Boeing

Overview

Ensuring that our values remain foundational to our work requires a daily commitment from every Boeing employee. This clear message on the importance of integrity in everything we do is delivered by Boeing’s chairman during an annual live broadcast to every employee, and by other senior leaders in various internal and external forums.

While each employee is accountable for upholding the code of conduct and following all applicable laws, regulations and company policies, Boeing advances its unified approach to ethics and compliance through the integration of key functions: Ethics and Business Conduct; Global Trade Controls; Corporate Audit; Compliance Risk Management; Corporate & Administrative Services which maintains an enterprise system for all policies, procedures and processes; and, the company’s Shared Services group.

These functions and operating groups constitute the Boeing Office of Internal Governance and Administration and represent over 7,500 employees worldwide, including more than 7,000 employees who work in Shared Services. As an integrated organization, this global team ensures the effective and efficient support across Boeing’s businesses through implementation of the company’s internal governance policies and plans, as well as providing common infrastructure and services.

This structure creates a sustainable advantage for Boeing by enabling compliant company performance that is embedded consistently across all geographic locations while building on the company’s 100 year old legacy of integrity.

quote

“The work we do matters—and the way we do it matters just as much—to the people who travel in our commercial airplanes, the men and women in uniform who rely on our defense products, and the astronauts pushing the boundaries of space. Lives depend on what we do, and that demands excellence and the utmost integrity.”

Dennis A. Muilenburg
Chairman, President and Chief Executive Officer
The Boeing Company

Dennis A. Muilenburg

Leadership Matters

concentric circles of performance, ethics and compliance, and diversity

Leadership Matters is a companywide initiative that focuses on enabling a culture of openness and accountability in order to sustain an ethical and compliant work environment and enhance business performance. The intent is to embed ethical decision-making into all aspects of business, and equip managers and employees with tools to confidently address ethics-related matters, and to raise questions without fear of retaliation.

The ethics and compliance groups provide a range of tools and resources to help managers and employees discuss ethics issues and regularly practice ethical decision-making skills. The tools and resources include:

  • Workplace case studies based on actual events
  • Staff meeting materials that drive openness, trust, and personal accountability, and encourage speaking up without fear of retaliation. Additional topics are provided to help employees respond ethically when faced with normal business pressures, such as workforce shifts, and cost or schedule constraints.
  • Training refreshers on company procedures and policies

Code of Conduct

The Code of Conduct establishes behavioral expectations for Boeing employees at all levels of the company – wherever we are in the world. Along with the Boeing Values, the code serves as the foundation for our workplace culture and provides the basis for the way we conduct business.

While we are committed to performing all business in accordance with relevant laws and regulations and provide our employees with a robust set of internal policies, we believe that it is our commitment to operating with integrity that ensures our long-term business success.

Every year from January to February, managers and employees meet to review and discuss Boeing expectations to keep promises, hold ourselves and each other accountable, and model ethical behavior. As part of these discussions, all employees reaffirm their personal commitment by annually signing the code of conduct and acknowledging their responsibilities to ask questions, seek guidance and to raise concerns about potential violations.

The code is available in English and nine other languages.

Compliance

world map

Complying with external regulations and our own strong internal policies and procedures is not only the right thing to do, it is vital to the ongoing success of our company. To ensure we maintain effectiveness in this area, compliance monitoring and assessments are built into all levels of the business.

Senior leaders of every Boeing business and function are responsible for identifying, analyzing, raising and addressing key compliance issues. They do this through the Compliance Risk Management Board, which is chaired by the senior vice president of the Office of Internal Governance and Administration. This oversight body enables the company to identify risk areas and ensure consistent actions across the company in order to remain compliant. It also facilitates cross-enterprise discussion to support proactive management of emergent risks.

Managers are responsible for compliance within the areas they oversee, and along with all employees, receive annual training on compliance risk areas related to their work. This includes training for a range of topics such as U.S. Defense Department procurement rules, proper handling of sensitive information and anti-corruption.  Each year, managers complete an online compliance training questionnaire for their respective employees. Based on manager responses, the system generates individualized training plans that support the kind of work the employee performs.

