Code Corner:
A Look at Our "Ethical Performance" in 2005
By Cherie Raven, manager of corporate compliance programs
As we look back on 2005, we can all be proud of the progress ITT made in strengthening our already robust compliance program to ensure we meet the highest ethical standards every day.
We continued along our path to a future where every employee recognizes their essential role in creating a positive organizational culture: treating each other with respect; being truthful and honest; acting with integrity; and taking responsibility for our actions. Employees and managers had the courage to discuss difficult issues, express concerns, and hold each other accountable for their behavior.
In 2005 the ombudspersons and corporate compliance program were asked to follow up on 76 potential violations of law, regulation or ITT policy. This increase -- from 60 requests in 2004, and 31 in 2003 -- is a positive trend and reflects greater awareness and trust in our program.
Despite this performance we know that there are still situations that individuals want to report, but do not. To encourage compliance reporting among ITT employees, we work to ensure no one faces negative consequences for raising concerns, and we take action when problems are confirmed. The table below demonstrates some of those actions.
Case Type |
Action Taken |
Issue |
Conflict of interest |
Terminated |
Manager hired family member and approved invalid medical expenses. |
Theft |
Terminated |
General accounting clerk stole and forged three checks. |
Conflict of interest |
Manager reprimanded. |
Manager paid employees to do landscaping work at his home during off hours. No ITT funds used. |
Abuse or misuse of ITT resources |
All terminated |
Three employees set up a business to compete with ITT while still on the ITT payroll. |
Sexual harassment |
Employee: terminated |
Employee sexually harassed co-worker. Manager ignored the behavior. |
Discrimination –National Origin |
Final warning and demotion |
Employee made improper remarks regarding coworkers national origin. |
Of the 76 cases that were investigated in 2005, most were simply misunderstandings. However, twenty-two of the investigations did require disciplinary action: nine led to terminations; two received final warnings; two were demoted; and eight brought reprimands. All reports are taken seriously and we respect the confidentiality of everyone involved.
As we all become more confident and aware of our individual responsibilities under the ITT Compliance and Ethics process, these numbers will continue to grow until all issues are surfaced and addressed. Our progress on this path should be encouraging to every ITT employee. Thanks to you and your participation in our program we are closer than ever to ensuring that we all "Do the Right Thing -- Always".
A Positive Trend
The increase in compliance investigations reflects employees' willingness to report potential violations and shows greater awareness and trust in ITT’s compliance and ethics program.