At Dell, our commitment to ethical conduct starts at the top with Michael Dell, our board and senior leadership, and then extends to all team members across the company.
As Michael Dell recently stated when Dell was again named a World’s Most Ethical Company by the Ethisphere® Institute, “Ethics and integrity matter at Dell. We work hard to earn our customers’ trust, improve our communities and inspire our team members through sound, ethical decision-making. Because at Dell, how we do our work is just as important as the results we achieve.” In FY18, we continued to focus on our integration with EMC and subsidiaries, while amplifying our commitment to Dell’s Culture Code, which encompasses the five values of our company.
Introducing a unified Code of Conduct and global compliance policies
After months of analyzing the Dell and EMC ethics and compliance programs, including their individual codes of conduct, key policies, controls and awareness initiatives, in FY18 we developed and launched a unified Dell Technologies Code of Conduct. The code’s concepts are rooted in Dell’s values (including integrity), which are the basis of how we make decisions and engage our critical stakeholders. Flowing from this new code are our key global compliance policies and expectations. Now all of our global team members are expected to follow the same rules for privacy, anti-corruption, trade compliance, competition law and conflicts of interest, just to name a few.
Enhancing our ethical culture
How do we determine how effectively we’re putting our values into action? One way is by surveying our team members about the ethics-related successes and challenges they’re experiencing each day. In FY18, we again partnered with the Corporate Executive Board (now Gartner) to conduct our fourth global Ethical Culture Survey. More than 41,000 Dell team members, speaking 17 languages, weighed in on topics such as trust in leadership and fellow colleagues, clarity of expectations, ethical pressures, the ability to identify misconduct, and their comfort in raising concerns without fear of retaliation. This confidential survey provided us with a benchmark against other companies and against our own past results. We were one of only three companies to receive a score over 6.0 (with 7.0 being the highest).
These positive survey results are the direct outcome of our programs and controls focused on various compliance risks, as well as our ongoing reinforcement of our values and integrity at all levels of the company. For example, in FY18 we supported our human resources and leadership teams in integrating the Dell Culture Code into a new Dell Technologies Advantage (DTA) training that, in addition to reinforcing our corporate strategy, taught leaders how our values and culture of integrity differentiate Dell in the marketplace. Top Dell executives facilitated the DTA training to more than 7,000 global leaders, and it was later expanded into a virtual training for all Dell team members worldwide.
“Ethics and integrity matter at Dell. We work hard to earn our customers’ trust, improve our communities and inspire our team members through sound, ethical decision-making. Because at Dell, how we do our work is just as important as the results we achieve.”
Michael Dell, CEO, Dell Inc.
Engaging internal and external stakeholders on ethics and compliance
Given the new Code of Conduct and other changes implemented in FY18 due to post-merger integration, training team members was a key priority. In October 2017, we launched a fully unified, online annual compliance training to ensure all team members had a consistent understanding of the new code, our values and what it means to operate in Dell’s name. By the end of FY18, all of our eligible team members worldwide had completed the training. In addition, key target groups received training on several key regulatory risk topics, each aligned to the outcomes of our annual enterprise risk assessment.
We continued our tradition of sponsoring a meal at Dell’s Worldwide Leadership Meeting and leveraging that valuable time to discuss critical compliance topics, complete with real case studies. In FY18, we hosted roughly 150 top global Dell executives, including Michael Dell, and focused on the emerging risks in the cybersecurity and privacy space. Presenters included Dell’s new chief security officer, Dell’s chief privacy officer and a former head of the Privacy Division of the U.S. Federal Trade Commission.
We also continued to share our philosophy and programs with customers. The Global Ethics and Compliance Team hosted a booth at our Dell EMC World customer conference, where we provided information about Dell’s Global Privacy Program and our work to meet various data protection requirements and regulations. Dell’s chief privacy officer spoke at a large session about the General Data Protection Regulation (GDPR) and how many of our customers are also preparing for its launch.
We were also proud to become a founding member of the Business Ethics Leadership Alliance (BELA) South Asia Chapter, in partnership with Ethisphere Institute. We are a longstanding member of BELA in the U.S. In FY18, Dell’s ethics and compliance and legal leadership in India engaged closely with internal business leaders and peer companies in the region to establish a BELA membership with the goal of fostering best practices and raising awareness of integrity and compliance as a business differentiator.
Working with third parties
We continued to expand our compliance efforts within Dell’s supply chain, as well as among distribution partners, channel partners and other third parties. To make our distribution and channel ecosystem more accountable to our high standards, we introduced a unified Dell EMC Partner Code of Conduct. The code addresses critical risk topics, including ethics, anti-corruption, trade, gifts and entertainment, marketing development funds, and privacy. We also continued our vetting and red flag management program, which provides for transparency of ownership and other insights that allow us to evaluate and select third parties with greater confidence.
Regional ethics and compliance personnel also partnered with local factory leadership and the sustainability team to ensure we were prepared for and engaged fully in scheduled FY18 Responsible Business Alliance audits of key Dell and Dell EMC factories around the world. We are proud to say that all factories audited received high marks in the Ethics portion of the audit.
Protecting customer and Dell data
Data privacy and security are at the forefront of our customers’ and employees’ minds. At Dell, we are committed to protecting the personal data we hold on our own behalf and on behalf of our customers and employees. Dell’s Global Privacy Program provides the foundation for protecting personal data worldwide, using best-in-class controls and processes to manage our employees’ and customers’ personal data. This program requires every one of our businesses and team members to protect personal data and to use it only for authorized purposes.
Over the past few years, Dell’s global privacy team has been collaborating with our business partners to build upon our existing best-in-class Global Privacy Program by adding new and enhanced features to meet the new European Union GDPR requirements, which took effect May 25, 2108. Our customers can be assured that any personal data they entrust to us will be protected and handled in accordance with the GDPR data protection principles.