Doing
the right thing,
every time
Worldwide Business
Conduct Manual
Letter from
Our CEO
Contents
Our PVPs
Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
1 of 60
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Contents
Letter from Our CEO
3
Our Purpose, Values & Principles (PVPs)
4
Our Purpose
5
Our Values
6
Our Principles
7
Doing the Right Thing – P&G and Me
8
Why Do We Have a Worldwide Business Conduct
Manual?
9
What is Expected of Me?
10
Consequences of WBCM Violations
11
Additional Expectations for Managers of Others
11
We Speak Up – Raising Questions
and Concerns
12
Recognizing the Right Thing to Do
13
Where Can I Raise Questions and Concerns?
14
Contact the Worldwide Business Conduct Helpline
15
Handling Reports
16
Retaliation is Not Tolerated
17
Cooperating with Investigations
18
Q&A
19
Committed to Respect
20
Promoting Respect in Our Workplace
21
Diversity and Inclusion
21
Non-Discrimination
21
Preventing Harassment
21
Ensuring Workplace Health and Safety
22
Workplace Health and Safety
22
Violence in the Workplace
22
Drug and Alcohol Use
22
Ensuring Fair Employment Practices
23
Child Labor and Forced Labor
23
Wage and Hour Practices
23
Freedom of Association
23
Q&A
24
Committed to Stewardship
25
P&G Information
26
Keeping P&G Information Secure
26
Records & Information Governance
27
P&G’s Intellectual Property
28
Proper Use of P&G Assets
29
P&G Technologies and Electronic Communications
29
Social Media
30
Physical Property
31
External Party Information
32
Privacy Safeguards
33
Personally Identifiable Information (PII)
33
Employee Data Privacy
33
Consumer Data Privacy
33
Protecting the Environment and Safety of P&G
Products
34
Protecting the Environment
34
Ensuring Product Quality and Safety
34
Communicating with Media and Analysts
35
Q&A
36
Committed to Integrity
37
Responsible Sales and Marketing Practices
38
Maintaining Accurate Books and Records
39
Complying with Competition Laws
40
Interacting with Competitors
41
Interacting with Customers
42
Interacting with Suppliers and Agencies
43
No Bribery
44
Preventing Bribery and Corruption of Government
Officials
44
No Commercial Bribery
45
Preventing Money Laundering
46
Government and Trade Controls
47
Work on Government Contracts
47
Imports and Exports
47
Boycotts and Restricted Countries
48
Handling External Party Information
49
Gathering Competitive Information
49
External Party Intellectual Property and
Commercial Rights
49
Avoiding Insider Trading
50
Handling Potential Conflicts of Interest
51
Disclosing Conflict of Interest
51
Gifts and Business Entertainment Guidelines
52
Interacting with the Government
53
Lobbying
53
Political Involvement and Contributions
53
Q&A
54
Resources
56
Reporting Concerns
57
Contact Information for Reporting
57
Worldwide Business Conduct Helpline
57
Global Security
58
Ethics & Compliance Committee and Office
58
Corporate Secretary
59
Letter from
Our CEO
Contents
Our PVPs
Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
Worldwide Business
Conduct Manual
2 of 60
Dear P&Gers,
Letter from
Our CEO
Contents
Our PVPs
Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
Worldwide Business
Conduct Manual
3 of 60
At P&G, our Purpose, Values and Principles (PVPs) are
the foundation of everything we do.
They are what make P&G special. Our Do the Right Thing culture is one of
the reasons I’ve been excited to say for more than 35 years – in any country
and on any business – that I work for P&G.
Our Purpose, Values and Principles set a high standard for each of us. High
standards are good. They require that we hold each other and ourselves
accountable not only for results, but – equally important – for how we
achieve those results.
Doing the right thing, every time, gives consumers, customers, shareholders,
external business partners, government and community leaders, and other
stakeholders a reason to trust us, to believe we achieve our results in the
right way and that we do not tolerate illegal or unethical dealings anywhere
in the world. This trust provides us with real competitive advantage – an
advantage that can be lost by a single illegal or unethical act. I know the
business pressures we face are more intense and more complex than ever
before. Even under these pressures, we must hold to our high standards of
doing the right thing. We cannot afford to do anything that causes people
to lose trust in P&G – our Company, our brands, our products or our people.
Our Worldwide Business Conduct Manual is the one document that describes
our mandatory, consistent, global principles for doing the right thing. Please
read it carefully, and take personal responsibility and accountability for
following the behaviors and policies referenced in it. Bookmark the
website
so it’s easily available for your day-to-day consultation.
If you have questions about business conduct, or if you have concerns
about whether we are following the letter and the spirit of the law in any
P&G business or operation, please talk with your manager, your Human
Resources contact, your P&G Legal counsel, or the Company’s Ethics &
Compliance Office, or contact me directly. You may also report any concerns
through the Worldwide Business Conduct Helpline. We’re committed to
creating a work environment that fosters open communication and supports
employees in reporting their concerns about whether the Company is doing
the right thing.
Thank you
for following the Worldwide Business Conduct Manual every
day, and for doing the right thing, in principle and in practice, as we work
together to win consumers with our leading brands and products.
David S. Taylor
President and Chief Executive Officer
DAVID S. TAYLOR
President and
Chief Executive Officer
Thank you
for doing the
right thing,
every time.
Our Purpose, Values and Principles
Taken together, our Purpose, Values and Principles are the foundation for P&G’s unique culture.
Throughout our history of over 175 years, our business has grown and changed while these elements
have endured, and will continue to be passed down to generations of P&G people to come.
Our Purpose
unifies us in a common cause
and growth strategy of improving
more consumers’ lives in small
but meaningful ways each day.
It inspires P&G people to make
a positive contribution every day.
Our Values
reflect the behaviors that shape
the tone of how we work with
each other and with our partners.
Our Principles
articulate P&G’s unique approach
to conducting work every day.
Letter from
Our CEO
Contents
Our PVPs
Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
Worldwide Business
Conduct Manual
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Our Purpose
We will provide branded products and services of superior quality and value that improve
the lives of the world’s consumers, now and for generations to come. As a result, consumers
will reward us with leadership sales, profit and value creation, allowing our people, our
shareholders, and the communities in which we live and work to prosper.
Letter from
Our CEO
Contents
Our PVPs
Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
Worldwide Business
Conduct Manual
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Our Values
P&G Brands and P&G People are the foundation of P&G’s success. P&G People bring
the values to life as we focus on improving the lives of the world’s consumers.
• We always try to do the
right thing.
• We are honest and
straightforward with
each other.
• We operate within the
letter and spirit of the law.
• We uphold the values and
principles of P&G in every
action and decision.
• We are data-based and
intellectually honest in
advocating proposals,
including recognizing risks.
• We respect our P&G
colleagues, customers and
consumers, and treat them
as we want to be treated.
• We have confidence in
each other’s capabilities
and intentions.
• We believe that people
work best when there is a
foundation of trust.
• We are all leaders in our
area of responsibility,
with a deep commitment
to delivering leadership
results.
• We have a clear vision
of where we are going.
• We focus our resources
to achieve leadership
objectives and strategies.
• We develop the capability
to deliver our strategies
and eliminate
organizational barriers.
•
We accept personal
accountability to meet
business needs, improve
our systems and help
others improve their
effectiveness.
• We all act like owners,
treating the Company’s
assets as our own and
behaving with the
Company’s long-term
success in mind.
• We are determined to be
the best at doing what
matters most.
• We have a healthy
dissatisfaction with the
status quo.
• We have a compelling
desire to improve and to
win in the marketplace.
Integrity
Ownership
Passion
for Winning
Leadership
Trust
CONSUMERS
P&G
BRANDS
P&G
PEOPLE
Letter from
Our CEO
Contents
Our PVPs
Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
Worldwide Business
Conduct Manual
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Our Principles
• We believe that all individuals can and want to
contribute to their fullest potential.
• We value differences.
• We inspire and enable people to achieve high
expectations, standards and challenging goals.
• We are honest with people about their performance.
We Show
Respect for
All Individuals
We Are
Externally
Focused
The Interests
of the Company
and the
Individual Are
Inseparable
• We believe that doing what is right for the business
with integrity will lead to mutual success for both
the Company and the individual. Our quest for
mutual success ties us together.
• We encourage stock ownership and ownership
behavior.
We Are
Strategically
Focused on
Our Work
• We operate against clearly articulated and aligned
objectives and strategies.
• We only do work and only ask for work that adds
value to the business.
• We simplify, standardize and streamline our current
work whenever possible.
Innovation
Is the
Cornerstone
of Our
Success
• We place great value on big, new consumer
innovations.
• We challenge convention and reinvent the way we
do business to better win in the marketplace.
