Judgment people
can account for.

Decisions and conflicts

Disclose a personal, financial or other interest that could affect a corporate decision. The person managing the engagement should determine how the conflict is recorded and managed, including whether someone else should make the decision.

Do not misrepresent authority, capabilities, ownership, service availability or the status of a commercial relationship. Represent the relevant entity clearly.

Payments, gifts and benefits

Do not offer or accept a bribe, kickback or improper advantage, directly or through an intermediary. Gifts, hospitality and third-party fees must have a legitimate purpose and must not influence a decision improperly.

Question requests for off-record payments, false descriptions or an unrelated beneficiary. Record transactions accurately and obtain the approvals appropriate to the engagement.

Raising a concern

A useful report identifies the relationship, people or entity involved, what happened, when it happened and how the reporter knows. Distinguish observed facts from an inference. Send only information you are entitled to share.

We expect people to be able to raise concerns in good faith without retaliation. Access should be limited to those who need to assess or resolve the matter; absolute confidentiality cannot be promised where disclosure is required by law or necessary for a fair review.

The form below requires a reply address so clarification is possible. It is not an anonymous reporting service. If your concern involves the person who normally handles your relationship, say so in the first line so an alternative reviewer can be considered.