Business Ethics - Doing everything in our power to live up to our values is our promise to our shareholders, our employees, our customers and our communities.
JohnsonDiversey holds itself to the highest standards of ethical and legal behavior in all our business operations. The governing principle and theme of all our ethics training and compliance programs, "Ethics is Good Business," expresses our view of the fundamental role those high standards play in everything we do.
"Conducting our affairs in accord with the highest standards is central to the traditions and culture of the Johnson family of business enterprises," said JohnsonDiversey President and ChiefExecutive Officer Ed Lonergan. "It is our responsibility to continue that tradition. It is the right way to do business."
All employees in leadership, managerial and professional roles as well as our Board of Directors are required to take part in annual online training on the company's Code of Ethics and Business Conduct. The training program includes explanations of policy as well as fictional scenarios that challenge a learner's understanding of the policy.
It addresses a host of critical issues, including discrimination, harassment, equal employment, insider trading, bribery, corruption, kickbacks, gifts and entertainment,compliance with laws, the effect of our operations and products on the safety of individuals and the environment, record keeping and accounting practices, and management of confidential information and company assets. It also addresses the obligation of employees to report suspected violations of the code and the means by which to
do so.
Certificate of Completion
The training program is available in the six languages spoken by the majority of our leadership and professional staff. At the end of the 45-minute program, each participant is required to take an online examination about the content. A certificate of completion, required of all participants, is not issued until the participant has answered all the questions correctly. Employees also are required to affirm that they understand and agree to comply with the Code of Ethics and Business Conduct, and that they are not aware of any violations of it. This process enables an employee to raise a concern about a possible violation of the code, which is then investigated under a process established and managed by JohnsonDiversey's Law Department.
Our Board of Directors and all 3,400 employees in leadership, managerial or professional roles completed the training in 2008. We will continue to expand the training to additional employees in 2009.
Whistleblower Policy
We significantly improved employees' access to the Code of Ethics and Business Conduct in 2008 by having the documents translated into 20 languages and posting the translations to the corporate intranet site. The link to the documents is displayed prominently at the center of our corporate intranet home page.
Also at that site is the company's Whistleblower Policy and contact information enabling employees to make a confidential report of a concern via telephone, fax, mail or e-mail. The Whistleblower Policy, also translated into 20 languages, explains the procedures the company has established to enable employees to report concerns regarding accounting matters, and establishes a firm prohibition against retaliation toward anyone who honestly reports such a concern.
Conflict of Interest Disclosures
We also require all employees in executive, leadership and managerial and sales roles, as well as our Board of Directors, to complete annual conflict of interest disclosures.
In addition, we take measures to ensure that the people with whom we do business are conducting their affairs in accord with our own high ethical standards. We require major suppliersto comply with our Supplier Guiding Principles and conduct periodic audits to ensure compliance with these principles.
The Ethics and Compliance Committee in conjunction with the Chief Compliance Officer of the company, oversee JohnsonDiversey's compliance with our Code of Ethics and Business Conduct as well as applicable laws and policies.
The essential document that underlies all our policies and procedures on ethical and legal matters is This We Believe, a written statement of the company's longstanding values.