• We develop superior understanding of consumers
and their needs.
• We create and deliver products, packaging and
concepts that build winning brand equities.
• We develop close, mutually productive relationships
with our customers and our suppliers.
• We are good corporate citizens.
• We incorporate sustainability into our products,
packaging and operations.
We Value
Personal
Mastery
• We believe it is the responsibility of all individuals
to continually develop themselves and others.
• We encourage and expect outstanding technical
mastery and executional excellence.
We Seek to
Be the Best
• We strive to be the best in all areas of strategic
importance to the Company.
• We benchmark our performance rigorously versus
the very best internally and externally.
• We learn from both our successes and our failures.
Mutual
Interdependency
Is a Way
of Life
• We work together with confidence and trust
across business units, functions, categories and
geographies.
• We take pride in results from reapplying others’
ideas.
• We build superior relationships with all the parties
who .contribute to fulfilling our Corporate Purpose,
including our customers, suppliers, universities
and governments.
Letter from
Our CEO
Contents
Our PVPs
Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
Worldwide Business
Conduct Manual
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Click here
to learn more
about our Purpose, Values
and Principles.
Doing the Right
Thing –
P&G and Me
Letter from
Our CEO
Contents
Our PVPs
Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
Worldwide Business
Conduct Manual
8 of 60
Why Do We Have a Worldwide
Business Conduct Manual?
Our character has been built on a foundation of integrity,
trust and respect since our beginning in 1837.
Our Worldwide Business Conduct Manual (WBCM) explains the global standards
each of us must follow in our work for P&G. It also explains our legal and ethical
responsibilities. You must follow these standards and the law at all times, and ensure
that you understand how they apply to your work. Our WBCM applies to all
employees and members of the Board of Directors, regardless of location, seniority
level, business unit, function, or region. For this reason, in this WBCM, “P&G” refers
in this document to The Procter & Gamble Company and all of its subsidiaries and
operating units. P&G also expects external parties with whom P&G does business
to follow standards equivalent to our WBCM. If you suspect or observe an external
party doing anything potentially illegal or unethical, especially related to P&G’s
business – for example, under-invoicing or violating competition laws – you must
report this immediately.
Though it contains P&G’s core global standards, our WBCM is not a complete
manual that describes all of the policies and procedures governing every employee
and situation. Check with your immediate manager or local HR manager to
understand whether there are additional policies / procedures you must also follow
in your role.
For more information about how P&G conducts business with external parties, visit
pgsupplier.com
.
Letter from
Our CEO
Contents
Our PVPs
Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
Worldwide Business
Conduct Manual
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RESPECT
STEWARDSHIP
INTEGRITY
What is Expected of Me?
We all have a responsibility to uphold our Purpose, Values, and Principles
in our work and in the business decisions we make.
It is important to keep in mind that certain countries’ laws may apply even when you conduct business outside of those countries’
boundaries. Even when something might be a common practice in your location or within your cultural norms, you need to continue
to apply and follow our WBCM. No one at any level of P&G has the authority to violate the WBCM or any law or regulation, or to
require another employee to do so. If anyone attempts to do so, you must raise this by following the steps set out in
“
Where Can I
Raise Questions and Concerns
.”
We are all expected to follow the provisions outlined in this WBCM. Many provisions cannot be waived for any reason. In those
extremely rare circumstances where you believe that a waiver of the WBCM is needed, you must request approval from the Ethics
& Compliance Committee in advance of any action. Executive officers or members of the Board of Directors who believe that a waiver
is necessary must request approval from the Board of Directors or an appropriate committee of the Board. If such a waiver is given,
P&G will promptly disclose such waiver as required by law.
Letter from
Our CEO
Contents
Our PVPs
Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
Worldwide Business
Conduct Manual
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You are expected
to do the right thing
at all times:
You must not allow
the needs of the
business to justify
doing something that
violates the law or is
inconsistent with
P&G’s PVPs.
You must know and
fully comply with the laws,
regulations, and P&G
policies that apply to
your work, and therefore
must, at a minimum,
complete all Company
training and certifications
required for your role.
You must be alert to
any situations or
actions that may
violate the law, our
WBCM or P&G policies,
and report them
appropriately.
Your actions need to
be consistent with P&G’s
PVPs and our goal
of making the lives of
the world’s consumers better
each day.
What is Expected of Me?
(cont.)
Letter from
Our CEO
Contents
Our PVPs
Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
Worldwide Business
Conduct Manual
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Consequences of Worldwide Business Conduct Manual Violations
Individuals who fail to comply with our WBCM will be subject to disciplinary action, which may include discipline in line with applicable law,
up to and including termination. In some circumstances, legal authorities may impose fines and criminal penalties on individual employees.
P&G may not be able to reimburse or insure employees against these fines / penalties.
Additional Expectations for Managers of Others
You must regularly communicate the importance of our WBCM, applicable laws, ethical conduct and policies to those who report to you.
You must also strive to create a positive work environment in which employees feel comfortable raising questions and concerns about
possible violations of our WBCM or P&G policies and reporting any situations that need to be addressed.
In addition, you must ensure employees who report a suspected violation of our WBCM, P&G policy or the law are protected from any
form of retaliation for doing so. Clearly communicate to those who report to you P&G’s “no retaliation” policy. Take appropriate action
if you believe there is the potential for any form of retaliation by contacting a Human Resources manager or the
Ethics & Compliance Office
.
For more information, see P&G’s Global Policy on Harassment Prevention
& Non-Discrimination at
wbcm.pg.com
.
Letter from
Our CEO
Contents
Our PVPs
Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
Worldwide Business
Conduct Manual
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WE SPEAK UP –
raising questions
and concerns
If the answer to any of these questions is “no,” or you are not sure, do not proceed.
Always ask before
acting. It is never okay to ignore our Purpose, Values, and Principles or our Worldwide Business
Conduct Manual for a business need.
If you encounter situations in which the right choice is unclear
or there is conflicting information, you are expected to seek guidance on how to ensure we do the right
thing in that situation.
You also have a duty to P&G and your fellow P&Gers to report any known or suspected violations
of our WBCM, P&G policy or the law. By making such a report, you are protecting the reputation and
integrity of our Company, our brands and our people.
At the core of P&G is the commitment to doing the right thing. This commitment has
been passed down from generation to generation of P&Gers. If you are ever unsure
about a business action or decision, you should
ask yourself the following questions
:
Recognizing the Right Thing to Do
Letter from
Our CEO
Contents
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Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
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Seek
guidance,
then
re-evaluate
MAYBE
MAYBE
MAYBE
MAYBE
MAYBE
STOP
Look for a better
alternative
NO
NO
NO
NO
NO
YES
PROCEED
YES
Would I
feel comfortable
if it was reported
in the news or
to someone
I respect?
YES
Will it
protect P&G’s
reputation?
YES
Am I being
truthful and
honest?
YES
Is it
legal
?
Does it
comply with
the PVPs,
WBCM and
policies?
Talk to your manager
If you need to raise a question or concern, your immediate manager is likely the best person to
speak to because he or she knows your business unit and your situation.
Talk to another manager
If you are not comfortable talking to your immediate manager, you can discuss the issue with
a higher level manager in your reporting line. Or, you can contact a manager in the
Ethics &
Compliance Office
; Finance & Accounting; Global Internal Audit; Human Resources; P&G Legal;
or Global Security to seek guidance or report your concerns.
Report it in another way
You may also contact the
Worldwide Business Conduct Helpline
; Ethics & Compliance Office;
The Ethics & Compliance Committee; or The Corporate Secretary of The Procter & Gamble Company.
Contact information for the
Ethics & Compliance Office
, Ethics & Compliance Committee and
Corporate Secretary is available in the
Resources
section at the end of our WBCM.
The
Worldwide Business Conduct Helpline
is available around the world 24 hours a day, seven
days a week. It is staffed by an independent company and can take calls in most languages.
When calling the
Worldwide Business Conduct Helpline
, you can report actual or suspected
violations anonymously, where allowed by applicable law. Please keep in mind that it may be
more difficult or even impossible to thoroughly investigate reports that are made anonymously.
You are therefore strongly encouraged to talk directly with a P&G manager, if possible, or share
your identity when making a report via the
Worldwide Business Conduct Helpline
. Protecting
the identity of innocent people and preventing retaliation for people who make reports in good
faith are a priority for P&G.
An HR
representative
A trusted
manager
A lawyer in
P&G Legal
Any
manager in
F&A or Global
Internal
Audit
The Ethics
& Compliance
Office
The P&G
WBCM
Helpline
wbcm.pg.com
Where Can I Raise Questions
and Concerns?
