Business conduct & ethics
IBM is committed to principles of business ethics and lawful conduct. It is IBM's policy to conduct itself ethically and lawfully in all matters and to maintain IBM's high standards of business integrity.
Employees must at all times comply with IBM's business conduct and related guidelines. Violation of any IBM guideline is cause for discipline, including dismissal from the company. Employees should consult their management immediately if they have any question whether their actions could violate an IBM guideline.
Furthermore, it is IBM's practice to voluntarily and promptly disclose known violations of government procurement laws to appropriate officials of government. In the event that IBM benefited economically from such known violations, it is our practice to reimburse the government customer accordingly. IBM employees should immediately make known to appropriate levels of management, either directly or through the Open Door or Speak-Up programs, any and all allegations of violations in connection with any government contract.
The Senior Vice President and General Counsel is responsible for providing specific instructions regarding business conduct and ethics and, as appropriate, directing periodic reviews, including business conduct guideline certification programs, to ensure compliance. Each operating unit or subsidiary is responsible for implementing such instructions, including administering certification programs.
In effect since August 15, 1995; replaces earlier policy dated November 10, 1986.
It is IBM's policy neither to buy nor to sell on a reciprocity basis.
To maintain the high performance standards of our products, we must base all our purchases on quality, price and the supplier's reliability. To use reciprocity as a purchasing consideration would limit our field of supply and could jeopardize our product quality and price.
In addition, we should never use our extensive purchases to aid our selling efforts. We must leave customers free to buy, unhampered by any reciprocity considerations.
In effect since November 10, 1966; replaces earlier policy dated January 26, 1961.
IBM Procurement is in full support of IBM's policy regarding reciprocity and at no time should this policy be compromised; i.e., Procurement should never change a sourcing decision based on a supplier's purchases, or lack of purchases, from IBM.
However, all major customers deserve the utmost courtesy and attention from all IBM employees, and this includes Procurement. This courtesy and attention, from a Procurement point of view, means:
- Procurement will advise these suppliers of any Procurement strategies or plans that may impact that supplier's business.
- Procurement will give these suppliers the opportunity to quote on any IBM business that they believe they are qualified for.
- Procurement will help these suppliers gain access to a somewhat higher management level than their level of business with IBM might normally justify.
- Procurement will make sure that affected IBM salespeople and account executives are advised of major events, good or bad, in the relationship; especially, if a major customer is about to lose a significant amount of business. IBM sales must be notified BEFORE the supplier is notified.
IBM Sales and Services publishes a list of IBM's major customers.
We should be very forthright, when the question arises, in explaining our no-reciprocity policy to suppliers.
From time to time, IBM may divest from certain areas of the business. In situations where IBM is a significant customer of the divested area, it may make sense for IBM to buy products from the acquiring company for a period of time.
This approach has two major benefits: first, it maintains the supply to IBM – finding an alternative supplier to completely replace the previously internally sourced supplier could potentially cause major disruptions while any new supplier gained a better understanding of the IBM requirements; and, second, providing the potential for a revenue stream for a defined period can make the sale more attractive to possible acquirers.
Any "partnering" arrangements of this nature require the approval of the CFO of the IBM Corporation.
Guidelines updated as of May 28, 2004.
In effect since August 15, 1995; replaces earlier policy dated November 10, 1986.
The employees of IBM represent a talented and diverse workforce. Achieving the full potential of this diversity is a business priority that is fundamental to our competitive success. A key element in our workforce diversity programs is IBM's long-standing commitment to equal opportunity.
Business activities such as hiring, promotion, and compensation of employees, are conducted without regard to race, color, religion, gender, gender identity or expression, sexual orientation, national origin, genetics, disability, or age. These business activities and the design and administration of IBM benefit plans comply with all applicable laws, including those dealing with equal opportunity. For qualified people with disabilities, IBM makes workplace accommodations that comply with applicable laws, and which IBM determines are reasonable and needed for effective job performance. In respecting and valuing the diversity among our employees, and all those with whom we do business, managers are expected to ensure a working environment that is free of all forms of harassment.
This policy is based on sound business judgment and anchored in our IBM Values. Every manager in IBM is expected to abide by our policy, and all applicable laws on this subject, and to uphold IBM's commitment to workforce diversity.
