Boeing

Ethics & Compliance

At Boeing, we believe that the same behaviors that drive strong performance – leadership, openness, accountability and inclusion – also enable a robust and effective ethics and compliance program. Ensuring that the Boeing values remain foundational to our work reflects a daily commitment from every employee who wears a Boeing badge. This message is delivered by the chairman each year with a videotaped message to every employee, and in numerous external remarks given by senior leaders in various forums.

While each employee is accountable for upholding our 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 four key functions: Ethics and Business Conduct, Global Trade Controls, Corporate Audit and Compliance Risk Management. These organizations constitute the Boeing Office of Internal Governance (OIG).

This integrated group creates a sustainable advantage for Boeing by enabling compliant company performance while building on its legacy of integrity. The nearly 500-person team of professionals focuses on:

  • Advancing an open, accountable and transparent culture;
  • Independently and objectively evaluating processes and controls;
  • Leveraging One Boeing through strong integration and collaboration;
  • Applying expertise, business acumen and strong functional discipline; and
  • Educating, training and informing Boeing employees worldwide.

 

Leadership Matters

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.

OIG’s ethics group provides 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.
  • Leadership messages on video that continually reinforce a strong tone from senior leaders

Other materials such as “Engineers: Excellent by Design” are designed to celebrate and encourage interest in engineering and demonstrate how integrity is an inherent part of our company, products, culture and people.

concentric circles of performance, ethics and compliance, and diversity

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

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. 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, as leaders, are responsible for compliance within the areas they oversee, and, along with all employees, receive annual training on major compliance issues that are applicable to their jobs, such as Department of Defense procurement rules, Federal Aviation Administration regulations or the Foreign Corrupt Practices Act. 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.

world map

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 OIG’s 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 +971 56 401 5692
SE Asia & Australia +61-7-3306-3400
North Asia +61-7-3306-3400