Letter from
Our CEO
Contents
Our PVPs
Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
Worldwide Business
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United States, Canada and Puerto Rico:
1-800-683-3738
Other Locations:
Collect: 1-704-544-7434
Toll free: Go to
www.pg-helpline.com
for a list of direct dial numbers
pghelpline@alertline.com
www.pg-helpline.com
WBCM Helpline
P&GPMB, 3767,
13950 Ballantyne Corporate Place
Charlotte, NC 28277
Phone
Email
Internet
Postal Mail
Contact the Worldwide Business
Conduct Helpline
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Our CEO
Contents
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Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
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P&G has an established process for handling
reports which is intended to ensure the following
outcomes:
Handling Reports
Any person
raising a concern
in good faith
or participating
honestly in an
investigation is
protected from
retaliation
Any person
accused of
wrongdoing is
treated fairly and
objectively
The correct
resources are
assigned so that
all incidents are
investigated
objectively and
resolved
appropriately
When a report is received, an independent investigator will be
appointed to look into the facts and is supported by other resources
needed to conduct an appropriate investigation. Normally this will
involve one or more managers from Human Resources, Global
Internal Audit, the Ethics & Compliance Office, Legal or Global
Security. They will then normally contact the reporter for additional
information. If you have reported anonymously, they can contact
you by leaving a message for you with the Helpline, which you can
then reply to, still maintaining anonymity if you choose. All reports
will be investigated thoroughly and promptly.
Where required by applicable law, anyone accused of wrongdoing
will have the right to access the information reported and to make
corrections in the event of an error.
For more information, see P&G’s
Incident Response Guidelines
at
wbcm.pg.com
.
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Our CEO
Contents
Our PVPs
Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
Worldwide Business
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Retaliation is Not Tolerated
P&G does not tolerate
any form of retaliation
against any person
who reports a suspected
violation in good faith.
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and Concerns
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Right Thing
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In addition, no one who participates or cooperates
honestly and completely in the investigation of a report
will be subject to retaliation for doing so. Anyone who
retaliates against a person for making a good faith
report or for participating in the investigation of a report
will be subject to disciplinary action, which may include
termination. These are not just things we say, but
commitments we actively work against when a report
is made.
Everyone has an obligation to cooperate fully and truthfully with any internal or external investigations into
allegations of misconduct. Failure to do so can result in discipline up to and including termination.
You must always provide truthful and accurate information to P&G personnel conducting an investigation
as well as to government regulators and external auditors. You must never alter or destroy documents
or evidence in order to prevent or hinder any investigation. Not only does destruction of evidence violate
our PVPs, but it can turn a minor matter into a serious violation.
If you are contacted by a government regulator or an external party in connection with a standard
inspection or routine audit, please notify your manager and follow established procedures. If a government
investigator contacts you seeking to visit P&G facilities or obtain information from P&G representatives
about any other matter, you must notify Legal.
Cooperating with Investigations
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Doing the
Right Thing
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Q: 0Andrea feels that her manager treats her unfairly. Can she report this?
A: 0 Andrea can report the situation to another manager or any of the resources
listed in “
Where Can I Raise Questions and Concerns
.” P&G takes all allegations
seriously and follows through with the commitment that all incidents will be
investigated and all reporters will be protected from retaliation.
Q: 0Lucas feels he’s being harassed by one of his co-workers, and he raised
an issue with his manager, Todd. What should Todd do after he receives
this information?
A: 0 It is essential that managers who receive a report, or otherwise become aware
of an incident, know what to do and who to contact to ensure the incident is
thoroughly and promptly investigated. An “incident” means an allegation,
finding, report, event or discovery that suggests that there may have been
violation of the law, WBCM or P&G policy. Incidents may or may not involve
a suspicion of intentional wrongdoing. Todd should immediately report the
incident to any of the resources listed in “
Where Can I Raise Questions and
Concerns
.” Once the incident is reported, specialized resources will be assigned
to investigate the case. As the investigation occurs, it will be important for Todd
and Lucas to respond to requests for assistance in resolving the situation. Todd
will also have the very important responsibility to ensure that Lucas is protected
from any form of retaliation, whether directly or indirectly.
Q: 0One of Lily’s colleagues, Michael, has been talking about how he makes
sure his brother’s firm wins bids for P&G engineering work. Lily is fairly
sure he is operating outside P&G standard procedures, but does not
know for sure. His brother’s firm seems to do a good job. She likes
Michael and has worked with him for a long time, and doesn’t want to
get him into trouble. What should she do?
A: 0 Lily should report her concerns to her manager or any of the resources listed in
“
Where Can I Raise Questions and Concerns
.” Company policies are there to
protect P&G and all P&G people. In our work, we are obliged to act in the best
interests of the Company, even if we think there may be consequences for a
colleague. Our incident management processes are designed to make sure
reports are investigated fairly. If Michael has done nothing wrong, he will
not get into trouble; if he has, the Company will take into account all the
circumstances before taking action.
Raising Questions and Concerns
Letter from
Our CEO
Contents
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Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
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Q&A
Committed to
Respect
VALUING AND LEVERAGING OUR DIFFERENCES
•
BEING INCLUSIVE
•
ENABLING EACH OTHER TO BE OUR BEST
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We treat all
of our P&G
colleagues and
external business
partners with
dignity and
respect.
Promoting Respect in Our Workplace
Diversity and Inclusion
We recruit, hire and retain the best talent from around the world, reflecting the markets and
consumers we serve. Developing and retaining a diverse workforce provides us with a sustained
competitive advantage. We recognize that a diverse mix of backgrounds, skills and experiences
drives new ideas, products and services. This maximizes our ability to achieve our goals.
Non-Discrimination
P&G is committed to providing equal opportunities in employment.
This means you must treat your fellow P&Gers, P&G applicants and external parties with whom
we do business fairly, and you must never engage in any form of unlawful discrimination. You
must follow all anti-discrimination laws, and in your employment decisions (such as recruiting,
hiring, training, salary and promotion), you must not discriminate against individuals on the basis
of race, color, gender, age, national origin, religion, sexual orientation, gender identity, gender
expression, marital status, citizenship, disability, veteran status, HIV / AIDS status or any other
legally protected factor.
Preventing Harassment
We are committed to providing a harassment-free environment, in which we all have an
opportunity to contribute at our highest potential. “Harassment” is behavior that creates an
offensive, intimidating, humiliating or hostile work environment that unreasonably interferes with
another person’s work performance. Harassment may be physical or verbal, and may be done
in person or by other means (such as harassing notes or emails). Examples of harassing behavior
include unwelcome sexual advances or remarks, offensive jokes and disparaging comments.
You must avoid engaging in harassing actions.
For more information, see P&G’s Global Policy on Harassment Prevention & Non-Discrimination
at
wbcm.pg.com
.
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Ensuring Workplace Health and Safety
Workplace Health and Safety
P&G people are our Company’s most valuable asset. Accordingly, we are
committed to the highest standards of safety to protect ourselves, our fellow
P&Gers and external parties who work at or visit our sites.
You must follow all P&G safety and security procedures, as well as applicable
laws and regulations. Nothing justifies working around or ignoring any
safety rule – whether a Company rule, regulation or law. If you are ever
aware of, or suspect, any unsafe working conditions or other safety issues,
you must report the situation to your manager, your site safety leader or
Legal immediately. If you have any concerns about your health at work or
the health of a coworker, you must promptly contact your site Health
Services (Medical) unit.
For more information, visit
healthnet.pg.com
.
Violence in the Workplace
P&G is committed to providing a safe work environment.
You must never engage in or tolerate any form of violence. At P&G,
“violence” includes threats or acts of violence, intimidation of others or
attempts to instill fear in others. No weapons are permitted on any P&G
owned or operated premises, consistent with applicable law.
If you know of or suspect incidents or threats of workplace violence, or if
you believe someone is in immediate danger, you must report your concerns
immediately to the P&G global security contact. Dial
1-513-983-3000
(voice prompt 3)
to be connected to someone immediately. The phone is
answered 24 hours a day, 7 days week by a Global Security Representative,
who will then filter the call to your appropriate P&G Regional Security
Manager. You can also contact your local HR manager or your immediate
manager. A list of security contacts can be found at
globalsecurity.pg.com
.
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Drug and Alcohol Use
We conduct business for P&G in a safe manner, free from the influence
of any substance that could impair our job performance.
You must never use alcohol, illegal drugs, controlled substances or
medication in a way that might harm your ability to conduct P&G business
safely and successfully. You must not let the use of any substance adversely
affect your ability to perform your job, even if you are using a medication
legally. You must never possess drugs that you do not have a legal right to
possess while on P&G property or while working for P&G. In addition, you
must never sell or distribute these substances, or drugs that have been
prescribed for you, whether or not you are doing P&G business, or whether
you are on or off P&G property.