In effect since January 1, 2003.
Political contributions and employee participation in politics
It is IBM's long-standing policy that we participate in politics as private citizens, not as IBMers. Therefore, it is the policy of the IBM Company not to make contributions of resources such as money, goods or services to political candidates or parties. This policy applies equally in all countries where IBM does business, regardless of whether or not such contributions are considered legal in any host country.
We encourage IBM employees to participate in political activity in their individual communities and countries. The company will do everything reasonable to accommodate employees who need to be away from work while running for or holding political office, or fulfilling significant party duties during a campaign or election. IBM will not pay employees for time off for political activity. However, if a country where IBM does business has a law that requires an employer to give time off, with pay, to any employee holding public office, then that law takes precedence.
Because IBM does business with many levels of government, we have instituted procedures designed to avoid conflict of interest situations for IBM employees holding government offices. These procedures must be followed.
In effect since December 19, 1975; replaces earlier policy dated December 20, 1966.
Employee well-being & product safety
Corporate strategies, instructions and procedures must support our commitment to employee well-being and product safety. Each of us, manager and employee alike, shares a personal responsibility for the following objectives:
-Provide a safe and healthful workplace for our employees.
-Provide products that are safe for use by our customers and employees.
-Meet applicable legal requirements and voluntary practices to which we subscribe where we operate and sell products.
-Incorporate employee well-being and product safety requirements in business strategies, plans, reviews and product offerings.
-Implement, measure, and continually strive to improve well-being processes for preventing work-related accidents, injuries and illnesses.
-Foster employee involvement and provide appropriate well-being education to employees to enhance their ability to work safely and productively.
-Perform audits and self-assessments of our conformance with employee well-being and product safety requirements with results reported to senior executive management.
-Investigate and address work-related and product safety incidents.
-Provide appropriate resources to fulfill these objectives.
Our support for well-being through prevention is vital to our innovation, productivity and morale. We have realized enormous dividends through customer and employee confidence in the safety of our products and our workplaces. The IBM Company expects nothing less in our efforts than the excellence we have attained in these areas.
In effect since June 20, 2001; replaces earlier policy dated November 17, 1997.
As a global company, IBM's business processes increasingly go beyond the borders of one country. This globalization demands not only the availability of communication and information systems across the IBM group of companies, but also the worldwide processing and use of information within IBM.
IBM remains committed to protecting the privacy and confidentiality of personal information about its employees, customers, Business Partners (including contacts within customers and Business Partners) and other identifiable individuals. Uniform practices for collecting, using, disclosing, storing, accessing, transferring or otherwise processing such information assists IBM to process personal information fairly and appropriately, disclosing it and/or transferring it only under appropriate circumstances.
This policy letter sets forth the general principles that underlie IBM's specific practices for collecting, using, disclosing, storing, accessing, transferring or otherwise processing personal information. These general principles apply to the processing of personal information worldwide by IBM.
The general principles are:
Fairness — IBM will collect and process personal information fairly and lawfully;
Purpose — IBM will collect only personal information that is relevant to and necessary for a particular purpose(s) and process personal information in a manner that is not incompatible with the purpose(s) for which it is collected.
Accuracy — IBM will keep personal information as accurate, complete and up-to-date as is necessary for the purpose for which it is processed.
Disclosure — IBM will make personal information available inside or outside IBM only in appropriate circumstances.
Security — IBM will make personal information available inside or outside IBM only in appropriate circumstances.
Access — IBM will provide individuals with appropriate access to personal information about them. The application of these principles is more particularly described in the applicable IBM Corporate Instructions (and any accompanying implementation guidelines) relating to processing personal information.
In effect since November 24, 1998.
Commitment to diverse business relationships
Wherever IBM operates around the world, we strive to conduct our business in a fair and equitable manner. Consistent with this objective, we follow local laws and customs of the countries in which we operate, and we actively seek to establish close working relationships with businesses indigenous to those countries.
The policy of the IBM Corporation is to provide diverse businesses the opportunity to participate in all areas of IBM's marketing, procurement and contracting activities. This policy applies to all firms or institutions regardless of the business owner's race, color, religion, gender, gender identity or expression, sexual orientation, national origin, disability, age or status as a special disabled veteran or other veteran.
