Business conduct and 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. Every IBM employee worldwide must take annual training on IBM’s Business Conduct Guidelines and certify their compliance. According to IBM’s 2017 Corporate Responsibility Report, 100 percent of IBMers around the world completed the BCG course, currently available in 25 languages.

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.

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.

Our commitment to ethics extends to our business partners. Any business that wants to partner with IBM is required to comply with IBM’s PartnerWorld Code of Conduct.

Political campaign contributions and expenditures

IBM has a long-standing policy not to make contributions of any kind (money, employee time, goods or services), directly or indirectly, to political parties or candidates, including through intermediary organizations, such as political action committees, campaign funds, or trade or industry associations. This policy applies equally in all countries and across all levels of government, even where such contributions are permitted by law. This policy is reflected in IBM’s Business Conduct Guidelines.

Contributions which are not permissible either as direct IBM payments or employee expense reimbursements include:

  • Campaign contributions to political candidates, their election campaigns, or political parties.
  • Contributions to any intermediary organization, including trade and industry associations, where those funds will be provided to candidates for public office, political parties or other intermediaries for the purpose of funding political candidates, their election campaigns, independent expenditures or electioneering communications, or political parties.
  • Purchase of tickets or other payment for events where a portion of the funds will be used, directly or indirectly, to fund political candidates, their election campaigns, independent expenditures or electioneering communications, or political parties.

Because of IBM’s policy on political contributions and expenditures, IBM does not have a Political Action Committee and does not engage in independent expenditures or electioneering communications as defined by law.


Public policy expenditures and lobbying

IBM may make expenditures to support or advocate particular viewpoints on public policy issues, including expenditures for intermediaries that advocate on IBM’s behalf. In addition, IBM occasionally may seek the participation of IBM employees, on a voluntary basis, in conveying the IBM position to public officials when the issue may have a significant impact on IBM or its employees and participation is in IBM’s best interest. Public policy advocacy involving expenditures or the participation of IBM employees requires the prior approval of IBM Government and Regulatory Affairs and appropriate legal counsel.

IBM engages in lobbying activities in accordance with applicable law and the requirements in Section 6 of IBM’s Business Conduct Guidelines. All IBM lobbying activities require the prior approval of IBM Government and Regulatory Affairs. IBM files periodic reports with the Secretary of the U.S. Senate and the Clerk of the U.S. House of Representatives detailing its U.S. federal lobbying activities and expenditures. These reports are available here. IBM also files lobbying reports with U.S. state and municipal governments, where required, and with the European Union Transparency Register.

Periodically, IBM Government and Regulatory Affairs reports to the IBM Board of Directors about the company’s policies and practices in connection with governmental relations, public policy, and related expenditures.

Public policy positions

IBM Government and Regulatory Affairs is a globally integrated corporate function responsible for managing IBM’s public policy issues and government relations worldwide. With dedicated resources in the Americas, Europe, Africa, and Asia, IBM Government and Regulatory Affairs pursues mutual objectives of global consistency and local relevancy in supporting IBM’s growth and business operations. IBM Government and Regulatory Affairs works with governments on key economic, governmental, and societal issues, helping them solve problems and create strategies for the future. An overview of IBM’s key policy positions is available here.

Trade and industry associations

Our policy restricts trade and industry associations from using IBM funds to engage in political expenditures. IBM has procedures to ensure that IBM payments to trade or industry associations comply with this policy. These procedures include IBM providing written communication of IBM’s restrictions to the association.

IBM joins trade and industry associations that add value to IBM, its stockholders and employees. These groups have many members from a wide variety of industries, and cover very broad sets of public policy and industry issues. As a result, there may be occasions where the views of a particular association on one or more specific issues are different than IBM’s views.

Employee public service and political activity

IBM encourages all employees to pursue personal interests, including active participation in their communities. If IBM employees choose to participate in political activity, they do so as individuals and not company representatives. IBM will make reasonable accommodations for employees to take vacation or reasonable time off without pay to pursue such activity. Because IBM does business with many levels of government, we have instituted policies and procedures designed to avoid conflict of interest situations for IBM employees engaged in public service, as described in Section 7 of IBM’s Business Conduct Guidelines.