For more information, see
P&G’s Global Policy on Alcohol
& Drug-Free Workplace at
wbcm.pg.com
. You can also
contact Human Resources,
your local Health Services
resource or P&G medical
personnel to discuss your
particular situation.
Ensuring Fair Employment Practices
Child Labor and Forced Labor
P&G forbids the use of child or forced labor in any of our global operations or facilities, and will not tolerate
exploitation of children, physical punishment or abuse, or involuntary servitude. P&G fully respects all applicable laws
establishing a minimum age for employment, in order to support the effective abolition of child labor worldwide,
and does not permit workers under the age of 18 to perform hazardous work. You must not do anything to violate
these principles.
Wage and Hour Practices
P&G follows all applicable wage and hour laws, including minimum wage, overtime and maximum hour rules.
You must never require an employee to violate these laws (e.g., require an employee to illegally work unpaid overtime).
Freedom of Association
P&G respects every employee’s right to choose to join or not to join a trade union, or to have recognized employee
representation in accordance with applicable law. You must not violate these employee rights.
UNFAIR
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Q: 0Lisa is a manager and needs to make a promotion decision. She thinks
that, since Herbert is 50 and nearing retirement age and Iris is only 35
and may stay with P&G for many years, it would be wise to promote
Iris. After all, P&G will invest in training the newly promoted employee
and she wants this investment to be used wisely. Is this a good
employment decision?
A: 0 No. Lisa is making this decision solely on the basis of age, and this is never
acceptable. She needs to make her decision based on merit and without regard
to any non-job-related personal characteristics.
Q: 0Michele’s supervisor tells Michele sexually offensive jokes and comments
on her appearance in a way that makes her uncomfortable. She asks him
to stop, but he laughs and tells her he’s “just kidding around.” Michele
wants to report this, but fears her supervisor will know she did so and
block her upcoming pay increase. What should she do?
A: 0 Michele should report the situation to another manager or any of the resources
listed in “
Where Can I Raise Questions and Concerns
” section immediately. P&G
will protect her from any retaliatory acts, including withheld pay or any other
form of mistreatment due to her report and will take the necessary actions to
ensure that she has the opportunity to work in a harassment-free environment.
We all have the right to work in a safe and positive workplace, and P&G will
work to ensure this goal is achieved.
Q: 0Amon recently injured his back on a hiking trip. His doctor prescribed
a painkiller so he could go on with his daily life. Amon finds that the
medication tends to make him dizzy and some routine tasks, such as
operating machinery, seem difficult. What should he do as he returns
to work at P&G?
A: 0 Before being able to return to work, Amon should obtain appropriate medical
clearance from his doctor and Company medical personnel. It sounds as if the
medication Amon is taking, even though he is doing so legally, could impair
his ability to safely and effectively perform his job. This could place Amon, his
coworkers and even consumers of our products in danger.
Non-Discrimination and Harassment
Drug and Alcohol Use
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Q&A
Committed to
Stewardship
CREATING AND PRESERVING VALUE
•
SAFEGUARDING ASSETS
•
PROTECTING OUR REPUTATION
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“Confidential
information” is
information that is not
available to the general
public, but we know
as a result of our
position with P&G.
P&G Information
Keeping P&G Information Secure
During the course of our work, we may learn confidential information
about P&G. “Confidential information” is information that is not
available to the general public, but we know as a result of our
position with P&G. Confidential information might be of use to
competitors or harmful to our Company if disclosed. We are all
responsible for proper handling of P&G’s confidential information to
prevent the loss of this important asset.
P&G has an information classification system to help us understand
what steps we need to take to protect different types of information,
depending on its sensitivity. We should become familiar with these
classifications, and protect information accordingly. This is especially
important when considering what to share and store electronically.
Among other things, you must not discuss confidential information in
places where you can be overheard, such as elevators and restaurants,
or open areas at P&G such as break rooms. In addition, you must not
leave confidential information, computers, tablets, flash drives or
mobile phones unattended. You must take great care not to disclose
confidential P&G information via social media, and should remember
that competitors and others often gather small bits of information
from a number of employees, and then are able to put these
pieces together to learn something important.
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These obligations of confidentiality also apply – both ethically and
legally – after your employment with P&G ends. When you leave
P&G, you must not disclose or use P&G confidential information.
In addition, you must return all copies of materials or devices
containing confidential information in your possession.
Nothing in this section or the WBCM is intended to prohibit disclosure
made in confidence to a government official or an attorney about a
suspected legal violation; documentation or discussion of employees’
working conditions, wages, hours, benefits, terms and conditions of
employment; or other activities legally protected under applicable law.
For more on protecting P&G information, visit
pgsecurity.pg.com
.
Records & Information Governance
P&G considers records created or received during the normal course of business a P&G asset. This includes documents,
email, spreadsheets, notebooks, photographs and video, regardless of whether they are electronic or hard copy. We must
manage and retain all P&G records according to our P&G Records & Information Management Policy and P&G’s Records
Retention Schedule (RRS).
You are expected to review your records, using the RRS, and destroy any documents that are no longer needed. However,
it is important that you take special care to keep all documents that relate to any imminent or ongoing investigation,
lawsuit, audit or examination involving P&G. This means that you never conceal, alter or destroy (even if past the retention
time in the RRS) any documents or records related to any such inquiries.
For more information, visit
retentionschedule.pg.com
.
P&G Information
(cont.)
P&G considers
records created or
received during the
normal course of
business a P&G asset.
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P&G Intellectual Property
P&G’s Intellectual Property (IP) is among its most valuable assets. IP includes copyrights, patents,
trademarks, trade secrets, design rights, trade dress, logos, know how, photos / videos, individuals’
names and likenesses, and other intangible industrial or commercial property. To the extent
permitted by law, P&G owns the rights to all IP relating to P&G businesses that we as individuals
create while employed by our Company. This is true regardless of whether the IP is patentable or
protectable by copyright, trade secret or trademark. You must not use this IP in a manner that is
inconsistent with P&G’s ownership rights. Contact Legal with any questions.
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Our Company’s
Intellectual Property
is among its
most
valuable assets
.
You must
safeguard P&G’s
proprietary information
and data, as well as
the technologies this
information is stored on.
Proper Use of P&G Assets
P&G Technologies and Electronic Communications
You must safeguard P&G’s proprietary information and data, as well as the technologies (such
as computer systems and applications) this information is stored on, from damage, alteration,
theft, fraud and unauthorized access. To achieve this goal, you must follow the specific security
measures and internal controls in place for the systems to which you have access.
You must not use P&G technologies or systems (including computers, phones and other
electronic devices that have access to the Internet) to download or send inappropriate,
discriminatory, sexually explicit or offensive statements or materials. In addition, you must not
use these technologies or systems to access illegal material, send unauthorized business or
charitable solicitations or conduct non-P&G-related commercial business.
P&G continues to expect any personal use of Company equipment and communications to
be occasional, incidental and limited, and in line with local agreements, if any. P&G strongly
encourages that whenever possible you use personal devices, rather than Company devices,
for personal matters. This will help protect P&G’s data, and your own, and will also help
ensure that the bandwidth that carries traffic between P&G and the internet is fully available
for business use.
For more on protecting P&G information, visit
pgsecurity.pg.com
.
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Proper Use of P&G Assets
(cont.)
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Social Media
P&G recognizes that the Internet provides unique opportunities to
listen, learn and engage with stakeholders using a wide variety of
social media tools, including blogs, micro blogs, social networking
sites, wikis, photo / video sharing sites, chat rooms and ratings and
reviews sites. Because there are many laws around the world that
regulate what P&G can and cannot say about itself and our products,
P&G has established rules for us to follow when using social media as
part of our daily work and in our personal use.
You must take great care not to disclose confidential P&G
information over social media – including photographs. You should
also remember to disclose your affiliation with P&G whenever you
provide opinions or reviews of P&G or competing products and / or
services (e.g., by disclosing “#PGEmployee” within your social media
postings). You should remember that electronic messages (such as
emails and text messages) are permanent, transferable records of
your communications and can affect the reputation of P&G.
For more information, see P&G’s Global Policy on Social Media at
wbcm.pg.com
.
If you believe that P&G technologies and/or electronic
communications are being used inappropriately, notify your
immediate manager, HR Manager, Legal or send an email to
securityincident.im@pg.com
.
You must take
great care not to
disclose confidential
P&G information
over social media.
Proper Use of P&G Assets
(cont.)
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Physical Property
P&G trusts us to respect and care for its physical property, to the best of our ability, at all times.
Physical property includes:
We should work together to prevent theft, destruction or misappropriation of all P&G physical assets.
You must never use P&G property for your own personal gain or for the benefit of another person, except to
the extent that it is approved in writing by local P&G policy.
