We Speak Up To Report Concerns
If you know of, or have a good reason to suspect, a violation of the Code, the Business Practices Guidelines or other Company policies, you are required to immediately report that information to your manager, Human Resources, Global Ethics and Compliance or the Global Legal Organization. Alternatively, you should feel free to go to higher levels of management without fear of retaliation.
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Global Ethics & Compliance
Colgate-Palmolive Company 300 Park Ave,
New York, NY 10022
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It is Colgate’s policy and practice to maintain the highest ethical standards, and to create a workplace free of inappropriate or unlawful behavior, in which people are encouraged to share their concerns with the Company without fear of retaliation. Consequently, at Colgate, no adverse action will be taken against any employee, former employee, agent or third party for complaining about, reporting, participating or assisting in the investigation of a suspected violation of the Company’s Code of Conduct, Company policy, or applicable law, unless the allegation made or information provided is found to be intentionally false or not made or provided in good faith. To the maximum extent possible, Colgate will maintain the confidentiality of all complaints. All allegations of retaliation will be investigated, and if appropriate, disciplinary action will be taken, up to and including termination.
All information provided to Global Ethics and Compliance is reviewed and, if it relates to the Code, the matter is promptly and thoroughly investigated by Global Ethics and Compliance and/or the Global Legal Organization. It is imperative that reporting persons do not conduct their own investigations, as investigations may involve complex legal issues. Acting on your own may compromise the integrity of an investigation and adversely affect both you and Colgate.
Reports can be made anonymously where local law permits. But, we encourage you to identify yourself when calling in order to help us to facilitate the investigation and follow-up. There are laws in some countries that restrict the type of information you may report. If these laws apply to your situation, a Global Ethics and Compliance representative will refer you to someone in your business unit who can assist you with your question or concern.
However, keep in mind that if you wish to identify yourself, the Company will take all appropriate steps to keep an individual’s identity and the information submitted confidential, and will only disclose information on a need-to-know basis when the disclosure is:
- Necessary in order to conduct an effective investigation, answer your questions or take appropriate action; or
- Otherwise required by applicable law.
A report or complaint may contain personal data. For the purpose of investigating a violation or suspected violation, it may be necessary, subject to local law, to transfer personal data collected in one country to other countries, including the United States. In such cases, personal data may be used by Company employees and Colgate entities that participate in the operations of Global Ethics and Compliance to investigate the report, but only for such period as is reasonably necessary for this purpose (and thereafter such personal data will be destroyed or retained only as required by Company policy or by law).
Global Ethics and Compliance Investigation Process
Colgate people are expected to provide their complete cooperation when participating in any Company investigation.
- An Investigator Is assigned based on subject matter expertise and objectivity
- Interviews Are Conducted and documents are reviewed by the Investigator
- Factual findings are developed based on the collected information
- Corrective actions are recommended based on the findings
- General Feedback about the outcome of the investigation is provided
Examples of concerns which generally should not be reported to Global Ethics and Compliance:
- Bonus Plans or Bonus Payout
- Payroll Issues
- Leaves or Vacation Time
- Individual Objectives
- Work Schedule or Shift Change
- Medical or Disability Benefits
These types of concerns should typically be brought to the attention of Human Resources.
Disciplinary Actions May Be Taken
The Company has a “zero tolerance” policy for any conduct that violates the Code or Business Practices Guidelines.
This means that when a violation has been verified, appropriate action commensurate with the nature and extent of the violation will be taken.
Examples of actions that could be taken include:
- Process improvements
- Policy development or revision
- Communications strategy
- Assignment of coach or mentor
- Disciplinary action
- Termination of employment
No individual or manager in the Company has authority to engage in conduct that does not comply with this Code, or to authorize, direct, approve or condone such conduct by any other person. As such, the Company intends to prevent the occurrence of conduct not in compliance with the Code or Business Practices Guidelines and to halt any such conduct that may occur as soon as reasonably possible after its discovery. Colgate people who violate the Code or Business Practices Guidelines may be subject to disciplinary actions, up to and including termination, subject to local law.
The Code Applies To All Colgate People And Activities
Compliance with the Code of Conduct and Business Practices Guidelines will be monitored by the Global Ethics and Compliance Department. The Department reports to the Chairman, President and Chief Executive Officer and to the Chairman of the Audit Committee of Colgate’s Board of Directors regarding the establishment, implementation and enforcement of the Code of Conduct and related programs. Information reported to the Global Ethics and Compliance Department or through other channels is, as appropriate, communicated on a confidential basis to the Audit Committee. The Code is applicable to everyone who works for the Colgate-Palmolive Company and its subsidiaries, including officers. Copies of the Code are available online on both our internal intranet site as well as our external website. Colgate people around the globe demonstrate their commitment to compliance and the Company’s ethical standards by participating in Code of Conduct training and certification on an annual basis.