CentoTech's ethical business conduct isn’t just a part of what we do—it’s at the very core of how we operate.
Doing the right thing for our employees, customers, stakeholders, and communities has helped us earn trust and build partnerships that will drive us forward in the next century, and beyond.
While each employee is accountable for upholding the CentoTech Code of Conduct, ensuring that our values remain foundational to our work, and following all applicable laws, regulations, and company policies, CentoTech advances its ethics and compliance initiatives through the Chief Compliance Officer, who works closely with the board of directors, senior company leadership, and external stakeholders.
OUR ETHICS & VALUES
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 raise questions without fear of retaliation.
CentoTech asks all employees across the company to provide answers to questions in a formal, confidential survey about their perceptions of the company, its direction, the quality of our managers, our shared values and ethics, along with other important dimensions of the corporate culture. CentoTech specifically asks about employees’ perceptions of retaliation for reporting wrongdoing and of their management’s support of ethical decision-making to ensure a culture of openness and accountability.
Focused surveys are also deployed to collect further details about employees’ perceptions of the CentoTech culture.
- Workplace case studies based on actual events.
- Staff meeting materials that drive openness, trust, and personal accountability, and encourage speaking up without fear of retaliation. Additional topics are provided to help employees respond ethically when faced with normal business pressures, such as workforce shifts, and cost or schedule constraints.
- Training refreshers on company procedures and policies.
The CentoTech Code of Conduct establishes behavioral expectations for our employees at all levels of the company – wherever they are in the world. Along with Company 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 applicable 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 meets to review and discuss CentoTech 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.
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 and continually enhance this area, compliance monitoring and assessments are built into all levels of the business.
Senior leaders of every CentoTech business and function are responsible for identifying, analyzing, raising and addressing key compliance issues. They do this through the Compliance Risk Management Board (CRMB), which is co-chaired by the Chief Compliance Officer and Controller, as well as involvement from other senior executive leaders. The CRMB's oversight 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.
CentoTech uses ongoing monitoring to track and assess effectiveness of internal controls and processes in meeting compliance goals. Each year, all compliance training is reviewed for relevance and effectiveness, based on subject matter experts’ feedback and effectiveness surveys from training completions. It is also refreshed as needed to ensure content is current and meaningful. From the company’s most senior leadership to its newest workers, CentoTech employees are committed to ensuring that compliance is core to everything we do.
Speaking up is a cornerstone for building an open and accountable workplace culture. At CentoTech, 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. CentoTech 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 reporting parties is strictly prohibited by the Code of Conduct, and action is taken against violators of anti-retaliation policies, up to and including dismissal.
CentoTech promotes awareness of the company’s reporting channels and non-retaliation policies in annual training for all employees (tracked to completion), recurrent employee communication, command media, and posters that are displayed in high-traffic work areas across the enterprise. Resources for deployment are available in additional languages. Managers also are asked to encourage speaking up within their own teams by using materials and resources developed by the Ethics and Business Conduct team 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.