You must never use Company credit cards for personal purchases unless incidental to a business trip. Personal
expenses charged to Company credit cards as part of a business trip must be reimbursed promptly.
You must follow P&G’s approved disposal / donation procedures for disposal of outdated P&G equipment or
other assets.
P&G Funds
(including credit cards)
Facilities
Equipment
Communications
Systems
You must ensure
we comply with
P&G’s confidentiality
agreements with
external partners.
External Party Information
We also often have an obligation to safeguard the confidential information of our external parties with whom
we do business.
You must ensure we comply with P&G’s confidentiality agreements with external parties, and you must never
share an external party’s confidential information with another company, or with a colleague who doesn’t have a
business need to know it. Equally, you must make sure that external parties with whom we do business who have
access to P&G’s information systems safeguard it. If a government agency requests that you provide them with
confidential information you received from an external party, contact Legal before providing any information.
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We must comply
with all applicable
laws governing PII
for consumers
and fellow P&Gers.
Privacy Safeguards
Personally Identifiable
Information (PII)
Personally identifiable information (PII) is
generally defined as any information that
identifies an individual – such as name,
physical address, email address, employee ID,
government ID, photograph, or any combination
of information that might identify an individual.
The definition of PII is evolving around the world,
so if you have a question about whether data
being handled by P&G and / or an external party
with whom we do business falls within the PII
definition, please consult Legal.
There are varying legal requirements governing
the use of PII across the countries in which P&G
operates. We must comply with all applicable
laws governing PII. Equally, external parties with
whom we do business who handle PII for us must
follow P&G’s privacy policies, security standards
and external party risk management processes.
If you are involved in the collection, storage,
transfer or use of PII, you must learn the legal
and policy requirements that apply to your
activities. If you believe that PII of any employee,
consumer, shareholder, or other P&G stakeholder
has been disclosed or used inappropriately,
you must contact Legal or send an email to
securityincident.im@pg.com
immediately. Failure
to do so could subject P&G to fines and / or
regulatory action.
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Consumer Data Privacy
P&G is committed to maintaining consumer
trust by protecting the privacy and security of
consumer PII. Laws governing the collection and
use of consumer PII vary by geography. These
laws may apply to particular data types, kinds
of consumers, types of data processing, or
communication channels. If you work with
consumer PII, you must ensure you adhere to
all applicable laws and P&G’s Global Consumer
Privacy Policy.
For more information on Privacy Safeguards,
visit
privacy.pg.com
.
Employee Data Privacy
We properly manage and use PII that our fellow
P&Gers, as well as prospective and former
employees, entrust to us.
You must not collect, access, use, retain or
disclose PII of our employees, except pursuant
to relevant and appropriate business purposes.
You must not share this information with anyone,
either inside or outside P&G, who does not have
a legitimate business need to know. In addition,
you must take steps to properly secure such data
at all times from unauthorized access. You also
must inform employees about the PII that is being
collected about them and how it will be used.
Protecting the Environment and Safety
of P&G Products
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Protecting the Environment
P&G’s goal is to meet or exceed all applicable
environmental laws, regulations and permit
conditions, and to use environmentally
sound practices to ensure protection of the
environment. Environmental regulations may
include rules governing the use, control,
transportation, storage and disposal of regulated
materials that may reach the environment as a
part of wastewater, air emissions, solid waste,
hazardous waste or uncontained spills. You must
understand and comply with health, safety and
environmental regulations in your daily activities.
If your job involves contact with any regulated
materials or requires that you make decisions
about how any materials are used, stored,
transported or disposed of, you must understand
how they should be legally, responsibly, and
safely handled. Contact the Health, Safety and
Environment experts in your organization
for further information.
Ensuring Product Quality and Safety
Product quality and safety are of the utmost importance to P&G. Our customers choose P&G because
we provide products of superior quality and value that improve the lives of the world’s consumers.
We must do our part to ensure that:
P&G meets or exceeds
all applicable legislative
and regulatory
requirements related
to product quality, safety
and labeling
Our products and
packages are safe
for consumers and
the environment when
used as intended
You must be aware of and follow the P&G policies and procedures designed to protect the quality
and safety of P&G products. As an employee of P&G, you may become aware of product complaints
that occur following the use of a P&G product. Should you become aware of a complaint, you
must email
Hefcr.im@pg.com
within 48 hours of becoming aware.
Just as we provide safe, quality products, we expect our suppliers to assure the quality and safety
of the products and services they provide to us. For guidance, contact the experts in Global Product
Stewardship (GPS) or Quality Assurance (QA) for safety or quality related concerns of our
products, respectively.
For more information, see the QA Corporate Policy – Complaint Management at
wqa.pg.com
.
P&G strives
to provide clear
and accurate
information to
the media, financial
analysts and the
general public.
Communicating with Media
and Analysts
P&G strives to provide clear and accurate information to the media, financial analysts and the general public.
In addition to important legal requirements to be clear and accurate, this helps us maintain integrity in our
relationships with the public and other external stakeholders, which in turn strengthens our corporate reputation.
Because this is so important, P&G has designated specific functions and individuals with responsibility for
communicating with the media and financial analysts.
• Only P&G’s Chief Executive Officer (CEO), Chief Financial Officer (CFO) and designated Investor Relations (IR)
personnel are permitted to speak with analysts and institutional investors about P&G. Other leaders can
and will speak to analysts, but it must be only by invitation of P&G’s CEO, .CFO, or IR Vice-President.
• All communications with members of the media are managed by the Communications function.
• You must contact your business unit’s Communications manager before participating in
media interviews or in events or forums where members of the media will be present.
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Q:0 Rosa gets a telephone call from a university
doing research on a P&G project in which she’s
involved. She guesses that they must know
about her project because of what she posted
on a social networking Internet site. She
wants to help the students and is proud of her
work. Should she provide information about
her project?
A: 0No, Rosa cannot share research data with anyone
outside of P&G. Rosa should not have posted
Company-related work on a social networking site,
either. Competitive agents regularly search the
Internet for this type of data and persuade
unsuspecting employees into sharing additional
information that can be used to piece together a
total picture of confidential projects, processes,
plans, etc. Rosa must immediately report the
information breach to Legal or Information Security
or send an email to
securityincident.im@pg.com
.
P&G Information
Q:0 Marcus works in Research & Development
at P&G. His team has collected a large amount
of consumer PII as part of a consumer
satisfaction survey. Lucia, who works in
Marketing, contacts him to request that he
send her the files containing this PII so that
she can develop targeted marketing emails.
Should Marcus give Lucia the information?
A: 0No. Although Lucia has what may seem like
a legitimate business reason for obtaining this PII,
the individuals who participated in the customer
satisfaction survey haven’t agreed to P&G using their
PII to send them marketing emails. Under P&G’s
Consumer Privacy Policy and many applicable laws,
marketing emails may only be sent to consumers
who have opted-in to receive them. Therefore,
Marcus shouldn’t provide this information to her.
Consumer Information
Q: 0Kyon recently conducted a consumer
home-use panel. During the panel, she
observed a potential safety concern with
a product that’s about to hit the market.
Only one person out of hundreds had any
troubles with the product, so she doesn’t
think it’s very important to report. Is this a
correct assumption?
A: 0No, not at all. Any product safety or quality issues
must be reported and resolved, no matter how
small the matter may seem. Kyon should email
Hefcr.im@pg.com
to raise any safety concerns that
she knows about or consult with Global Product
Stewardship (GPS), Quality Assurance (QA) or
Legal immediately.
Product Safety
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Q&A
Committed to
Integrity
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BEING HONEST AND STRAIGHTFORWARD
•
BUILDING TRUST
•
DOING WHAT’S RIGHT
Responsible Sales and Marketing
Practices
Our business is built on a foundation of trust. For this reason, we strive to compete vigorously and effectively,
but never unlawfully or unethically. We must make only truthful statements about P&G and its products and
services. All marketing claims must be substantiated and live up to their promises.
You should be familiar with the sales and marketing review procedures that apply to your work. As laws and
regulations change frequently in this area, you must know the latest requirements.
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We strive
to compete
vigorously and
effectively.
Maintaining Accurate Books
and Records
We maintain the accuracy and integrity of our books and records.
Reporting accurate, complete and understandable information about
P&G’s business, earnings and financial condition is one of our most
important duties.
We must ensure that our financial statements, regulatory reports and
publicly-filed documents comply with all applicable and accepted
accounting principles, statutory requirements and P&G’s internal and
disclosure control procedures. Our internal and external auditors will
regularly review our compliance with these requirements, so we must
always provide them with our full cooperation.
