GE infuses compliance and governance into every aspect of its business. We are committed to maintaining a world-class compliance culture in every GE business and everywhere we operate around the world. We recognize that our reputation for integrity and compliance is a competitive advantage, and are proud to have been honored as one of Ethisphere’s World’s Most Ethical Companies for 11 straight years (2007–2017), one of only 13 companies out of 124 that have made the list for each year.
At the heart of GE’s Integrity & Compliance program is The Spirit & The Letter, a code of conduct and set of policies that cover our integrity commitments on critical subjects and risk areas.
GE’s Integrity & Compliance program focuses on prevention, detection and response. It begins with personal commitments from our leadership and is supported by robust compliance processes. GE leaders personally engage in the active oversight of compliance risk areas and lead by example to create a culture of compliance.
A hallmark of GE’s compliance program is a steadfast commitment to a vibrant, well-publicized and effective “open reporting environment,” in which employees are encouraged to raise integrity concerns and to feel confident that they can do so without fear of retaliation. In today’s environment, GE employees remain the Company’s first and best line of defense in the early detection of potential compliance issues. GE has approximately 620 ombudspersons around the globe to encourage the reporting of concerns without fear of retaliation.
During 2016, more than 4,470 integrity concerns were reported through the open reporting and ombudsperson process (30% anonymously), covering a variety of issues. The reported concerns led directly to 1,173 disciplinary actions as of February 1, 2017.
GE strives to be out in front of significant compliance risks in order to ensure that the Integrity & Compliance program is evolving as new risks emerge. For example, GE has built a Project Management Organization that focuses on compliance risks related to large projects, in response to the acquisition of Alstom’s Power and Grid businesses. GE also continues to focus its efforts on key compliance risk areas through memberships in organizations including the Business Ethics Leadership Alliance and Transparency International, of which GE was a founding member.
With changing workforce demographics and modes of communication, our program requires constant reinvention in order to stay relevant for a global community. Our program priorities include simplification, working horizontally, and utilizing data to further strengthen our compliance program. These three initiatives parallel our key pillars of prevention, detection and response.
1. Simplification (Prevent)
GE believes that simpler compliance is better compliance, and therefore has been making strides to simplify the program. The Company has been striving to make integrity policies more readable for employees. Examples include the creation of one-page guides for supplier onboarding, competition law, revenue recognition, and business courtesies.
GE has also been exploring more efficient and effective ways to train and communicate with employees about integrity and compliance. For example, in 2016, GE incorporated compliance-based gaming options into its mobile compliance application and began piloting the use of compliance-based training within the applications employees use each day, in order to give them the information they need when they need it.
2. Data (Detect)
Data has become an increasingly important feature of how we work in a global environment. Systems and processes result in data that, if properly combined, can yield insights into the health of the program. GE has developed a Compliance Executive Dashboard that centralizes compliance data for the Company’s business units. In 2016, GE began exploring predictive analytics and piloted a monitoring program related to business courtesies. In 2017, GE will continue to pilot monitoring and analytics in additional risk areas.
3. Working Horizontally (Respond)
As GE has continued to grow its global footprint, it has become increasingly important to get the balance right between local and global processes. In cases where the risk-mitigating controls are similar, GE has found that having one policy and one process has resulted in better outcomes. In 2016, the Company centralized the monitoring of business courtesies, which was enabled by the implementation of a standard process, policy and tool. In 2017, GE will continue to explore opportunities to centralize including driving consistent requirements for onboarding of direct suppliers.