Governance at IBM

The ultimate responsibility for our economic, environmental and social performance lies with IBM senior management, as does our adherence to IBM’s overall compliance programs. Corporate responsibility at IBM is integrated across the business through the following forums.

Corporate Responsibility Steering Committee

Our Corporate Responsibility Steering Committee is charged with providing leadership and direction on key corporate responsibility issues. Senior executives from functional areas across the company make up the committee, which is chaired by the vice president for Corporate Citizenship and Corporate Affairs. Each functional area within IBM is responsible for the development of its own corporate responsibility goals and strategy, and organization-wide goals are approved by the steering committee.

Corporate Responsibility Working Group

Consisting of representatives from 10 functional areas (including global representation), our Corporate Responsibility Working Group meets at least monthly to manage IBM’s corporate responsibility activities and stakeholder engagement across the company. The working group is responsible for reviewing key policy and strategic issues and making recommendations to the steering committee throughout the year.

On a day-to-day basis, our activities are coordinated in the Corporate Citizenship and Corporate Affairs organization, which reports to the senior vice president for marketing and communications.

Ethics and integrity leadership

IBM has a long history of ethics and integrity leadership. Creating a culture of ethics and integrity starts with our employees and leaders and extends to our business partners, suppliers and communities in which we live and work. To propagate a culture of ethics and integrity, we teach, listen and collaborate. In 2014 we enhanced and added a number of initiatives designed to help reinforce our standards and values.

In 2014, as in prior years, IBM saw 100 percent participation by its employees around the world in its online Business Conduct Guidelines (BCG) course and certification. First published in 1961, the BCG is currently available in 24 languages around the world. For nearly 10 years we have provided an online, interactive BCG training program in 14 languages. It is refreshed annually to include timely, relevant business scenarios that employees may face when conducting IBM’s business. IBM’s trust and compliance officers, lawyers and management also work to provide compliance and ethics training to employees around the world in targeted group sessions.

In 2014, we supplemented our employee ethics and integrity education program with three new online courses for employees who are achieving career milestones. These education modules are designed for employees new to IBM, those promoted to management positions and those taking international assignments in emerging markets. Also in 2014, IBM senior business leaders around the world worked to foster our culture of compliance by sponsoring integrity summits in eight cities, primarily in emerging markets. These summits emphasized the role of leaders in creating an ethical culture and focused on key compliance risks in each region, along with specific actions that can be taken to mitigate these risks.

In addition to teaching about ethics and integrity, we also listen. For more than 50 years, IBM has maintained an internal “speak up” reporting channel for employees, as well as channels for suppliers, business partners and others to report concerns or suspected violations to the company. These channels support anonymous reporting. Ten years ago, we added an online component to that channel. And since 2010, hundreds of thousands of IBM employees have provided their perspective on integrity at IBM by participating in our semi-annual survey. In 2014, more than 45,000 employee surveys were completed, providing valuable feedback about employee perception of ethics and integrity within the organization. The insights from these surveys are used to enhance our global ethics and integrity programs.

IBM’s commitment to ethics and integrity leadership does not end with our employees, however. We also provide online ethics and integrity education to our business partners’ and suppliers’ employees, as part of their partnership commitment to IBM. In 2014, IBM extended its online education offerings to nearly 15,000 representatives from our business partners and suppliers around the world. And since 2013, IBM’s chief trust and compliance officer has delivered an address at our Global Business Partner Leadership Conference (PartnerWorld®) on the value of ethics and integrity. In 2014, the presentation “Why Integrity Matters — Mitigating Regulatory and Other Risks” was delivered to more than 1,400 business-partner employees at this event. Also in 2014, IBM’s compliance team delivered in-person ethics and integrity training to more than 800 supplier employees representing 500 supplier entities across 22 cities.

Consistent with our commitment to the communities in which we do business, IBM collaborates with universities to deliver ethics and integrity seminars. In 2014 we partnered with US universities to support the Young African Leadership Initiative (YALI) Fellow program. YALI is sponsored by the US Department of State and hosts 500 young African leaders for six weeks of networking and skills-building programs in business, entrepreneurship and public policy at US universities, commencing with a session in Washington, DC, and a meeting with President Obama. IBM contributed faculty to four of the business- and entrepreneurship-sponsoring universities — University of Notre Dame, Yale University, University of Texas and Clark Atlanta University — to conduct a seminar entitled “Ethical Leadership & Business Integrity — Creating a Culture of Trust.” This seminar reached more than 100 YALI fellows during their skills-building visit. IBM also conducted seminars on creating a culture of trust at other universities in the United States and the Czech Republic.

Just as we have done for many years, IBM intends to continue its tradition of teaching, listening and collaborating with all our constituents around the world for many years into the future.

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President Obama’s message to the Young African Leaders Initiative applicants.