In the United States, these activities comply with all applicable federal, state and local laws, including those dealing with the use of small business; small disadvantaged business; women-owned small businesses; HUBZone businesses; veteran-owned businesses and service-disabled veterans.
This policy applies to all areas of expenditures, whether for products or services. Action should be taken by all IBM organizations to ensure that this policy is implemented and that there are programs that ensure IBM's performance against this commitment.
In effect since June 25, 2003; replaces earlier policy dated November 19, 1993.
IBM is committed to environmental affairs leadership in all of its business activities. IBM has had long-standing corporate policies of providing a safe and healthful workplace, protecting the environment, and conserving energy and natural resources, which were formalized in 1967, 1971 and 1974, respectively. They have served the environment and our business well over the years and provide the foundation for the following corporate policy objectives:
-Provide a safe and healthful workplace and ensure that personnel are properly trained and have appropriate safety and emergency equipment.
-Be an environmentally responsible neighbor in the communities where we operate, and act promptly and responsibly to correct incidents or conditions that endanger health, safety or the environment. Report them to authorities promptly and inform affected parties as appropriate.
-Conserve natural resources by reusing and recycling materials, purchasing recycled materials, and using recyclable packaging and other materials.
-Develop, manufacture and market products that are safe for their intended use, efficient in their use of energy, protective of the environment, and that can be reused, recycled or disposed of safely.
-Use development and manufacturing processes that do not adversely affect the environment, including developing and improving operations and technologies to minimize waste; prevent air, water, and other pollution; minimize health and safety risks; and dispose of waste safely and responsibly.
-Ensure the responsible use of energy throughout our business, including conserving energy, improving energy efficiency, and giving preference to renewable over nonrenewable energy sources when feasible.
-Participate in efforts to improve environmental protection and understanding around the world and share appropriate pollution prevention technology, knowledge and methods.
-Utilize IBM products, services and expertise around the world to assist in the development of solutions to environmental problems.
-Meet or exceed all applicable government requirements and voluntary requirements to which IBM subscribes. Set and adhere to stringent requirements of our own no matter where in the world the company does business.
-Strive to continually improve IBM's environmental management system and performance, and periodically issue progress reports to the general public.
-Conduct rigorous audits and self-assessments of IBM's compliance with this policy, measure progress of IBM's environmental affairs performance, and report periodically to the Board of Directors.
Every employee and every contractor on IBM premises is expected to follow this policy and to report any environmental, health or safety concern to IBM management. Managers are expected to take prompt action.
In effect since July 29, 1997; replaces earlier policies dated July 14, 1995, and November 29, 1990.
Team IBM views quality through the eyes of our clients. IBM's commitment to the goal of achieving the highest standards of quality for our products, services, and solutions forms the basis of our value proposition and our brand image, and is a cornerstone upon which IBM builds lasting and essential client relationships.
Our value is delivered as One IBM and not through individual organizations or units. This delivery can be direct or through our partners and channels which span the geographic markets we serve.
IBM’s goal is to consistently provide an experience which contributes to every client’s success, resulting in high levels of client satisfaction, and the client's decision to choose and recommend IBM.
IBM leaders are responsible for defining metrics, improvement targets and driving actions to achieve our quality goals. All IBMers are expected to model IBM’s nine Client Experience practices contributing to continuous quality improvement.
In effect since March 3, 2014.
IBM human rights principles
In effect since November 4, 2014.
IBM global employment standards
At IBM, we have always set high standards for the way we conduct business – in areas from corporate and social responsibility to sound business ethics, including compliance with all applicable laws and regulations.
These Conduct Principles apply to all categories of IBM employees. However, they are not meant to describe the full scope of IBM human resource policies or practices. More detailed statements of policies, procedures and practices are contained in documents such as the IBM Business Conduct Guidelines. Employees are required to comply with all IBM policies, procedures and practices at all times and are responsible for consulting their management if they have any questions.
Our goal is to ensure full compliance with these principles by IBM managers and employees. A companion to this document, the IBM Supplier Conduct Principles, governs our relationships with and standards for IBM suppliers.