Boeing uses ongoing monitoring to track and assess effectiveness of internal controls and processes in meeting compliance goals. From the company’s most senior leadership to its newest workers, Boeing employees are committed to keeping compliance a core element of everything we do.

Speaking Up

Hands Raised

Speaking up is a cornerstone for building an open and accountable workplace culture. At Boeing, we believe that creating an environment where employees are comfortable raising issues and concerns without fear of retaliation enables openness which can lead to improved business performance and inspire greater innovation. Boeing maintains policies and procedures to encourage employees to report concerns and seek guidance, using confidential and, when preferred, anonymous methods, including contacting local ethics advisors, using toll-free phone numbers and accessing web-based portals. Retaliation against employees who raise concerns is not tolerated and is cause for appropriate corrective action, up to and including dismissal.

Boeing promotes awareness of the company’s reporting system and non-retaliation policies in recurrent employee communication, command media and posters that are displayed in high-traffic work areas across the enterprise. Managers also are asked to encourage speaking up within their own teams by using materials and resources developed by the ethics group to foster dialogue and increase openness. As part of the company’s Speaking Up initiative, managers and employees have access to a series of modules with supplemental team activities that emphasize the importance of speaking up, listening, and taking action. Electronic cards, or e-cards, can be used by all employees to recognize colleagues for speaking up and demonstrating leadership.

How to Contact Ethics

The Boeing Ethics Line is staffed during business hours, five days a week, and is available to all Boeing employees at all levels from anywhere in the company, including subsidiaries. Advisors are available to listen to and act upon concerns expressed by callers about possible violations of laws, regulations, or company policies. Ethics executives and advisors are assigned to business units and organizations, and are located globally to provide guidance regarding proper behavior in the workplace.

24-hour access to the Boeing web allows U.S. employees to confidentially submit questions and concerns. Individuals may submit information anonymously or self-identify. Due to European legal requirements, we cannot accept submittals from individuals in the European Union. Any issues involving an employee based outside the U.S.; concerns alleged to have occurred at a non-U.S. location; or an individual (regardless of nationality) who is calling from outside the U.S. must use the telephone numbers listed below for the appropriate region. Individuals calling from the U.S. should use: 1-888-970-7171.

Non-U.S. Americas 253-657-5304
Europe, Israel, Turkey +44 (0) 7584 517029
Middle East, Russia +971 56 401 5692
India, Africa +91 11 4656 6046
SE Asia & Australia +61-7-3306-3400
North Asia +61-7-3306-3400

Anti-Corruption Program

Boeing strictly forbids bribery and corruption of any kind. It is imperative that we compete on the merits alone. Integrity is a core company value and in support of it, Boeing provides employees and other stakeholders with clear guidance and detailed procedures to ensure compliance with the U.S. Foreign Corrupt Practices Act and other global anti-corruption laws and regulations. This guidance is clear that we must never sacrifice our ethical principles to win or keep business—that no business is worth it.

Our anti-corruption program is organized into nine areas and includes extensive controls tested regularly to ensure effectiveness. Employees are encouraged to report concerns and potential issues. Confidential and anonymous reporting methods are provided. Retaliation against reporting parties is strictly prohibited, and action is taken against violators of anti-retaliation policies. The company also makes its employees aware of their federally protected whistleblower rights which are designed to protect employees against retaliation for reporting potential wrongdoing by a U.S. contractor or subcontractor.

Competing Globally with Honesty, Integrity and Compliance

Boeing’s anti-corruption program is organized into nine areas, and reflects the company’s commitment to competing globally with honesty, integrity and in full compliance with all applicable laws and regulations. Detailed policies and procedures govern each area and demonstrate the company’s zero tolerance for corruption, applicable to employees at all levels and in every location where we operate. Program risk is assessed throughout the year, and results are shared at the company’s executive council and board levels. Assessment results are used to make improvements to further strengthen the program and sustain effectiveness.

