2017 Sustainability Report

Xylem People

Ethics

The cornerstone of Xylem’s ethics policy is our Code of Conduct. Our Code of Conduct requires all of our Directors, officers and employees to act ethically and honestly.

We expect every interaction, every transaction and every business opportunity to be handled in a manner consistent with our Code of Conduct, our policies and all applicable laws. We ensure compliance with multiple layers of accountability and make it easy for employees to speak up when they see something wrong.

In 2017, we made several enhancements to our ethics program, including the global launch of our new Xylem Integrity Line (XIL), which encompasses a reporting hotline and web-based interface to replace the legacy reporting system. The XIL facilitates easier issue reporting by users, and it enhances our issue response and investigation management capabilities. In tandem with our launch of the XIL, we embarked on a global “speaking up” campaign to remind our colleagues about the importance of raising issues of concern and asking questions when they see conduct that may potentially be inconsistent with our company values. Included in our campaign were new “speaking up” posters promoting the importance of colleagues saying something if they see something.

In addition, we expanded Xylem’s ombuds-person program, increasing the number of local ombudspersons around the company’s global operations by 25 percent in 2017, thus increasing the number of direct touchpoints employees have with our ethics and compliance program throughout the organization.

Our Code of Conduct went into effect for Pure Technologies, EmNet and Valor Water Analytics employees on day one following our acquisition of those businesses, and we are continuing to fully roll out all ethics policies across our expanded organization. The Code of Conduct is posted publicly in 26 languages and is available to employees on our company intranet and to third parties on our public website. In addition, our Supplier Code of Conduct is posted publicly in 18 languages and is incorporated into our standard contracts.

Training

Every other year, we conduct global Code of Conduct training for all employees, and we provide training to all new employees and at targeted locations throughout Xylem on a continuous basis. Through Code of Conduct training, Xylem employees gain a deep understanding of our core values of respect, responsibility, integrity and creativity and the types of behaviors, actions and decisions that will enable them to support these values. Additional topics covered in the Code of Conduct training are carefully selected by reviewing current ethics and compliance trends within the company and analysis of our hotline reporting and other data.

Training is conducted through a combination of on-line and in-person video delivery to ensure all employees are aware of Xylem’s commitment. After training, Xylem employees certify that they understand how the Code applies to their jobs and how to comply with its provisions. Companywide Code of Conduct training was conducted in 2016 with 96 percent completion, and we will update the training for all employees in 2018. In all, Xylem conducted more than 4,300 person-hours of live ethics and compliance training during 2017, up 18 percent versus 2016.

Reporting Mechanisms

Xylem endeavors to create a corporate culture where employees are expected to report misconduct, where they have many ways to report concerns and where retaliation for reporting is not tolerated. Our reporting concerns policy encourages employees to report misconduct through:

  • The Xylem Integrity Line, a toll-free, 24-hour-a-day confidential reporting helpline available to employees, suppliers or customers with language support in over 180 languages.
  • Local ombudspersons who receive and impartially address employee Code of Conduct questions or ethical concerns and are required to take all reasonable and legally permissible steps to protect the identity of all those who report possible violations in good faith.
  • Consultation with management, Human Resources or our team of ethics and compliance professionals, including our Chief Ethics and Compliance Officer.

We build awareness about our policy and reporting mechanisms through robust employee engagement, which includes ethics and compliance newsletters, “speaking up” posters translated into 21 languages at our locations, live training and an employee intranet portal dedicated to Xylem’s ethics and compliance program.

At Xylem headquarters and in each of our regions, we have established Ethics and Compliance Review Boards. These boards, staffed by senior managers and compliance leaders, meet at least quarterly to oversee local compliance with our Code of Conduct and compliance policies, manage compliance trainings, drive employee engagement, and monitor any ethics and compliance investigations. The boards ensure that every concern that is raised receives appropriate management attention and is resolved in a fair and expeditious manner. They also facilitate learnings from across the organization.

The number of ethics concerns raised in 2017 was generally in line with benchmarking for a company of Xylem’s size and industry. Our total number of questions and concerns raised decreased 10 percent from 2016 to 2017.

Anti-Corruption

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 of 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 on a periodic basis and offer training for third parties to help them understand how to remain compliant.

Ethics and Compliance Reporting
  2016 2017
Number of Questions and Concerns Raised (through Xylem’s complaint handling and resolution process) 67 60
Percent of Substantiated Reported Complaints 36% (24) 43% (26)
Percent of Unsubstantiated Reported Complaints 46% (31) 35% (21)
Percent of Other* Complaints 18% (12) 22% (13)
Percent of Credible Reported Complaints Investigated 100% 100%
Percent of Substantiated Cases Resolved (through discipline, training, process enhancement, etc.) 100% 100%

* Other Complaints refer to reports transferred to other departments for appropriate handling or where there was not enough information to conduct an investigation

Anti-Trust

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 bi-annual, online training for designated employees, as well as targeted live trainings where appropriate. In 2017, Xylem did not pay any non-compliance fines.

Human Rights

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.