensure a workplace free from harassment and discrimination, we introduced an expanded, updated training session on workplace respect and preventing workplace harassment during the fourth quarter of the year. The training is one of several resources available to ensure employees can successfully navigate today’s work environment. Nearly half of our employees (1,272) completed the multi-hour session within the first 30 days.