Internal controls are systems and processes that combine policies,
authorizations and procedures with proper accounting and
management tracking. Disclosure controls are systems and processes
that help ensure that important information is made available to
the right people at the right time.
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You must never intentionally delay recording transactions or
events, or intentionally record incorrect, incomplete or misleading
information about any transaction or event. Even if you do not
directly record transactions or events, you must be sure any and all
information you report or file, including management reporting, time
cards, quality reports, performance scorecards and expense reports,
is accurate and complete.
For more information, visit the Standards for Accounting and
Financial Excellence (SAFE) at
safe.pg.com
.
Complying with Competition
Laws
P&G competes vigorously and fairly. We succeed based on the quality of our
products and our People, and never through unfair business practices. We must
all abide by competition laws (also referred to as “antitrust” laws). These laws
can vary from market to market, but their common goal is to preserve free and
open competition and to promote a competitive marketplace. When markets
operate freely, our consumers benefit through high-quality goods and services
at competitive prices. Failure to comply with these laws can have serious and
far-reaching consequences for P&G and the individuals involved.
For more information, visit
antitrust.pg.com
.
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Interacting with Competitors
Even in the absence of formal contact, casual contact and
exchange of information can create the appearance of an informal
understanding between competitors. For this reason, P&G’s general
rule is
“No Contact with Competitors.”
However, at times you
may join trade associations and occasionally engage in various other
activities with competitors, as long as you have permission from
Legal. Be extremely cautious when interacting with competitors
at these events. If a competitor attempts to discuss any of the
prohibited topics with you in a trade association meeting, you must
stop the conversation immediately, leave the meeting and report
the incident to Legal.
For more information on the P&G’s Policy on Trade Associations,
visit
antitrust.pg.com
.
Contact with suppliers who are also competitors is allowable,
provided discussions and interactions are strictly limited to the
purchase of the material, equipment, goods or services that P&G
is buying, and provided Legal was aligned before contacting
competition. Approval from Purchases and alignment from the
appropriate leaders and functions, as outlined in the
Buying from
Competitors Policy
, must also be obtained before contacting
competition. Contact Purchases for more information.
For more information, visit
communities.pg.com/cm/GlobalPurchases
.
You must exercise caution when interacting with competitors.
You must avoid cooperating, or even appearing to cooperate, with
competitors.
You must never discuss any of the following topics
with competitors without Legal’s consent:
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Pricing or
pricing policy,
costs, marketing
or strategic
plans
Proprietary
or confidential
information
Boycotts
of certain
customers,
suppliers or
competitors
Joint behavior
toward
customers
Technological
improvements
Promotions
we will
conduct with
customers
Division
of customers,
markets,
territories or
countries
For more information,
see Global Commercial Practices
and Policies at
sales.pg.com
.
Interacting with Customers
Certain competition laws also govern your interactions with P&G customers, including both retailers and distributors.
You must treat our customers equitably and never seek to provide any unfair advantage to one customer over another.
P&G gives all competing customers within a given market equal opportunities to qualify for the same prices, terms
of sale and trade promotions.
You must never:
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Restrict how, to whom or where
customers sell P&G products
without the advance approval
of Legal
Leverage P&G’s particularly
strong position in certain
markets to limit in-store
competition,
focusing instead on building P&G
business on the merits
of P&G products and brands
Pressure or agree with a
customer about resale prices
of P&G products
(pricing is
always at the customer’s sole
discretion)
We are
committed to allowing
suppliers and
agencies to compete
equitably for
our business.
Interacting with Suppliers and Agencies
Just as P&G competes fairly, we are committed to allowing suppliers and agencies to compete equitably for our business
based on the total value offered by that supplier.
If you are involved in supplier or agency selection, you must make decisions based solely on the merits of the supplier’s or
agency’s offering. You must follow P&G’s purchasing processes and systems. In addition, you must never:
•
Make purchasing decisions on the basis of reciprocal deals or gifts or entertainment
•
Solicit any (potential) supplier or agency on behalf of charitable, civic or other organizations without prior authorization
from the Chief Ethics & Compliance Officer.
For more information, see Global Sourcing Principles at
pgsupplier.com
. For more
information on P&G’s purchasing processes, visit
purchases.pg.com
.
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No Bribery
Bribery not only harms P&G, but also the communities where we do
business. We prohibit bribes to government officials and employees
everywhere we do business. Most countries have strict laws against
bribery and it is important to remember that engaging in bribery, or even
appearing
to engage in such activity, can expose us to criminal liability.
You must never offer or pay a bribe. Bribery includes more than cash
payments. Gifts, travel and entertainment, and offers of employment for
government officials, employees or their families might be perceived as
bribery and must be carefully reviewed. Even donations to charity, when
given at the request of, or in hopes of influencing, a government official
can be considered bribery. It is also important to know that a
“government official” could include people like doctors or nurses at
government-run hospitals, teachers or administrators at public schools
or universities, or buyers for government-owned stores.
Besides bribery, P&G also prohibits “facilitating payments,” which are
small payments to individual officials to secure or speed up routine
government actions. Expediting payments, such as speeding up a
passport renewal, which are permitted under applicable law and made
to the agency itself (not to an individual) are not facilitating payments.
You must never offer or pay a facilitating payment unless you have
received prior written authorization from the Ethics & Compliance
Committee. Any payments made to assure the immediate personal safety
of an individual would not be considered a violation of our WBCM, but
must be reported immediately to the
Ethics & Compliance Office
.
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In addition to not giving or offering bribes or facilitating payments to
government officials, you must never allow an external party to do so on
P&G’s behalf, or enter into any transaction where you suspect an external
party is engaging in bribery. You should also be aware of “red flags” (for
example, cash payments, payments without supporting documentation,
payments in another party’s name) that suggest the possibility of bribes
or payments by someone at P&G or an external party with whom we do
business and report them to the
Ethics & Compliance Office
or Legal.
For more information, see P&G’s Global Policy on Anti-Bribery at
wbcm.pg.com
for details and the processes to be followed for all
interactions with government officials. Contact Legal or Global
Government Relations if you have any questions or concerns.
Preventing Bribery and Corruption
of Government Officials
A bribe
is anything
of value, including money,
gifts and entertainment,
intended to influence
someone to provide an unfair
benefit. Even low value items
can be a problem if the
intent is improper.
You must not
solicit or accept bribes
or kickbacks from
anyone who does
or is seeking to do
business with P&G.
No Bribery
(cont.)
No Commercial Bribery
You must never make supplier, customer or other business decisions based on any personal benefit given or
offered to you. In particular, you must not solicit or accept bribes or kickbacks from anyone who does or is seeking
to do business with P&G. You must never offer or give any bribes or kickbacks to any supplier, customer or other
external party. Keep these principles in mind when offering or receiving any form of gifts or entertainment.
For more information, see P&G’s policy on External Party Gifts, Meals and Entertainment at
wbcm.pg.com
.
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A “kickback”
is
the return of a sum
already paid or due
to be paid as a reward
for awarding or
fostering business.
Preventing Money Laundering
Money laundering is an attempt by individuals or organizations to
hide the proceeds of their crimes by making those proceeds look
legitimate. Money laundering is against the law and contrary to our
PVPs. Our approved payment and sales practices are designed to
ensure P&G resources are not used to violate these laws. They must
be followed for all purchases of goods and services, and for all sales.
You must be vigilant and exercise good judgment when dealing with
unusual customer transactions, including requests to make payment
to, or receive payment from a different company than the one P&G
is buying from or selling to. You must only conduct business with
customers that are willing to provide you with proper information so
that P&G can determine whether the payments are appropriate.
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Without advance permission from appropriate Legal and Tax
personnel, you must never:
This list is not exhaustive. For more information, see P&G’s Standards
for Accounting and Financial Excellence (SAFE) policy on Money
Laundering Avoidance and Designated Entity Control Compliance
at
safe.pg.com
(under Internal Controls) or contact the
Ethics &
Compliance Office
.
Make a
payment to, or
accept a payment
from, an entity that
is not a party to
the transaction
Accept
payments in
cash, unless no
secure banking
system exists
Ship customer
orders in a manner
inconsistent
with standard
procedures
Conduct
foreign exchange
operations with
unauthorized
institutions
Money
laundering is
against the law
and contrary to
our PVPs.
P&G operates
globally and has to
comply with special laws
and regulations
for the import and
export of products and
technical data.
Government and Trade Controls
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Work on Government Contracts
Many countries place strict legal requirements on companies that do
business with the government. When selling to, negotiating with or
working with government customers, it is critical that you abide by
these requirements. These rules are often much stricter and more
complex than those that govern P&G sales to commercial customers.
If your work involves government contracts, you must know and
follow the particular rules that apply to your work.
For additional information, contact the
Ethics & Compliance Office
.