Forced, bonded (including debt bondage) or indentured labor; involuntary prison labor; slavery or trafficking of persons shall not be used. This includes transporting, harboring, recruiting, transferring, or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company-provided facilities. As part of the hiring process, workers must be provided with a written employment agreement in their native language that contains a description of terms and conditions of employment prior to the worker departing from his or her country of origin. Employment is voluntary and employees shall be free to terminate their employment at any time. Employers and agents may not hold or otherwise destroy, conceal, confiscate, or deny access by employees to employees’ identity or immigration documents, such as government-issued identification, passports, or work permits, unless such holdings are required by law. Workers shall not be required to pay employers’ or agents’ recruitment fees or other related fees for their employment. If any such fees are found to have been paid by workers, such fees shall be repaid to the worker.
IBM will not use child labor. The term “child” refers to any employed person under the age of 16, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. We support the use of legitimate workplace learning, internship, and other similar programs which comply with all laws and regulations applicable to such programs. Employees under the age of 18 (Young Workers) shall not perform work that is likely to jeopardize their health or safety including night shift and overtime. IBM shall ensure proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable law and regulations, and will provide appropriate support and training to all student workers. In the absence of local law, the wage rate for student workers, interns, and apprentices shall be at least the same wage rate as other entry level workers performing equal or similar tasks. In the unlikely event an instance of child labor is discovered, the matter will be referred to the VP, Global Recruitment and the VP, Employee and Labor Relations for immediate corrective action.
IBM will, at a minimum, comply with all applicable wage and hour laws and regulations, including those relating to minimum wages, overtime hours, piece rates, non exempt or exemption classification and other elements of compensation, and provide legally mandated benefits. The pay which employees receive will be reflected in a timely and understandable manner via a pay statement or similar documentation that includes sufficient information to verify accurate compensation for work performed, including overtime compensation and its calculation if appropriate. All use of temporary, dispatch and outsourced labor will be within the limits of the local law.
IBM will not exceed maximum hours of work prescribed by law and will appropriately compensate overtime. Employees will not be required to work more than 60 hours per week, including overtime, except in extraordinary business circumstances with their consent or where the nature of the position requires such work, such as for exempt employees and employees in executive, managerial or professional positions. In countries where the maximum work week is shorter, that standard shall apply. Employees shall be allowed at least one day off during every seven day work week.
IBM will not discriminate in hiring, promotion, training, compensation of employees and employment practices on grounds of race, color, religion, age, nationality, social or ethnic origin, sexual orientation, gender, gender identity and expression, marital status, pregnancy, political affiliation, union membership, protected genetic information or disability, or covered veteran status. IBM will create a work environment free of discrimination or harassment based on the noted categories. Workers shall be provided with reasonable accommodation for religious practices. In addition, workers or potential workers should not be subjected to medical tests or physical exams that could be used in a discriminatory way.
IBM will treat all employees with respect and dignity and will not use corporal punishment, threats of violence, or other forms of abuse, physical coercion or harassment. Disciplinary policies and practices in support of these requirements shall be clearly defined and communicated to workers.
In conformance with local law, IBM will respect the legal rights of all its employees to form and join worker organizations of their own choosing, including labor organizations or trade unions, or to refrain from forming and joining such organizations, for purposes of bargaining collectively and to engage in peaceful assembly. IBM complies with applicable local laws worldwide regarding employee and third-party involvement, and will not discriminate based on an employee's decision to join or not join a labor organization. IBM respects the rights of employees to organize, and makes managers at all levels aware of those rights. Employees and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation, or harassment. The Company’s long-standing belief is that the interests of IBM and its employees are best served through a favorable, collaborative work environment with direct communication between employees and management. IBM endeavors to establish such favorable employment conditions, to promote positive relationships between employees and managers, to facilitate employee communications, and to support employee development.
IBM will provide its employees with a safe and healthy workplace in compliance with all applicable laws and regulations. Consistent with these obligations, IBM will have and implement effective programs that encompass things such as life safety, incident investigation, chemical safety, ergonomics, and provide safe standards of health and safety in any housing and transportation provided for our employees by the company. Workers will be provided health and safety training in their primary language. Health and Safety related information shall be clearly posted in the facility.
