Evolving from Compliance to an Integrity culture

<p><b>ABB is committed to fostering a culture where integrity is woven into the fabric of everything we do and is at the core of our governance. Integrity must be embedded in our people, businesses and processes, through our collective responsibilities as a company and individual accountability.&nbsp; This means behavior that falls short of our standards and expectations is simply not an option.

</b></p> <p>&nbsp;</p> <p>The&nbsp;<a href="https://search.abb.com/library/Download.aspx?DocumentID=9AKK107680A7765&amp;LanguageCode=en&amp;DocumentPartId=&amp;Action=Launch">ABB Code of Conduct</a>, our policies and set of internal controls are designed to guide our employees on our standards and prevent integrity concerns. Through the years, as a mark of our maturity, our Integrity Program has evolved beyond pure legal compliance to embracing standards of conduct that are supported by individual accountability and ownership of our integrity and business principles.&nbsp;<br> <br> Working with integrity means that we measure performance not only by the results achieved, but also by how the results were achieved.&nbsp;<br> <br> All employees must understand that behaving with integrity is a core element of any career at ABB. Integrity is one of ABB’s five strategic imperatives, and it is the responsibility of every ABB manager to ensure that their direct reports understand this.</p> <p>&nbsp;</p> <p>Learn more about our standards and policies, and training components of our Integrity Program.</p>

Standards and policies

At ABB, we have zero tolerance for illegal and unethical behaviour. With a strong set of internal controls and group directives which provide practical guidelines for applying the ABB Code of Conduct in our day-to-day activities, we strive to create a culture of integrity reflected in our behaviour. 

Our group directives reinforce the following areas:

  • Bribery and corruption is prohibited in all business dealings, whether with public officials or private sector business partners. As a rule, facilitation payments are not permitted.
  • Substance-based due diligence is mandatory prior to the appointment of ABB representatives, such as third party local agents and exclusive distributors. Centralized and transparent approval processes with appropriate controls over performance, is mandatory prior to any remuneration payments.
  • Political and charitable contributions are subject to detailed internal policy and controls.
  • The gifts, entertainment and expenses policy defines thresholds, approval processes and their documentation, with additional controls for public officials.
  • Agreements with subcontractors and consortium partners are aligned with ABB’s commitment to integrity in the performance of the contract, including commitments not to violate anti-bribery laws. Suppliers must also maintain integrity standards which are satisfactory to ABB and agree to the ABB Supplier Code of Conduct.
  • Compliance due diligence is mandatory for any acquisition target or joint venture. Thorough integration strategies are implemented.

Gifts, entertainment, and expenses

Our success as a company is based on the quality and reliability of our products and services. To protect our reputation, our customers and stakeholders can trust us to only give or receive legitimate and reasonable business gifts and entertainment.

Our group directive on gifts, entertainment and expenses covers both giving and receiving. As a company, we respect global thresholds and approval processes, taking into consideration local standards in the regions in which we do business.

We also recognize that other companies and customers often have their own code of conduct to abide by, and we are committed to never putting anyone in a position to violate their commitments. Our controlled and transparent approval process for gifts, entertainment and expenses serves to support our employees so that they can feel confident they are not crossing the line.



 

Furthermore, additional controls have been developed for public officials. Employees of government owned or controlled companies are subject to these heightened standards. In order to determine whether gifts, entertainment or expenses are appropriate, each employee should consider the following criteria:

  • Made for the right reason: The gift and entertainment should be given as an act of appreciation, friendship or hospitality.
  • No obligation: The gift, entertainment or reimbursement of expense does not place the recipient under any obligation.
  • No expectations: Expectations are not created in the giver or an associate of the giver or have a higher importance attached to it by the giver than the recipient would place on such a transaction.
  • Made openly: If made secretly then the purpose will be suspect.
  • No misuse of expenses: Payment or reimbursement of expenses shall not be misused to hide inappropriate gifts or entertainment.
  • Appropriate: The nature of the gift, entertainment or expense is appropriate and is in line with both general business practice as well as local cultural and ethical standards.
  • Legality: It conforms to the laws of the country where it is made and any other applicable laws.
  • Conforms to the recipient's rules: The gift, entertainment or reimbursement of expenses meets the rules or code of conduct of the company or organization where the receiving person is employed.
  • Infrequent: Such giving or receiving is not a regular happening between the giver and the recipient.

Appointment of ABB representatives

Expecting the utmost integrity from ABB representatives, such as agents, is paramount to our company.

