IBM's Trust & Compliance Office provides centralized and independent oversight of IBM's ethics and compliance programs. The Trust & Compliance Office is led by IBM's Vice President, Assistant General Counsel, Chief Trust & Compliance Officer. A global team of compliance professionals works with IBM employees around the world to help ensure that IBM conducts business with integrity and is a model of compliance with legal and regulatory requirements everywhere in the world the company does business. The team also administers IBM's global Business Conduct Guidelines certification and education program. Their most important job is to call upon and unleash the ideas and dedication of the only people who can create a culture of trust and personal responsibility within IBM and in all IBM relationships -- that is, IBM employees themselves.

Integrity is the keystone to IBM's value of Trust and personal responsibility in all relationships. All managers throughout IBM play a critical role in fostering effective business integrity in the workplace. They fulfill this role by developing, promoting, and leading a culture of integrity in their organizations. The Trust & Compliance Office supports their efforts by providing compliance resources, tools and expertise.

• IBM Business Conduct Guidelines
  • The IBM code of business conduct and ethics for our directors, executive officers and employees.
• Supplier conduct principles & guidelines
  • The principles and guidelines with which IBM suppliers are required to comply to do business with IBM.
• Corporate responsibility
  • Information about IBM's corporate citizenship and social responsibilities initiatives.
• Business Partner code of conduct
  • The standards of business conduct and business practices with which IBM requires IBM Business Partners to comply.
• Other IBM policies
  • Other corporate policies that govern internal and external company-wide actions.

Trust is a cornerstone of IBM's brand and values. IBM looks to its employees, suppliers, and IBM Business Partners to be the stewards of IBM's good name and reputation, and to act decisively if they become aware of possibly unlawful or unethical conduct, or suspect there has been a violation of IBM's Business Conduct Guidelines or workplace policies.

IBM provides communications channels for employees, suppliers, IBM Business Partners, and others to report concerns or suspected violations to the company. One such channel for reaching IBM is by emailing Trust and Compliance at trustww@us.ibm.com. Some reporting channels include mechanisms for submitting anonymous reports. IBM does not tolerate threats or acts of retaliation against any employee for reporting a concern or suspected violation.

Reported concerns and suspected violations are reviewed and investigated, if appropriate. Findings of misconduct are subject to disciplinary action, which may include termination of employment or business relationship.