2021 CORPORATE RESPONSIBILITY REPORT I 68 Integrity: a fundamental value (continued) Enterprise risk management begins with awareness We maintain an enterprise risk management (ERM) program overseen by our Board of Directors and driven by our C-suite executives that is designed to promote risk awareness throughout the company’s key business, operations, and support functions. Our program, which is integrated with the company’s governance, performance management, and internal control frameworks, entails a formal continuous process that identifies, assesses, mitigates, and manages the risks from both internal and external conditions that could significantly impact the company and influence its business strategy and performance. The program is based on the most recent framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) and focuses on operational, financial, legal, compliance, and strategic risk. As part of the program, together with our Board of Directors, we routinely assess our enterprise-level risks, emerging risk factors, overall company-level risk tolerance, and the effectiveness of our risk management, as well as monitor the progress of and resources applied to risk mitigation. In addition, we continue to strengthen the alignment of our ERM program with our key environmental, social, and governance (ESG) areas of focus. Reporting process We routinely communicate with employees on how to confidentially report a violation of the Code and take all reports of violations extremely seriously. Reports are investigated by the Compliance, Human Resources, and/or Legal departments, as appropriate. If the investigation reveals a violation of a compliance policy, the Compliance department oversees any necessary corrective action including discipline up to and including termination. The corrective action taken is dictated by the type of issue involved, based on the circumstances and facts gathered during the investigative process, and consistent with written disciplinary guidelines. Our Senior Vice President of Compliance provides oversight on the program and reports directly to our CEO. Our commitment to human rights We are committed to protecting human rights across our operations, including our supply chain. We’re proud to share our human rights policy, and we believe that protecting and supporting human rights is our fundamental responsibility as an employer. We comply with all applicable employment and human rights laws and regulations where we have operations to ensure alignment with our values. • We provide fair and equitable wages, benefits, and other conditions of employment in accordance with local laws and regulations. • We do not allow child labor in our operations. • We do not use or engage in any form of coerced, indentured, or prison labor. • We provide a safe and healthy work setting, including PPE and the tools to work safely. • We promote a workplace that is free of discrimination and harassment and prohibit threats or abuse. • We embrace diversity in the workforce and supplier base, create an environment that promotes diverse opinions and equal opportunity, and operate in a way that treats all people with respect and dignity. TABLE OF CONTENTS 2021 OVERVIEW COVID-19 RESPONSE PROMOTING A HEALTHIER WORLD CREATING AN INSPIRING WORKPLACE BUILDING VALUE REFERENCES
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