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Formal corporate policies issued by the IBM chief executive officer (or the senior officer he directs) govern companywide 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. Their intent is to express clear direction on the things that are fundamental, basic, most important and therefore most enduring in our business.

IBM has corporate policies that cover the following issues:

 

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.

 

Reciprocity

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.


Guideline A
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:

  1. Procurement will advise these suppliers of any Procurement strategies or plans that may impact that supplier's business.
  2. Procurement will give these suppliers the opportunity to quote on any IBM business that they believe they are qualified for.
  3. Procurement will help these suppliers gain access to a somewhat higher management level than their level of business with IBM might normally justify.
  4. 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.

Guideline B
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.

 

Workforce diversity

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

IBM has a long tradition of excellence in employee well-being and product safety. The importance we place in these efforts demonstrates our commitment to employees, customers and business partners.

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:

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.

 

Data privacy

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 implement appropriate technical and organizational measures to safeguard personal information and instruct third parties processing personal information on behalf of IBM, if any, to process it only in a manner that is consistent with processing it on IBM's behalf, and to implement appropriate technical and organizational measures to safeguard the personal information.

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.

 

Environmental affairs

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:

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.

 

Quality

IBM has an overriding worldwide commitment to the quality of the products, solutions and services we provide to our customers. Quality is recognized as a fundamental component of the value customers receive from IBM.

IBM is committed to the goals of achieving total customer satisfaction; delivering superior products, solutions and services; and exceeding customer requirements. Recognizing that the marketplace is the driving force behind everything we do, IBM implements effective business processes that support value creation for our customers and our stakeholders.

IBM leaders are responsible for establishing objectives and using measurements to drive continual improvement in quality and in customer satisfaction. All IBMers are expected to contribute to continual improvement as an integral part of our quality management system.

In effect since September 28, 2000.

 

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 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 or involuntary labor
IBM will not use forced or involuntary labor of any type (e.g., forced, bonded, indentured or involuntary prison labor); employment is voluntary.

Child labor
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 apprenticeship, internship and other similar programs that comply with all laws and regulations applicable to such programs.

Wages and benefits
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, nonexempt or exemption classification and other elements of compensation, and provide legally mandated benefits.

Working hours
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, 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 should be allowed at least one day off per seven-day week.

Nondiscrimination and harassment
IBM will not discriminate in hiring, promotion, compensation of employees and employment practices on grounds of race, color, religion, age, nationality, social or ethnic origin, sexual orientation, gender, gender identity or expression, marital status, pregnancy, political affiliation, disability or veteran status. IBM will create a work environment free of discrimination or harassment based on race, color, religion, gender, gender identity or expression, sexual orientation, national origin, disability, age or veteran status.

Respect and dignity
IBM will treat all employees with respect and dignity and will not use corporal punishment, threats of violence or other forms of physical coercion or harassment.

Freedom of association
IBM will respect the legal rights of its employees to join or to refrain from joining worker organizations, including labor organizations or trade unions. IBM complies with legal requirements worldwide regarding employee and third-party involvement. IBM respects the rights of employees to organize, and makes managers at all levels aware of those rights. 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.

Health and safety
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 will implement effective programs that encompass things such as life safety, incident investigation, chemical safety, ergonomics, and will provide safe standards of health and safety in any housing and transportation provided for our employees by the company.

Protection of the environment
IBM is committed to worldwide leadership in environmental protection. In addition to complying with applicable environmental laws and regulations, every employee must comply with IBM's environmental policy and the corporate directives and requirements that support that policy. Employees are expected to report any environmental concern or violation of environmental law or IBM requirements to their management. Managers are expected to take prompt action.

Laws, including regulations and other legal requirements
IBM will comply with all applicable laws, regulations and other legal requirements in all locations where it conducts business.

Ethical dealings
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.

Communications
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.

Monitoring/record keeping
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.

Privacy
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 process the information only 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.

Support for employees and community involvement
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.

In effect since February 8, 2005.