Xylem trains employees on applicable anti-corruption laws and regulations, primarily through our Anti-Corruption Policy, Gifts, Hospitality & Travel Policy and Anti-Corruption Manual, and our Code of Conduct.
In addition, designated employees around the world in Finance, Legal, Compliance and Sales and Marketing are provided with additional, in-depth anti-corruption training either in person or online. Xylem conducts an annual risk assessment of all its Growth Centers and regional Commercial Teams, which includes risks related to bribery and corruption. This risk assessment is monitored and updated regularly. Xylem’s internal audit department also conducts regular audits of select sites to determine compliance with the U.S. Foreign Corrupt Practices Act and Xylem’s internal policies, and to assess the effectiveness of our anti-corruption program.
Operating as a global company, corruption and bribery also present risks to Xylem in areas where we leverage third parties rather than having a Xylem-owned office. We mitigate this risk by conducting robust due diligence with select third parties. As part of the approval process, third parties certify that they will comply with all applicable anti-corruption and anti-bribery laws. We renew our due diligence every two years and offer training for third parties to help them understand how to remain compliant.
Xylem operates in many highly competitive markets around the world where it must submit competitive bids to win business. It is therefore critical that our employees understand and comply with the various anti-trust and competition laws in all of the locations where we do business. This is accomplished through a combination of policies and procedures, comprised of an anti-trust/competition law policy, a competition law compliance manual and our Code of Conduct, and a robust training program, consisting of a bi-annual on-line training for designated employees as well as targeted live trainings where appropriate. In 2016, Xylem was not involved in any anti-trust incidents and did not pay any non-compliance fines.
With a global presence, we want to serve as a positive influence in the communities where we operate and where our employees live, demonstrating by our actions that human rights violations are both avoidable and unacceptable. Xylem fully supports and adheres to the principles of both the Universal Declaration of Human Rights and the United Nations Global Compact wherever we operate. The Xylem Human Rights Policy outlines our commitment to human rights, dignity and fairness. In particular, we are committed to:
- Providing safe and secure conditions for those working on our company’s behalf.
- Safeguarding the environment.
- Protecting the rights of indigenous people.
- Following all applicable wage and hour laws, including upholding our employees’ right to exercise freedom of association and collective bargaining.
- Strictly prohibiting human trafficking and the use of child or forced labor, including prison or bonded labor.
- Treating each other fairly and equitably.
While Xylem does not conduct dedicated human rights training for employees, our Code of Conduct states that all Xylem employees and businesses will conduct business in a manner that respects and advances human rights “at all times and in all locations, regardless of local business customs.” To ensure that every facet of our business upholds these standards, we seek business partners who share these commitments.