Business Courtesies, Giving and Receiving

Boeing employees are required to be vigilant in ensuring that any business courtesy is reasonable, lawful and fully justified under the circumstances, and does not suggest the appearance of impropriety. Company policies and procedures strictly prohibit offering any courtesy that could be misinterpreted as an attempt to gain an improper business advantage, and include elevating thresholds of management approval. Before any courtesy is offered, an employee must determine that it is lawful and appropriate and would not cause embarrassment to the company or recipient.

Additionally, employees must follow strict guidelines when determining if an offered courtesy can be accepted. Employees are prohibited from soliciting courtesies, or accepting any courtesies when a real or perceived attempt is being made to influence action by Boeing.

Employment Decisions

Boeing policies and procedures require that all hiring decisions be made fairly, ethically and in accordance with all relevant laws and regulations. Additional precautions, including Law Department review, are taken for hiring decisions involving current or former non-U.S. government officials, representatives of non-U.S. airlines, officials of public international organizations and their relatives.

Financial Controls, and Books and Records

The Boeing financial management system is designed to assure, among other things, that company resources are effectively and efficiently managed and that reporting requirements are satisfied with integrity and reliability and in compliance with all relevant laws, regulations and generally accepted practices and principles. Specific to anti-corruption controls, all employees are required to maintain accurate financial records and appropriately document and obtain approval of costs and expenses. Employees may not approve expense reports for themselves or their peers. Use of company credit cards for non-business expenses is strictly prohibited. Personal credit cards may not be used for business expenses, except in very limited circumstances. Company policy prohibits falsification of accounting or other business records.

Grants, Business Donations, Sponsorships, Memberships

Boeing makes investments in communities where employees live and work through charitable grants, in-kind donations, sponsorships, volunteer time and memberships to various organizations in order to promote positive and sustainable change. Boeing policy requires that all grants, business donations, sponsorships and memberships be made in an ethical manner and in accordance with all laws and regulations. All requests for payments or donations to support an organization or project outside of the United States are reviewed by the Law Department.

International Consultants

Boeing recognizes that good business practices include drawing on the expertise of outside consultants and professional service providers. To ensure those relationships comply with applicable laws, the company has detailed requirements for creating, maintaining and renewing consultant relationships. The company conducts appropriate due diligence based on the consultant’s statement of work and geographic location, and renews that due diligence at appropriate intervals. All consultant agreements require strict compliance with applicable laws and with Boeing’s ethical business conduct guidelines. Hiring, renewing or expanding the scope of work of any consultant requires multi-layer executive management approvals and review by the Law Department.

Additionally, Boeing takes seriously its industrial participation commitments, and when warranted, engages service providers to help Boeing ensure it meets those commitments. Boeing policy requires that proposed industrial participation service providers undergo the same degree of due diligence and approvals as described above.

Mergers and Acquisitions

Boeing pursues mergers, acquisitions, joint ventures and equity investments when such transactions fit with the company’s strategic and operating objectives. All such transactions are accompanied by comprehensive due diligence to examine rigorously the books, records, corporate filings, operations and compliance history of the candidates for the transactions.

Non-sale Agreements (including Teaming Agreements)

Boeing policy sets out detailed procedures for review and approval of teaming agreements and other non-sales agreements with companies, including appropriate levels of due diligence to ensure compliance with the U.S. Foreign Corrupt Practices Act and other applicable anti-corruption laws. Terms and conditions in those agreements must include warranties of compliance with all applicable anti-corruption laws.

Non-U.S. Political Contributions

Boeing maintains detailed requirements for all political activities inside and outside the United States. For activities outside the United States, Boeing policy prohibits company contributions to political candidates, political parties and party officials, and political advocacy groups. This prohibition covers both monetary contributions and in-kind donations.

Supplier Management

Boeing contracts with suppliers around the world to provide products and services in support of its diverse business portfolio. Company policies and procedures are designed to ensure that supplier relationships follow the highest standards of ethical business conduct. Appropriate due diligence is conducted for potential suppliers. The terms and conditions in all supplier agreements require that suppliers provide assurance of compliance with all applicable anti-corruption laws, granting Boeing contractual rights in the event of a breach. Additionally, company procedures prohibit employees from soliciting gifts from suppliers or having any contact with suppliers that would give rise to even the appearance of impropriety, and require all employees to comply with anti-kickback laws and regulations.