IBM will operate in a manner that is protective of the environment. At a minimum, IBM will comply with all applicable environmental laws, regulations, and standards, such as requirements regarding chemical and waste management and disposal, recycling, industrial wastewater treatment and discharge, air emissions controls, environmental permits, and environmental reporting. IBM will also comply with any additional environmental requirements specific to the products or services being provided to IBM as called for in design and product specifications, and contract documents.
IBM will comply with all applicable laws, regulations and other legal requirements in all locations where it conducts business.
IBM expects its employees to conduct business in accordance with the highest ethical standards, and maintains Business Conduct Guidelines that employees are required to follow. IBM strictly complies with all laws and regulations on bribery, corruption and prohibited business practices. IBM Global Procurement maintains IBM's policy regarding conflict minerals.
IBM makes available to all employees open communications channels for suggestions and complaints to management. IBM maintains channels for direct contact with the Corporate Office for employee complaints, including any form of harassment including sexual harassment.
IBM will perform business audits to ensure adherence to our policies, practices and procedures. We will keep records in accordance with local laws and regulations.
IBM is committed to protecting the privacy and confidentiality of information about its employees. IBM recognizes that under the laws of some countries certain information about employees, such as information regarding racial or ethnic origin, political opinions or philosophical beliefs, trade-union membership, and health or sex life, should be considered "sensitive." Whenever possible, such sensitive information should be processed in aggregate or anonymous form so that a particular individual is not identifiable. Where this is not feasible, IBM will only process the information in accordance with applicable local law (and any designated safeguards provided therein); and with employee consent where required; or where necessary for the establishment, exercise or defense of legal claims. All employees are expected to use information about IBM clients, suppliers, and business partners in accordance with their job responsibilities and the IBM Business Conduct Guidelines.
IBM provides numerous programs for employees to encourage and enhance the positive impact of their community involvement. These global programs include: On Demand Community, a suite of online tools and resources to support employee volunteerism; Community Grants, a program that awards long-term volunteer commitments with grants of cash or IBM equipment; and Matching Grants, a program through which IBM matches employee grants to schools and nonprofit organizations.
Formal corporate policies issued by the IBM Chief Executive Officer, or the senior officer he or she directs, govern company-wide actions within IBM and actions with all third parties. Our corporate policies reflect IBM's values and the resulting management system within which our decisions are made.
Senior Vice President, Human Resources
In effect since April 1, 2016.
IBM grant programs
Our grant programs are designed to apply IBM’s resources to specific projects and programs that fit within our targeted areas of interest, and to enhance IBMers’ support of their communities worldwide.
Impact Grants provide consulting expertise and software designed to support the work of educational and nonprofit organizations. In the program’s first five years, we delivered nearly 2,000 Impact Grants in 70 countries.
IBM Community Grants support employees and retirees who volunteer regularly with not-for-profit organizations. In 2011, community organizations received grants with a value of $10 million through IBM Community Grants.
The IBM Matching Grants program enables employees and retirees (North America only) to increase the value of their donations to educational institutions, hospitals, hospices, nursing homes, and cultural and environmental organizations with a matching gift from IBM. In 2014, more than 6,400 organizations received grants with a total value of more than $11.5 million.
IBM partners with organizations which have a tax-exempt classification under Sections 170(c) or 501(c)(3) of the U.S. Internal Revenue Code. We do not make product and services donations or grants to:
-Individuals, political, labor, religious, or fraternal organizations or sports groups;
-Fundraising events such as raffles, telethons, walk-a-thons or auctions;
-Capital campaigns, construction and renovation projects;
-Chairs, endowments or scholarships sponsored by academic or nonprofit institutions;
-Special events such as conferences, symposia or sports competitions;
-Organizations that advocate, support, or practice activities inconsistent with IBM’s non-discrimination policies, whether based on race, color, religion, gender, gender identity or expression, sexual orientation, national origin, disability, age or status as a protected veteran.
The overwhelming majority of our activities are proactively initiated by IBM, and are not a result of unsolicited proposals. We do not encourage unsolicited proposals.
For information about our activities, please contact your local IBM Corporate Citizenship & Corporate Affairs manager. View the directory
2015 Corporate Responsibility Report
IBM's approach to corporate responsibility reflects our business — applied technology, continuous transformation and sustainable change. Our 2015 report details the impact of our efforts worldwide.