 

Special care is required when selecting ABB representatives, such as third party local agents and exclusive distributors, to ensure that they follow ABB rules and commit to working with the highest level of integrity. All appointments are subject to robust, structured approval processes and remuneration guidelines are predefined.


 

ABB uses standard agreements that include anti-bribery provisions, audit rights, and rights to terminate agreements for violations of the ABB Code of Conduct. 

An electronic database is used to support the appointment process and associated due diligence of agents. It also provides instruction for proper controls during execution of their activities, and an approval process for remuneration payments.  

Integrity Training

Our Integrity Program has a strong training component. We provide e-learnings, face-to-face trainings and diverse communication materials to enable understanding of the expected integrity behaviours.

  1. E-learning solutions

    The ABB Integrity Awareness Portal, provided in partnership with SAI Global, hosts the e-learning solutions accessible to our employees and external stakeholders. The portal includes short animations, ethical moments, quizzes, videos, infographics, easy-to-understand content for employees to choose from. It can be accessed anytime and anywhere, from a desktop or mobile device, by our employees, contractors, representatives and channel partners.

    • Employees and contractors must be connected to the ABB network to log into the Integrity Awareness Portal. Then use this LINK.
    • ABB Representatives with an existing e-learning account can use this LINK to login.
    • ABB Channel Partners can self-register and set up an e-learning account by using this  LINK.

    Important note: legitimate e-mails from our service provider will have links to https://sai360-integrityatabb.csod.com/ (for employees) and sent from 'integrity.abb@csod.com' (for ABB Channel Partners).

  2. Face-to-face training

    Our face-to-face training supports an inclusive, two-way approach to personal accountability and responsibility for every employee. These sessions allow employees have real-time interaction and discussions of difficult issues, and time for additional guidance as needed. ABB stands by the fact that face-to-face training has the highest impact and the company makes every effort to commit time and resources to educate and empower our employees using this training method.



     

    Additional face-to-face training courses are tailored to different audiences, depending on their risk exposure. Selected integrity topics, such as antitrust and integrity leadership are provided to employees in appropriate positions and functions.



     

    Face-to-face training sessions create constructive dialogue through the business and provide time for employees to work through and learn from real examples within ABB.

Key messages for employees

ABB’s technology makes a major contribution to businesses and communities around the world. It is not only what we do, but how we do it, which determines our reputation with our stakeholders and our level of continued success.

Upon joining ABB, employees are required to read and understand ABB’s Code of Conduct, to know what is required to live up to our ethical standards and expectations. All employees are expected to take mandatory training on our key Code of Conduct topics.

For those employees which face higher risks in their day-to-day work, such as those that are customer-facing or in gatekeeper functions (e.g., Finance or Legal & Integrity), we provide tailored upskilling to enable them to identify and appropriately address risks that they confront in their work.

Every employee at ABB must understand that:

  • ABB must not breach any laws.
  • ABB competes and wins fairly, ethically, and only by playing by the rules.
  • The ABB Code of Conduct and our detailed policies and procedures collectively explain the behavior expected of every employee.
  • ABB remains proactive by designing, implementing and maintaining education and communications, conducting internal surveys, and committing resources, to adequately implement the ABB Global Integrity Program.

Management's Responsibility

The primary responsibility for ensuring that employees are aware of and embrace these messages lies with the business. Business Presidents and financial controllers regularly review and report on integrity and compliance developments in their business. Any issues identified are required to be an agenda item for reviews by the business and form part of ongoing performance evaluations. 

Integrity Communications

We use the communications component of our Integrity Program to raise awareness and visibility of integrity throughout ABB. Regular and wide-ranging communications enable employees around the world to be aware of ABB’s commitment to integrity and what the consequences are if we fall short.

Integrity communications are posted at regular intervals on the ABB intranet including:

  • Straight Talk cases
  • Viva Engage posts by management
  • Integrity Circles with conversational tools for management and employees.

Our Straight Talk case library is a dedicated internal platform where we share integrity learnings, both successes and failures, from real-life cases that ABB has faced. Each ‘Straight Talk’ publication gives greater transparency into our investigations portfolio, including risks and trends, the types of reports made, the geographies concerned, and the reporting methods used by employees. All  employees connected to the ABB network can access these.

Display stands, integrity boards and poster campaigns are rolled out in ABB locations around the world to raise awareness about specific areas of risk and encourage reporting of all suspected violations of the ABB Code of Conduct or the law. We provide regular integrity messaging and visuals across ABB locations to promote a strong culture of integrity.