Code Corner

When in Doubt, Discuss
By Cherie Raven, manager of corporate compliance programs

If you are a regular reader of our Code Corner you might have the impression that ITT Industries is rife with people who violate our trust and our Code of Corporate Conduct (COCC). Nothing could be further from the truth. It is just that real world examples are often the best tool to illustrate a concern when discussing our compliance program. These examples are often drawn from the rare disciplinary actions employees have faced related to the requirements of our COCC. These are the types of risks that both you and ITT can face when we choose not to follow our code. If it feels wrong, it probably is.

Each of our actions affects ITT and our coworkers. Your commitment to quality encourages others to do their best work. When we all do our best we create superior products that our customers want to buy. When we treat customers fairly ITT gains a reputation for integrity and becomes an attractive investment. Our revenues and stock price reflect your hard work.

This all happens because ITT employees are good people. Most of us want to do the right thing.  When we are not sure what that is, we can reach for the Code, talk to a supervisor, HR, an Ombudsperson or any of the other "Points of Contact" listed in the COCC. Anticipating and discussing potential conflicts with the code before they occur is always our best course of action. Recently a senior manager at one of our Value Centers anticipated the potential for a significant conflict of interest. (See sidebar). He discussed his concerns with his management and the compliance staff to ensure that guidelines were established and appropriately communicated to prevent even the appearance of misuse of his position with ITT. This is an excellent way to resolve an ethical dilemma. When in doubt, discuss.

Our Partnership for Performance and Value-Based Leadership Development processes include the notion of "Leading with Character." Whether we work on the assembly floor or manage a division each of us has the power to lead, and the responsibility to be Ethical Leaders. This means more than following the Code. It requires that we visibly practice our core ethical values. We make it clear that we are being honest, even when that means telling people that you don't know, or cannot share certain information. We show respect to everyone around us, even when having difficult conversations. We regularly talk about the ethical components of business decisions. Hold yourself to highest standards of behavior, and openly expect others to do the same. Clearly communicating your personal and professional commitment to our Code and Values is all it takes to be an Ethical Leader.

An Ethical Role Model

Even with the best of intentions potential conflicts of interest arise every day. Recently one of our field leaders saw the potential for his position at ITT to appear to inappropriately benefit a political campaign he was considering. He wanted to ensure that no employee felt coerced to support him and that no ITT resources would be used. He did not want to take advantage of the company or his fellow employees, but knew that some people might perceive him to be doing so.

He brought the situation to his supervisor and they met with members of our compliance team. The individual knew what he wanted to do, and everyone in the room knew what the Code and Policies said. They discussed the situation and together found some surprisingly simple solutions to many of the issues involved.  The final plan protects both the individual and the company. In this case "Doing the Right Thing" meant establishing clear, enforceable controls on fundraising and ITT employee participation in the campaign. This might make it a little more difficult to raise the required funds but it ensures a strong campaign since everyone who participates truly supports the candidate. A situation with real potential to become a code problem was turned into a positive example for all of ITT.