Ethical conduct is not just an aspiration; it is the foundation upon which we build success. We are committed to doing business the right way – legally, ethically and with unwavering integrity. Fostering a strong ethics and compliance culture is the primary mission of our dedicated Ethics & Compliance (E&C) department.

In May 2023, the E&C department launched a refreshed global ethics and compliance program thus reaffirming our commitment to an ethics and integrity focused organization. The program is risk based, incorporates key global regulatory frameworks and is composed of six elements, which play a unique and important role in identifying, prioritizing, and mitigating risks related to ethics and compliance.

The program elements are:

• Ethical culture and leadership engagement
• Management support, resources and oversight
• Standards, policies and procedures
• Communication, education and training
• Monitoring, evaluation and risk management
• Internal reporting, investigation and remediation

With the refreshed global program, the E&C department plays a key role in helping Allied Universal fully integrate ethics and compliance into daily management and strategic planning and provides an independent view of ethics and compliance risk management across the organization. This independent view is maintained primarily through evaluation, risk-based monitoring and oversight. Key strengths of the Allied Universal’s global ethics and compliance programme:

• A Clear Message: “Always Act with Integrity” sets the standard for all employees.
• Leadership by Example: Both senior leadership and managers play a crucial role in promoting ethical behavior. We expect leaders to “role model” ethical conduct through uncompromising integrity.
• E&C: Your ethics partner: The E&C department provides assurance, oversight and governance to ensure the businesses and functions can operate ethically with integrity and in accordance with the Code and applicable laws.
• Multi-faceted Approach: The program addresses various aspects, including policies, procedures, training, communications, investigations, risk management and advice and expertise.
• Building Trust: Ultimately, the program aims to foster a culture of ethics and compliance across the organization, strengthening trust with stakeholders.

Following the launch of the refreshed global ethics and compliance program in 2023, the E&C department focused on further building awareness and embedding the program across the organization. Leveraging a strategic approach, the department fostered leadership engagement through a series of program enhancements, support and guidance to the businesses effective management of concerns and investigations and targeted communications.

Also in 2023, we refreshed and re-issued several key policies, including our global competition and antitrust policy and anti-bribery and corruption policy, to our businesses with our annual ethics refresher training.

We continued to develop better and more streamlined training methods to more efficiently educate about and raise awareness for key enterprise risks. This training included, “Ethics Moments” which are a series of code based ethical dilemmas designed for senior managers to create discussion at the start of meetings or with their teams on important code based topics. These were created in 2023 and implementation began in early 2024. The most significant development of our program in 2023 was the consolidation of our North America and international Speak Out ethics hotlines (discussed in more detail below). We also commenced several larger enterprise-wide projects that will be completed in early 2024 including a refresh of our customer due diligence processes and procedures and the integration and launch of our integrated Global Code of Ethics.

Anti-Bribery and Corruption Policy: Zero Tolerance

As a global company operating in the most challenging environments, we do not tolerate any form of bribery, corruption or kickbacks. In 2023, we refreshed and re-released our global anti-bribery and anti-corruption policy. Our policy is simple: 

• The company does not accept or offer bribes.
• The company does not accept or offer kickbacks.
• The company does not tolerate corruption in any form.

With the refreshed policy, we released several supporting strategic communications and other messaging. This policy demonstrates our commitment to conducting business with honesty and integrity.