Code Corner

What Happens After a Violation is Reported?
By Alan Leibowitz, director of Corporate Compliance Programs & Security

One measure of a well functioning compliance program is what happens when someone violates the Code of Corporate Conduct. Our credibility depends on appropriate corrective action being taken whenever there is a violation.

ITT Industries is committed to investigating and addressing every reported concern. We also strive to ensure that where corrective action is required it is chosen with great care so that everyone involved is treated fairly and consistently. Several of the program enhancements we implemented in 2004 were focused on that goal. Our new Compliance Review process, better data collection and improved ombudsperson accessibility are just a few examples.

Sometimes when an employee reports a potential violation they are concerned that no action will be taken. It may appear that nothing happens because we often cannot discuss the outcome of an investigation due to our commitment to confidentiality in our compliance process.

In order to keep all employees better informed of Corporate Compliance activities, we will provide an annual summary of representative cases and corrective action taken. In 2004, our compliance team received 60 reports from employees in Europe, Asia and the Americas regarding potential violations of the Code. Nearly one-third of those cases required corrective action. The following table describes some of those cases (names and specific identifying details have been removed to protect the privacy of those involved):

While the great majority of our fellow employees are honest and ethical, we still have those who take advantage of our trust or do not demonstrate the respect we demand for every employee. As you can see from the examples above, when violations occur we are firm in our enforcement of the Code. While every case is different and the specific facts determine whether and to what extent action is taken, every case is addressed. Prompt and appropriate response helps to complaints helps everyone understand that our Code applies equally at all levels and everywhere we operate.

If you have questions regarding the type of issues described above, you can discuss them with any of the points of contact listed in the Code or by submitting a question to codecorner@itt.com.

I reported a violation of the ITT Code of Conduct to my Ombudsperson. It has been weeks but I still have not heard what discipline the employee received. How can I be certain that this was addressed?

Answer: If you provided your contact information (you can remain anonymous), our Ombudsperson should get back to you to let you know that the issue has been addressed and to see if you have any questions or concerns about the process. If that has not happened, you should call the Ombudsperson.  He or she can let you know that the issue was or is being addressed, but for privacy reasons you will generally not be given any detail on the corrective action taken.

The success of our compliance program depends on alert employees like you quickly reporting their concerns. Even if you are not sure that a violation has occurred, it is always a good idea to ask questions to make sure that any potential issues are properly addressed. In this way, you are helping to keep ITT Industries the kind of place where we can all be proud to work.