How we do things
At Hewlett Packard Enterprise, how we do things is as important as what we do. Our corporate values, policies, and training courses set clear expectations for employees, and demonstrate our commitment to the highest ethical standards. We are responsible for our actions, accountable for their consequences, and serious about our efforts.
We also use our scale and influence to encourage ethical behavior beyond our own operations, such as in our supply chain and towards human rights.
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Our codes of conduct detail our expectations for employees, contingent workers and anyone doing business with us. These codes include:
Our Ethics and Compliance program provides guidelines to ensure that employees, business partners, and suppliers worldwide engage in lawful and ethical business practices when doing business with us. We respond swiftly to violations and have systems in place for reporting and resolving ethical concerns, in line with our policies and local laws.
Corrupt behavior undermines the values on which our company is built, the principles of fair competition, and the rule of law. We do not tolerate corrupt behavior, including bribery or kickbacks, in any circumstance.
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HPE’s Ethics & Compliance Office (ECO) has a dedicated anti-corruption team staffed with specialized attorneys, auditors, and compliance professionals. This team is responsible for implementing our anti-corruption compliance program and updating and enhancing the company’s anti-corruption policies and processes, in partnership with other global functions and business units.
Through our anti-corruption compliance program, we promote compliance with the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, and other anti-corruption laws around the world. Our Anti-corruption Policy provides the guidelines and principles to help directors, officers, and employees worldwide uphold our anti-corruption commitment, while our Global Business Amenities Policy establishes limits, approvals, and requirements for employees to follow when providing and receiving business amenities (gifts, meals, travel and entertainment) to or from third parties.
HPE provides anti-corruption training to all employees annually as part of its Standards of Business Conduct training. We provide this training in twenty different languages: English, French, Italian, German, Spanish, Japanese, Chinese (simplified), Chinese (traditional), Korean, Vietnamese, Portuguese, Dutch, Bulgarian, Czech, Hungarian, Arabic, Russian, Hebrew, Indonesian, and Polish. ECO regularly presents “ethics roadshows” to senior business leaders in countries around the globe in live meetings to discuss anti-corruption and other top risk areas, investigations trends and the importance of a strong tone from the top. ECO also presents live and virtual trainings on anti-corruption compliance to groups of employees in high-risk areas, using current and refreshed content.
We use internal data and Transparency International’s Corruption Perceptions Index to identify countries at high risk for corrupt activity. We also benchmark our program with those of other companies to identify potential improvements. This information helps us to prioritize employee education and training efforts and focus our audits and assessments of our own operations as well as our suppliers and partners.
We have a robust third-party due diligence screening program, covering partners, suppliers, agents, global logistics service providers, lobbyists, and other third parties. We include anti-corruption terms and conditions in our contracts with third parties. We also review certain high-risk transactions for anti-corruption compliance, and we have a dedicated internal investigations team within ECO that investigates allegations of bribery and corruption.
For more information regarding our corporate ethics and anti-corruption policies and practices, please refer to our Living Progress Report.