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.


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.

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.

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.

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.

Data privacy

As a globally integrated enterprise, IBM's business processes frequently extend beyond the borders of one country. Such globalization demands not only the availability of communication and information systems across the IBM group of companies (IBM), but also the world-wide processing and use of multiple types of information, including Personal Information.

IBM is 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 assist 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, including the general principle of Privacy by Design. These general principles apply to the processing of Personal Information world-wide by IBM.

The general principles are:

IBM will collect and process Personal Information fairly, lawfully, and in a transparent manner.

Purpose Limitation:
IBM will only collect Personal Information that is relevant to and necessary for a particular purpose(s) and will only process Personal Information in a manner that is not incompatible with the purposes for which it is collected.

Data Minimisation:
IBM will only process Personal Information that is adequate, relevant and not excessive for the purpose for which it is processed.

IBM will keep Personal Information as accurate, complete and up-to-date as is necessary for the purpose for which it is processed.

IBM will keep Personal Information in a form that permits identification for no longer than necessary for the purpose for which such Personal Information was collected.

IBM will only make Personal Information available inside or outside IBM in appropriate circumstances.

IBM will implement appropriate technical and organizational measures to safeguard Personal Information and will 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.

Individual Rights:
IBM will provide individuals with appropriate rights such as right of access and correction relating to their Personal Information, as set out in the Binding Corporate Rules and in applicable law.

IBM will have appropriate policies and practices for the safe handling of Personal Information that it processes on behalf of its customers.

IBM will have appropriate governance, including corporate instructions, guidelines, appropriately trained personnel and other measures to be able to demonstrate that the processing of Personal Information is performed in compliance with this Policy Letter.

IBM Employees who come in contact with Personal Information must act consistently with the principles contained in this Policy Letter.

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.

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.

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:

-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.


IBM is committed to the goal of achieving the highest standards of quality. Quality forms the basis of our value proposition, our brand image and is the cornerstone upon which IBM builds lasting relationships where we are essential to our clients' success.

The client’s perception of IBM and its offerings, products and services is the lens through which quality will be evaluated in the marketplace. Our goal is to deliver value to our clients each time they interact with IBM directly or through our business partners in all the geographic markets we serve. IBM listens to client feedback and uses the insights to improve client experience and quality. The client’s decision to choose and recommend IBM to their business partners, colleagues and friends will be part of how IBM will measure success.

IBM leaders are responsible for understanding how clients interact with IBM, for defining measurements and improvement targets, and for driving actions to achieve quality goals. All IBMers are expected to model the nine IBM Practices that define everything we do on behalf of the company.

IBM human rights principles

Visit the IBM human rights principles page

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.

Freely chosen employment / Young workers / Management system

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.

Young Workers

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.

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, 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.

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, 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.

Non-discrimination and harassment

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.

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 abuse, physical coercion or harassment. Disciplinary policies and practices in support of these requirements shall be clearly defined and communicated to workers.

Freedom of association

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.

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 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.

Protection of the environment

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.

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. 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.

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.


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.

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.

Management System

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.

Original signed by:

D.J. Gherson
Senior Vice President, Human Resources

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.

IBM Impact Grants

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

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.

Matching 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.

Grant guidelines

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

IBM Cognitive Principles

We are in the early days of a promising new technology, and of the new era to which it is giving birth. This technology is as radically different from the programmable systems that have been produced by the IT industry for half a century as those systems were from the tabulators that preceded them.

Commonly referred to as artificial intelligence, this new generation of technology and the cognitive systems it helps power will soon touch every facet of work and life – with the potential to radically transform them for the better. This is because these systems can ingest and understand all forms of data, which is being produced at an unprecedented rate. Cognitive systems like IBM’s Watson can reason over this data, forming hypotheses and judgments. Most importantly, these systems are not simply programmed, they learn – from their own experiences, their interactions with humans and the outcomes of their judgments.

As with every prior world-changing technology, this technology carries major implications. Many of the questions it raises are unanswerable today and will require time, research and open discussion to answer. But at IBM, we have learned something over 100 years of inventing and introducing transformative technologies and of guiding their responsible adoption and use. This experience has taught us that it is both pragmatic and wise to establish principles to guide what we develop and bring to the world, and how we do so.

Today we are establishing the following principles for the Cognitive Era:

Purpose: The purpose of AI and cognitive systems developed and applied by the IBM company is to augment human intelligence. Our technology, products, services and policies will be designed to enhance and extend human capability, expertise and potential. Our position is based not only on principle but also on science. Cognitive systems will not realistically attain consciousness or independent agency. Rather, they will increasingly be embedded in the processes, systems, products and services by which business and society function – all of which will and should remain within human control.

Transparency: For cognitive systems to fulfill their world-changing potential, it is vital that people have confidence in their recommendations, judgments and uses. Therefore, the IBM company will make clear:

  • When and for what purposes AI is being applied in the cognitive solutions we develop and deploy.
  • The major sources of data and expertise that inform the insights of cognitive solutions, as well as the methods used to train those systems and solutions.
  • The principle that clients own their own business models and intellectual property and that they can use AI and cognitive systems to enhance the advantages they have built, often through years of experience. We will work with our clients to protect their data and insights, and will encourage our clients, partners and industry colleagues to adopt similar practices.

Skills: The economic and societal benefits of this new era will not be realized if the human side of the equation is not supported. This is uniquely important with cognitive technology, which augments human intelligence and expertise and works collaboratively with humans. Therefore, the IBM company will work to help students, workers and citizens acquire the skills and knowledge to engage safely, securely and effectively in a relationship with cognitive systems, and to perform the new kinds of work and jobs that will emerge in a cognitive economy.

Our experience over more than a century and our daily work with clients from every industry and sector around the world have taught us that transparency and principles that engender trust are important for both business and society. However, we also recognize that there is much learning ahead for all of us. In that spirit, we hope that our publication of these tenets can spark an industry-wide – indeed, a society-wide – dialogue on the fundamental questions that must be answered, in order to achieve the economic and societal potential of a cognitive future.

In effect since January 17, 2017.

IBM supports animal care resolution

IBM and its employees have long been widely recognized for exemplary behavior by providing life-saving blood products across the tri-state area and around the world. IBM believes strongly in the mission of blood collection agencies. At the same time, IBM also believes in the humane care and treatment of animals, including the chimpanzees New York Blood Center (NYBC) used in research experiments in Liberia over a 30-year period. While the NYBC provided care for a period of time, it terminated funding for the 66 surviving chimpanzees in March 2015, transferring the financial burden for their care to animal welfare organizations that had no involvement in the research. Our company strongly urges the NYBC to work with the government of Liberia, Humane Society of the United States, and other charitable organizations to find a sustainable, long-term solution to ensure the health and well-being of the chimpanzees. While IBM does not provide monetary donations to the NYBC or any donated space for collection, IBM has suspended its support of NYBC blood drives in New York while the NYBC works with all deliberate speed to implement a long-term solution to this issue.
May 2017