Sustainability at PPG
Ethics and Compliance
Overview of management approach to ethics
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 2013, the company enhanced two key compliance programs to further improve our controls and processes.
Export Compliance Program
With a focus on continuous improvement in our program, we enhanced the global compliance screening tool and classification processes. Additionally, we simplified our end use screening process and updated our policies based on the new export control reform initiative. Internal audits were conducted to assist in affirming that these improvements were implemented effectively and achieved desired objectives. Over 8,000 employees globally participated in export control online or face-to-face training sessions.
PPG’s global anti-corruption program was enhanced last year with the increased focus on PPG’s third party intermediary program. Initially introduced in 2012, the global program includes robust due diligence, stronger anti-corruption contract requirements and proof of service requirements for all commission-based sales agents. Internal audits were conducted in a number of locations to monitor compliance with the program. All regions were actively engaged in this initiative, including preparing for a second phase to address the risks associated with a range of other intermediaries. In addition to targeted live training on the risks presented by these third parties (which represent PPG with both government and commercial customers), the company also provided online training on its Anti-Corruption policy and program to over 17,500 employees worldwide.
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 2013, highlights of our training included:
PPG Ethics Hotline Reporting
Educated nearly 25,000 global employees from across the world on compliance risks specific to their job responsibilities related to the Code of Ethics, Export Control, Competition Law and Anti-Corruption.
Conducted live training workshops in Australia, China, Colombia, France, India, Korea , Malaysia, Mexico, Puerto Rico, Russia, Singapore, Switzerland, U.S., Thailand and Vietnam for more than 1,500 employees on topics such as Compliance and Controls, Code of Ethics, anti-corruption, export control, intellectual property, anti-trust, risk management and commercial contract compliance.
Held face-to-face ethics and compliance training for employees who joined PPG as the result of acquisitions, including the AkzoNobel North American architectural coatings business, and the Spraylat Corp., and Deft Inc. businesses. Our integration efforts included introduction courses on the Code of Ethics, Anti-Corruption, Export Control and Competitor Contacts. These efforts ensure all employees understand our culture of integrity as PPG continues to grow—regionally and operationally.
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 hotline 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 substantiated complaints regarding breaches of customer privacy and losses of customer data in 2013.
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.