In 2019, we focused on enhancing our compliance
framework by developing a dedicated ethics and
compliance program and corresponding strategic
plan. Through this, we were able to significantly
increase the resources devoted to our compliance
function. Our Chief Ethics and Compliance Officer
(CECO), a member of the executive leadership team,
leads the effort to further develop our ethics and
compliance program across the entire corporation.
The CECO is assisted by other leaders who focus
on key areas (including environmental, health, safety
and various general compliance issues), as well as
important processes (investigations, compliance
training, risks, and communications). It is important
to note that the Ethics & Compliance is not just a
single Department within All Brands Groups - but
rather a corporate-wide program - with key Ethics &
Compliance Officers (also known as “ECO’s”) who
help shape and implement the program initiatives in
each of the operating companies.
Through the collective efforts of these leaders,
this corporate-wide program involves compliance
risk management, improved compliance training programs for our employees, thorough
investigations and remedial actions relating to health, environmental and safety incidents, and efforts to strengthen our corporate culture. To further heighten the focus on ethics and
compliance, the Boards of Directors established
Compliance Committees to oversee the ethics and compliance program, maintain regular
communications with the Chief Ethics and
Compliance Officer, and ensure implementation of
the ethics and compliance program’s strategic plan
across the corporation.