InThisIssue
A Message from Alan Leibowitz, the new director of Corporate Compliance Programs and Security for ITT Industries
Welcome to our first "Code Corner." This column will be a regular feature in extra, and will be a key link to the ITT Industries Corporate Ethics and Compliance Program. We will discuss important ethics and compliance issues and answer your questions about the Code of Conduct.
Have you noticed how it's practically impossible to read a newspaper without seeing a story about poor ethical judgments that have ruined individual and corporate reputations? We never want to face that situation.
ITT Industries motto to "Do the Right Thing, Always" means we always choose the ethical path. We have a strong ethics program and a long history of establishing and enforcing an ethical culture where employees can feel secure in their company's commitment to the Code. This column, along with several other initiatives you will see in the near future, is intended to strengthen that program.
All employees are scheduled to receive introductory training in our new Code this year. As part of that training, you will have an opportunity to discuss compliance issues and ask questions about the Code.
But you don't have to wait for that training to get clear guidance about the Code. You can read the new Code online today and ask your management team to help answer any questions you might have. In addition, we have an established ombudsman system in place, with trained ITT representatives who are available to discuss the Code of Conduct or other ethical concerns. Contact information for your Management Company or corporate ombudsman can be found at the end of the Code.
Finally, I encourage you to send your questions to CodeCorner@itt.com. Each month, we will answer a few that affect the broadest audience and publish the results in this Code Corner column. All answers in this column provide general guidance; your local policies may be more restrictive.
I look forward to working with all of you to strengthen our commitment to the Code of Conduct. And now, for our first question:
-
Question:
I have been working with potential customers outside the government arena
and would like to take them to a local sporting event. Is this acceptable
under our new Code of Conduct? This would give me an opportunity to make
my final sales pitch. Could I just give them the tickets and not accompany
them to the game?
Code Corner responds: Assuming the event is not lavish or extravagant, going to the game with the customer is generally permissible under our code of Conduct as reasonable and appropriate entertainment. It has a clear business purpose - to make the final sales pitch. Simply giving the tickets without going with the customer is not allowed. The tickets would be a gift of more than token value which requires permission from your Management Company president. Permissible gift giving is generally limited to token gifts such as a hat with an ITT Industries logo. In some cases, particularly with government customers, all entertainment is prohibited by customer policy. Always ask your guest if they have such policies.
To View the Code of Conduct...
The latest version of the Code of Conduct - including translations - can be found on the ITT Industries homepage at www.itt.com.
Story Ideas