Sustainability at PPG
Ethics and Compliance
For more than 130 years, PPG’s reputation has been rooted in a steadfast commitment to the highest standards of ethics and rigorous compliance to ethics principles. PPG’s commitment to perform with integrity is instilled in employees as an expectation of behavior guided by the PPG Global Code of Ethics (the “Code of Ethics”).
Code of Ethics Update
The Global Ethics and Compliance Committee, under the leadership of PPG’s CEO, reviews and reinforces the Code of Ethics on a regular basis to ensure that it is consistent with evolving global standards as our businesses grow globally. PPG utilizes three regional sub-committees to promote global consistency and drive regional stewardship of its corporate compliance and ethics program. In 2014, the company enhanced two key compliance programs to further improve our controls and processes:
Export Compliance Program
PPG’s End Use Screening procedure was revised in 2014, enabling PPG’s businesses to focus on ensuring compliance in transactions and further implement PPG’s export compliance program requirements. Additionally, the classification and licensing procedures were revised to take into account the export control reform initiative the U.S. government launched at the end of 2013. PPG also closely monitored sanctions imposed by the U.S. government on Russia and trained employees across its businesses accordingly. Finally, more than 12,000 employees globally participated in export control training, delivered through online and face-to-face training sessions.
Key enhancements to PPG’s global anti-corruption program were introduced in 2014, including an expanded risk assessment of PPG’s global third-party intermediaries and increased training and communication to support our global gift and entertainment policies. Initially introduced in 2012, the global third party intermediary program focused on commissioned-based sales agents and included robust due diligence, stronger anti-corruption contract requirements and proof of service requirements. In 2014, the company undertook a risk assessment of other global third party intermediaries in order to add them to the intermediary management program. All regions and businesses were engaged in the risk assessment. Online anti-corruption training for key intermediaries was added to the program, and internal audits were conducted in a number of locations to monitor compliance with the program.
Ethics and Compliance Training
Our ethics and compliance calendar ensures that our employees receive regular and practical training on their ethics and compliance responsibilities. In 2014, highlights of our training included:
Educated nearly 32,000 employees from across the world on compliance risks specific to their job responsibilities related to the Code of Ethics, Export Control, Anti-Corruption and Competition Law.
Conducted live training workshops across the globe for more than 2,400 employees on topics such as compliance overview, Code of Ethics, anti-corruption, export control, intellectual property, anti-trust, security and commercial contract compliance.
Ethics Hotline Reporting
PPG has an open reporting environment and expects employees to raise any ethics or compliance related questions or concerns. The company offers several reporting channels for employees to use. Specifically, PPG has an anonymous Ethics Hotline that is available to employees in 51 countries, 24 hours every day. The phone numbers are also available on PPG’s internal and external Ethics websites so that anyone, including customers and suppliers, can report potential ethics violations by PPG employees and seek advice and assistance.
Employees are also offered other avenues to communicate their concerns or questions by contacting PPG’s “Ask the Experts” online resource, their supervisor, Human Resources representative, and Chief Compliance Officer. All of these reporting channels are posted on the Ethics intranet.
PPG has several processes in place to monitor for breaches of customer privacy and losses of customer data. Incidents are reported to the global information technology service desk or the IT security team, both of which operate 24/7. Critical incidents, including reports of potential data loss or lost or stolen personal computers, follow a security incident procedure when reported to the team. In addition, PPG uses incident problem reporting processes, including PPG’s confidential Ethics Hotline, that alert PPG’s security team. There were no complaints regarding breaches of customer privacy and losses of customer data in 2014.
PPG is committed to addressing human rights issues. PPG’s position on freedom of association and collective bargaining is available in its Code of Ethics. The Code of Ethics also pledges that PPG will ensure child labor is not used and the minimum age of all employees complies with applicable local laws. The company has also committed that it will never use forced labor in any form.