Business Ethics Amazon encourages and enforces strict adherence to local, state, federal, and international laws. Our Code of Business Conduct and Ethics (Code of Conduct) outlines the behavior we expect from employees regarding potential ethical issues such as conflicts of interest, insider trading, discrimination and harassment, and compliance. Bribery and Corruption Amazon has zero tolerance for bribery and corruption in any form for any of our businesses. Our anti-corruption compliance program is implemented as part of a centralized global compliance program, led by the Vice President for Business Conduct and Ethics. The program is grounded in our Code of Conduct, which is supported by numerous additional policies, procedures, and other communications, and includes an outright prohibition on bribery of any kind. Our Business Conduct and Ethics program includes a risk assessment and compliance goal-setting process that gathers broader business input through regular client interviews, a whistleblower hotline, centralized investigation and reporting of violations, due diligence processes designed to detect potential compliance issues before engaging in transactions with third parties, and a wide variety of online and in-person training about compliance-related topics and the company’s compliance policies. Amazon has extensive controls relating to financial transactions, through which groups such as accounting, finance operations services, accounts payable, and payroll all own processes that identify, monitor, and evaluate risks including fraud, misappropriation of assets, corruption, and the integrity of financial reporting. Other control functions such as finance, procurement, and internal audit all work together with the Business Conduct and Ethics team to prevent, detect, and deter corruption. Data Privacy Amazon understands that customers care how their personal data is collected, used, and shared, and we work every day to earn and maintain customer trust. Across all of our products and services, our principled approach to privacy begins with transparency, customer control, and security. We inform our customers of our privacy and data security policies, practices, and technologies through our privacy notices, including the Amazon.com Privacy Notice and the AWS Privacy Notice . We are also enhancing cybersecurity awareness beyond Amazon by offering the training we use for our own employees free to individuals and businesses. Data Privacy Oversight An ad hoc committee of the Board appointed in 2022 receives reports from management and reports to the Board at least annually on data protection and cybersecurity matters. This committee also reviews the measures implemented by Amazon to identify and mitigate data protection and cybersecurity risks. Amazon requires employees with access to information systems, including all corporate employees, to undertake data protection and cybersecurity training and compliance programs annually. Whistleblowing Amazon provides secure and accessible channels where employees can raise concerns and report violations in confidence and without risk of reprisal. As described in our Code of Business Conduct and Ethics, employees can speak with anyone in their management chain or the Legal Department when they have a question about the application of the Code of Conduct or when in doubt about how to properly act in a particular situation. The Legal Department has provided guidelines for how employees can report concerns. We do not allow retaliation against an employee for reporting misconduct by others in good faith. Employees must cooperate in internal investigations of potential or alleged misconduct, and those who violate the Code of Conduct will be subject to disciplinary action up to and including discharge. In addition, suggestions or complaints emailed to a member of the senior leadership team are considered Executive Escalations. Any employee can utilize this method of providing a suggestion or raising a concern to leadership. All escalations are independently reviewed by Human Resources, used as a learning opportunity, and may be used to update our processes to prevent gaps in the future. 2021 Sustainability Report Introduction I Environment I Society I Governance I Appendix 77
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