Imports and Exports
P&G operates globally and has to comply with special laws and
regulations for the import and export of products and technical data.
Exports can include the physical movement of a product, software,
equipment, technology or piece of information to another country.
An export can also occur when technology, technical information,
service or software is disclosed or provided to a citizen of another
country, regardless of where the person is located. Before engaging
in any type of export, you must verify the eligibility of both the
location of delivery and the recipient. You also must obtain all
required licenses and permits, accurately complete all required
documentation and pay all proper duties.
Imports, or bringing goods into another country, are also subject
to various laws and regulations. These may require the payment of
duties and taxes, as well as the submission of documentation. P&G
has very detailed policies and procedures for those that work in this
area, which you must follow.
If you have any questions about P&G’s import and export policies
and procedures, please contact the iTrade team or the
Ethics &
Compliance Office
.
Government and Trade Controls
(cont.)
Boycotts and Restricted Countries
Economic sanctions and trade embargoes are tools used by governments to further various foreign policy and national
security objectives and they can change frequently and on short notice. P&G has systems and processes in place to help you
comply with these, but if you are unsure whether a transaction complies with applicable sanctions, you should contact the
Ethics & Compliance Office
.
Various governments have enacted laws that prohibit companies from participating in or cooperating with any international
boycott that the government does not approve. If you receive a request to participate in any way with an international
boycott, or suspect you have received such a request, you must immediately report the request to the
Ethics & Compliance
Office
. Note that such a request might be a specific request to comply (or agree to comply) with the boycott rules of a territory,
or it may be to give a certification that products, or the owner or shipper is not a boycotted or “blacklisted” entity.
For further guidance, see guidelines on T
rade Controls and Anti-Boycott at
wbcm.pg.com
(under
Key
Policies).
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None of us
may gather information
about our competitors
using deception, theft,
misrepresentation,
or other illegal or
unethical means.
Handling External Party Information
Gathering Competitive Information
While P&G needs to know what our competitors are doing in order to effectively compete, none of us may
gather information about our competitors using deception, theft, misrepresentation, or other illegal or
unethical means.
You must not request competitively sensitive information from family or friends about their employers, or
new hires about their former employers. In addition, in most circumstances you should also not ask for
information directly from our competitors, as this can raise considerable legal risks. You must talk with Legal
before asking for information directly from our competitors.
If a P&G supplier or customer is also one of our competitors, you must not solicit confidential information
from them in areas of competitive overlap without talking to Legal first. In addition, you must not ask them
to share confidential information from their suppliers or customers.
For more information on collecting competitive information, see P&G’s Competitive Intelligence (CI) Policy
at
cinet.pg.com
.
External Party Intellectual Property and Commercial Rights
We should respect all external party intellectual property (IP) rights and other intangible commercial rights
belonging to others. Intellectual property includes creative works, personality rights, and other ideas and
inventions protected by law such as copyrights, patents, trademarks, trade secrets, and design rights,
among others. We should never knowingly infringe upon these rights.
Your duty to respect all external party IP and commercial rights applies to any business activities you
conduct, including the creation of any internal or external communications or marketing materials. You
must check with Legal before using the name or materials of another person or company.
You must use all external party assets – including software, music, videos and text-based content – in
accordance with the specific terms of their licenses.
Only software properly licensed for business use is permitted to be used. This means you must not use
software or applications that you licensed for personal use (such as apps on your personal smartphone
or iPad) for business use.
For more information, see P&G’s Appropriate Use of Hardware and Software Policy at
pgsecurity.pg.com
.
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Avoiding Insider Trading
While working on behalf of P&G, we may become aware of material nonpublic information about P&G or other companies
with whom we do business. Material nonpublic information (also known as “inside information”) is information about a
company that is not known to the general public and that a reasonable investor would consider important when deciding
whether to buy, sell or hold that company’s stocks, bonds, options, or other financial instruments (“securities”).
You must not buy or sell the securities of a company on the basis of material nonpublic information (known as “insider
trading”). Doing so is a criminal offense in many countries and is prohibited by P&G. If you have any doubt about a
potential securities transaction, seek guidance from Legal or submit your question to
insidertrading.im@pg.com
. Our Global
Insider Trading Policy applies to all employees and the Board of the Directors. Individuals who are on P&G’s “Insider Trading
List” are subject to additional requirements.
If you reveal material nonpublic information to anyone, including any member of your immediate family or household, and
that person then buys or sells securities based on that information, you may be legally liable for “tipping.” This is true even
if you do not personally trade on the information. Tipping is a violation of our WBCM and the securities laws, and carries
severe penalties, including potential criminal liability for at-fault individuals.
For more information, see P&G’s Global Insider Trading Policy at
tradingpolicy.pg.com
.
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You must act
at all times solely
in the best interests
of P&G.
Handling Potential Conflicts of Interest
You must act at all times solely in the best interests of P&G. In order
to uphold P&G’s reputation, you must be alert to any situations
that may create a conflict of interest, whether actual or potential.
A “conflict of interest” arises when you have a personal relationship
or a financial or other interest that could interfere with your
obligation to act solely in the best interests of P&G, or when you
use your position with P&G for personal gain.
For more information about these situations, see P&G’s Global Policy
on Conflict of Interest at
coi.pg.com
.
If you are in a role where you provide P&G funds to a charity, or are
involved in charity-related programs on behalf of our Company, see
P&G’s Global Policy on Charitable / Community Relations Contributions
at
wbcm.pg.com
.
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Disclosing Conflicts of Interest
If you find yourself in a potential or actual conflict of interest
situation, you must immediately report it to your manager through
the Company’s COI process located at
coi.pg.com
. This way, the
situation can be properly reviewed and assessed. P&G will work with
you to find an appropriate solution. You are expected to take any
remedial actions requested by P&G.
If you are aware of any other potential conflicts at P&G, you should
report these to your manager or through the other available means
of reporting (see “
Where Can I Raise Questions and Concerns
”
section). Executive officers and members of the Board of Directors
must report potential or actual conflicts to the Chief Legal Officer.
You must be
cautious when giving
or receiving gifts
or entertainment from
anyone who does
business with P&G.
Gifts and Business Entertainment Guidelines
You must be cautious when giving gifts or entertainment to, or accepting gifts or entertainment from, anyone
who does or seeks to do business with P&G. You must only participate in business entertainment when it is
an integral part of business building activities. Remember that accepting gifts or entertainment may represent
a conflict of interest and / or appear to limit your ability to make an objective business decision. In addition,
offering such courtesies may be viewed as an attempt to influence a business decision. You must always follow
P&G’s policy on External Party Gifts, Meals and Entertainment and also respect and adhere to customer or
supplier policies that may not permit the acceptance of gifts or entertainment.
For more information, see P&G’s policy on External Party Gifts, Meals and Entertainment at
wbcm.pg.com
.
If you are ever uncertain about the appropriateness of a gift or entertainment, you should talk to your manager,
Legal or the
Ethics & Compliance Office
.
You must comply with P&G’s Anti-Bribery policy when giving gifts or business entertainment to Non-US
government officials. You must not offer any gifts of value, including meals or products, to members of the
U.S. Congress or their staffs. See also the “
No Bribery
” section.
For more information, also see P&G’s Global Policy on
Anti-Bribery at
wbcm.pg.com
.
Handling Potential Conflicts of Interest
(cont.)
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Only certain
individuals within
our Company may
engage in lobbying
efforts on
P&G’s behalf.
Interacting with the Government
Lobbying
As a corporate citizen, P&G often takes a position on issues of public
policy that could impact our business. P&G also engages in efforts
to affect legislation or government policy. However, regulations on
P&G activities in this area vary around the globe. Therefore, only
certain individuals within P&G may engage in lobbying efforts on
P&G’s behalf.
You must not contact a government official in an attempt to influence
legislation or government policy on behalf of P&G unless your efforts
have been approved by appropriate Global Government Relations,
Communications or Legal personnel.
The Honest Leadership and Open Government Act (HLOGA) is a
United States law that imposes criminal liabilities for violating U.S.
Congressional gift rules. All P&Gers everywhere in the world
(whether or not engaged in lobbying) must comply with HLOGA.
Therefore, none of us may provide Members of the U.S. Congress or
their staffs any gifts of value, including meals or products. See also
the “
No Bribery
” and “
Gifts and Business Entertainment
” sections.
For more information, contact the Vice President of Global
Government Relations & Public Policy, your local Government
Relations manager or Legal.
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Political Involvement and Contributions
P&G recognizes your right to participate in the political process
as an individual. However, you may only participate on your own
time and at your own expense. You must not use P&G time, funds,
facilities or assets for political purposes or contributions without
express written permission from the Ethics & Compliance Committee.
