THE COMPANY'S ETHICS & COMPLIANCE TEAM PLAYS A CRITICAL ROLE IN CUMMINS' SUSTAINABILITY.
The team helps employees live the company's Integrity value, to "do what is right and what we say we will do."
High on the group’s list in 2016: updating the Company’s Code of Business Conduct. Vice President of Ethics & Compliance Mark Sifferlen wants to make sure the code remains relevant to employees.
“People and circumstances change, so we have to continually do everything we can to help our employees understand the importance of ethical behavior,” Sifferlen said.
REVIEWING SUPPLIERS AND THIRD PARTIES
One of the major tasks undertaken by Ethics & Compliance in 2015 was to review thousands of Cummins suppliers to determine if the actions of any represent a legal or reputational risk to the company.
As a global corporation, Cummins relies on a number of external companies and vendors to sell and service its products, bid on business, obtain licenses and permits, and interact with officials to move products across borders. This group includes independent distributors and dealers, sales agents, consultants, customs brokers, and a number of other people – as many as 10,000 suppliers and third parties in all.
Ethics & Compliance put a special focus in these areas and used screening agencies, which have their own databases based on court records, media reports and other documents, to conduct an initial review. In a few cases, “boots on the ground” research was required to resolve questions. The team prioritized the results and put together remedial action plans where necessary, but in general didn’t find many critical issues.
SUPPLIER CODE OF CONDUCT
Cummins’ Supplier Code of Conduct applies to all businesses that provide products or services to Cummins and its subsidiaries, joint ventures, divisions or affiliates.
Available in 15 languages, the supplier code is built around seven principles and helps Cummins ensure that it’s doing business with other companies around the world that share its values for sustainable practices.
All new suppliers receive a copy of Cummins’ Supplier Code of Conduct and the company encourages them to adopt it. If the supplier already has a code that at least meets Cummins’ minimum requirements, it sometimes is allowed to use its existing code.
Cummins’ top suppliers, who collectively receive about 80 percent of the company’s total spending, are required to certify their intent to comply with Cummins’ Supplier Code of Conduct.
The company in 2016 is working to make available to suppliers Cummins’ policies relevant to the supplier code to help drive home the code’s importance to Cummins.
Cummins uses a comprehensive compliance training program to ensure employees understand the Code of Business Conduct and company policies that support the code’s 10 ethical principles. The training program also emphasizes to employees the important role they play in enforcement of the code.
Employees can report any problems they see on line or via a toll-free hotline – anonymously where permitted by law.
Using the Cummins Learning Center, Ethics & Compliance can target specific professional and administrative employee groups with the training most important to them and their job function. The employees receive an email when it’s time to take an appropriate ethics training and then the training is delivered on line.
More than 15 courses are offered as part of the company’s compliance training, ranging from Anti-Bribery to Careful Communications and Treatment of Each Other at Work.