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Accenture Douglas G.

Scrivner, General Counsel, Secretary & Compliance Officer

In Accentures ethics and compliance program, the company uses six core values of stewardship, best people, client value creation, one global network, respect for the individual and integrity. Douglas Scrivner, General Counsel at Accenture, says that ethics and compliance cant be effective if theyre only seen as bolt-ons, or something that is only done at the end of the day after the regular work is complete. We aim to put ethics and compliance into the way our people work and lead. We seek to leverage existing processes, procedures, structures and functions to ensure the outcomes we are expecting and alignment with the goals of the organization, says Scrivner. To better understand how the companys ethics and compliance program is being received by employees, Accenture uses employee surveys, risk assessments and results of corporate investigations. Scrivner notes that in a recent survey, over 90 percent of employees feel that Accenture is highly ethical and that the companys commitment to integrity has been communicated to the whole company. Those are excellent scores for a company of more than 181,000 people, Scrivner says. We havent arrived at the end of our journey (and never will), but I am confident that we continue to move in the right direction and continually reinforce our commitment and our expectations in this area. Caterpillar Ed Scott, Chief Ethics & Compliance Officer Ed Scott, Chief Ethics and Compliance Officer at Caterpillar, says that the ethics at Caterpillar start at the top, beginning with CEO Jim Owens. Our leaders work to ensure that Our Values in Action [Caterpillars Code of Conduct] are part of everyday life at Caterpillar, says Scott. They take various opportunities to incorporate Our Values in Action into their communications. In turn, Caterpillar employees are expected to know and live by Our Values in Action. Scott says that he is most proud of the way that the companys ethics program reaches out to the thousands of Caterpillar employees working in around 50 countries in all regions of the globe. Over the past few years, weve made significant strides in globalizing our approach, says Scott. One item in particular is our Annual Assessment and Questionnaire. It is offered in 14 languages and all of our employees are required to complete this. You can imagine that with so many employees, this is a major undertaking.

Scott believes that any companys ethics and compliance program is only as strong as the culture behind it. You can have the best ethics and compliance program in the world, but if you dont have an ethical culture supported by strong leadership, the program will ultimately not succeed, Scott says. Generations of Caterpillar people built our honorable reputation and ethical culture through their words and deeds. General Mills Roderick A. Palmore, Executive Vice President, General Counsel, Chief Compliance and Risk Management Officer

As a well established global business, General Mills knows that ethics programs must be adaptable to the different regions in which the company operates. A strong ethics and compliance program must feel culturally relevant to employees, says Roderick Palmore, General Counsel of General Mills. A program that genuinely reflects the culture and values of a company helps employees understand and incorporate the messages of the program into their daily decisions. Employees experience them as part of the very fabric of the companys culture. To help employees learn from prior real-world decisionsboth good and badGeneral Mills developed a feature on its company Intranet that uses real examples that came from the companys Ethics Line. We continually look for opportunities to incorporate real stories from our history to bring to life our heritage of integrity and to respond to that feeling of pride we all have in working for General Mills, Palmore says. Palmore says that in order to remain relevant, General Mills makes sure that its ethics and compliance program is continually evolving in a real-time way to meet the needs of a constantly changing demographic-base of employees. We strive to be the best, Palmore says. That means we need to stay fresh in our thinking and be in touch with best practices. Philips Electronics North America Brent Shafer, CEO

Above and beyond mere word play towards and ethics program, Philips links its sustainability and ethics programs with the companys core strategy. And, even more important, Philips grades its success by measurable results. By 2012, Philips aims to generate 30 percent of total revenue off Green Products, further increase energy efficiency of the company by 25 percent and double the companys investment in Green Innovations to 1 billion. Our performance in 2008 shows that we are well on track to achieve these goals with 25 percent of total sales coming from Green Products, investing 282 million euros in green innovations and reducing our carbon footprint by 5 percent, says Brent Shafer, CEO of Philips Electronics in

North America. We communicate transparently on our sustainability performance through our annual report that is independently verified by a third party. Shafer notes the importance of transparency when it comes to reporting about the ethical environment of the company, especially in developing countries. It is important for anyone with an interest in Philips to know that any corporate targets, whether it is a sales goal or growth ambition, will not happen at the expense of non-compliance with the Philips General Business Principles, Shafer says. This risk is heightened in emerging markets as corporate governance systems are less developed in emerging markets compared to mature markets. Unilever Iskah C. Singh, Deputy Global Code & Compliance Officer, Associate General Counsel

Unilever uses a number of approaches to engage its employees in the company ethics and compliance program, according to Iskah Singh, Associate General Counsel for Unilever. Our employee training and education program raises awareness and reinforces the values of the Code of Business Principles, says Singh. Also, employees annually acknowledge understanding and compliance with our Code of Business Principles. In addition to traditional training modules, we have utilized smaller Ethical Moments 3 to 5 minute clips to raise awareness and strengthen the open ethics and compliance environment. Singh says that a strong ethics and compliance program provides many benefits: solid leadership; encourages and facilitates open communication; clearly articulates the standards of business conduct; continually reinforces ethics awareness and actively demonstrates that the values are not just words on paper but are lived on a daily basis. Singh notes that a key differentiator in Unilevers ethics and compliance program is the fact that employees deep within the organization can look to their immediate supervisors as examples of ethical leadership. It is here that an ethical culture is cultivated and the standards and values of Unilevers Code of Business Principles is given meaning, says Singh. T-Mobile USA Robert Dotson, President and CEO

Robert Dotson, president and CEO of T-Mobile USA says that the real test of a companys ethics program is the extent to which it is in the fabric of all employees. He says that happens through strong tone of the top. That emphasis also echoes through the halls of our parent company, Deutsche Telekom, says Dotson. However it also includes active participation and support from our employees. Our employees strive to get results the right way; they regularly raise issues or questions to management on our anonymous Integrity Line; and they

take personal responsibility for how they live the values in their quarterly performance reviews. Its a top to bottom program that is owned at all levels of the company. Dotson adds that T-Mobile is a fast paced company in a competitive industry, and that brings a certain amount of pressure to develop game-changing products, outpace the competition, and drive excellent financial results. But, he says, that shouldnt affect how the products are developed or how the company operates. Our employees know that getting great results is only part of the equation, Dotson says. We expect everyone to get the right results, the right way. Performance and values are like two wings of an airplane they are both required for success, and you really would never try flying without one of them. Send your comments to Ethisphere editors by sending an email to letters@ethisphere.com. Your comments may be published in an upcoming issue of Ethisphere Magazine.

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