Maintaining
Accurate Books
and Records
Complying with
Competition Laws
Commercial
Bribery
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Q&A
Q: 0Trish is facing various budget
limitations at the end of the
fiscal year. To defer recognizing
an expense, she asks a supplier
to bill our Company a few days
late for the purchase of a costly
piece of equipment. This way,
she can record the purchase in
the next fiscal year. The supplier
will be paid and her department
will meet its budget. Can she
do this?
A: 0No, she must never delay or
intentionally record incorrect,
incomplete or misleading
information about transactions.
Q: 0Chet is an Account Manager in
Sales. One of his customers is
a small, rural store chain. The
customer tells Chet that if they
would buy all their laundry
detergent from P&G at a good
discount, the customer will drop
all competing products and stock
only P&G laundry. Can Chet
agree to this proposal?
A: 0Maybe, but he would need to seek
approval from Legal before making
any form of agreement with the
customer. None of us may enter
into any agreements – whether
verbal or written – that prohibit a
customer from purchasing products
from a P&G competitor without
such approval. Doing so could be
in violation of P&G policy and
competition laws.
Q: 0For the launch of a new initiative,
Stella proposes to give one very
nice Swiss watch to the buyer at
each customer. While she means
for the customers to use the
watches in charity raffles or the
like, she knows the buyer will
likely take the watch for personal
use. Can she authorize this
premium?
A: 0No, Stella can’t approve the premium
for the initiative. P&G cannot pay for
these expenses, since doing so might
create the appearance of bribery.
Q: 0While planning a trip out of his
home country on a P&G project,
John urgently needs to obtain a
visa for the country he is visiting.
If he doesn’t secure it quickly, the
deal he’s working on will likely
fall through. The visa agency tells
him that there will be a 2 day
wait for the expedited service
and a 2 week wait for the normal
service. However, if they pay the
desk officer $10 in cash, the visa
can issued immediately. Since it’s
such a small amount, can John
just authorize the agency to pay
the money?
A: 0No, John can’t make or authorize
any such payment, no matter how
small it is. He would need to check
if this is an official charge, that it will
be paid to the Embassy and not an
individual officer and that a receipt
will be provided. If he cannot get this
reassurance, he must wait until the
visa can be obtained officially and
must inform Legal about the request
immediately.
Bribery of
Government
Officials
Avoiding Insider
Trading
Conflicts of
Interest
Q: 0Through his position at P&G,
Ned has knowledge that P&G is
planning to enter into a contract
with a small, publicly traded
company that will be significant
for that company. He knows he’s
not allowed to trade based on
this inside information, but is
planning to tell his sister so that
she can make some money in the
stock market. Is this okay?
A: 0No. Ned can’t trade on the basis of
this inside information himself, and
he can’t provide it to his sister either.
This is called “tipping” and is
a violation of P&G policy and
securities laws.
Q: 0The company that employs
Hans’ wife was recently
bought by one of P&G’s main
competitors. Hans isn’t sure
whether this matters, since
his wife’s company will only be
a subsidiary of our competitor.
What should he do?
A: 0Having an immediate family member
who works for a competitor poses
a potential conflict of interest, and
Hans should disclose the situation
to his manager immediately.
Reports should be made online at
coi.pg.com
and assistance can be
provided by Human Resources.
P&G will work to determine whether
an actual conflict exists and, if so,
what needs to be done to resolve
the situation.
Q: 0Sally, an Account Manager, is
offered four box seat tickets to a
regular season soccer game by a
customer with whom she works.
General admission tickets are
available. What should she do?
A: 0Accepting tickets, or any other gift,
from a supplier or customer raises
significant conflict of interest
concerns. If the tickets to game are
not associated with any business
event (e.g., they are purely for Sally
to use with her family or friends),
she should graciously decline the
tickets. If the tickets are for Sally
and her co-workers so they can
attend the game with representatives
of the customer, then attending the
event may have genuine business
relationship-building value. Sally
should consult with her manager –
who must not also be attending –
and review the requirements of
P&G’s policy on External Party
Gifts, Meals and Entertainment to
determine what to do.
Gifts and Business
Entertainment
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Q&A
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Reporting Concerns
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Contact Information for
Reporting
Worldwide Business Conduct Helpline
The
Worldwide Business Conduct Helpline
is
available around the world 24 hours a day, seven
days a week, and is staffed by an independent
company and can take calls in most languages.
When calling the
Worldwide Business Conduct
Helpline
, you can report actual or suspected
violations anonymously, where allowed by
applicable law.
pghelpline@alertline.com
United States, Canada and Puerto Rico:
1-800-683-3738
Other Locations: Collect: 1-704-544-7434
Toll free: Go to
www.pg-helpline.com
for a list of direct dial numbers
www.pg-helpline.com
WBCM Helpline
P&GPMB, 3767,
13950 Ballantyne Corporate Place
Charlotte, NC 28277
Postal Mail
Phone
Email
Intranet
If you have questions or doubts as to whether an action is consistent with our Worldwide Business Conduct Manual,
P&G policy, or the law, you should seek advice. You also have a duty to P&G and your fellow P&Gers to report any
known or suspected violations of our WBCM, P&G policy or the law.
Refer to the “
We Speak Up – Raising Questions and Concerns
” portion of the WBCM on how to report concerns.
Reporting Concerns
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Ethics & Compliance Committee
and Office
The Ethics & Compliance Committee is responsible for
maintenance, oversight and final interpretation of the WBCM.
It is comprised of the Chief Executive Officer, Chief Financial
Officer, Chief Legal Officer, and Global Human Resources Officer.
The Ethics & Compliance Office is a multi-functional team of
Legal, Finance, HR and GBS professionals with expertise in how
ethics and compliance issues are viewed and managed both
externally and within the Company.
ethicscommittee.im@pg.com
The Procter & Gamble Company
Ethics & Compliance Committee
One Procter & Gamble Plaza (C-11)
Cincinnati, OH 45202
Ethics & Compliance Committee
(G.O. C-11)
Postal Mail
Inter-
departmental
Mail
Email
Global Security
(Workplace Violations)
The Global Security organization is responsible to ensure
that physical security for P&G facilities meets P&G policy and
standards to deliver a safe and secure work environment.
If you know of or suspect incidents or threats of workplace
violence, or if you believe someone is in immediate danger, you
must report your concerns immediately to the P&G global
security contact. Dial
1-513-983-3000 (voice prompt 3)
to be
connected to someone immediately. The phone is answered 24
hours a day, 7 days week by a Global Security Representative.
globalsecurity.pg.com
globalsecurity.im@pg.com
Email
Intranet
Phone
1-513-983-3000
(voice prompt 3)
Reporting Concerns
(cont.)
Corporate Secretary
An Officer of P&G and a member of the
Company’s Legal Division
Our WBCM is implemented in line with applicable law and consultation procedures. This edition, effective September 2016, supersedes and replaces all
previous versions. It describes P&G’s policies and practices currently in effect. The WBCM may, consistent with applicable law and with reasonable advance
notice where required, change from time to time upon approval from the Ethics & Compliance Committee and / or P&G’s Board of Directors.
This applies in its entirety to all of P&G’s non-employee members of the Board of Directors, Officers and employees. However, only the following sections
are deemed to be the Code of Ethics for the purposes of the rules of the SEC and the listing standards of the New York Stock Exchange: Doing the Right
Thing – P&G and Me, We Speak Up – Raising Questions and Concerns, Non-Discrimination, Preventing Harassment, Workplace Health and Safety, Ensuring
Fair Employment Practices, Keeping P&G Information Secure, Records & Information Governance, Proper Use of P&G Assets, Privacy Safeguards, Ensuring
Product Safety, Responsible Sales and Marketing Practices, Maintaining Accurate Books and Records, Complying with Competition Laws, No Bribery,
Preventing Money Laundering, Government and Trade Controls, Avoiding Insider Trading, Handling Potential Conflicts of Interest, and Resources. Sections
listed include any subsections contained therein. All sections not listed above, as well as all sidebars, Q&A’s, examples, and linked policies or documents,
are not included in the Code of Ethics.
Letter from
Our CEO
Contents
Our PVPs
Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
Worldwide Business
Conduct Manual
59 of 60
corpsecretary.im@pg.com
Corporate Secretary (G.O. C-11)
The Procter & Gamble Company
Corporate Secretary
One Procter & Gamble Plaza (C-11)
Cincinnati, OH 45202
Email
Postal Mail
Inter-
departmental
Mail
Letter from
Our CEO
Contents
Our PVPs
Raising Questions
and Concerns
Doing the
Right Thing
Respect
Stewardship
Integrity
Resources
60 of 60
Worldwide Business
Conduct Manual
Doing the right thing,
every time
