Operating ethically and leading with integrity
Our Corporate Compliance Program integrates our obligations and commitment to integrity into our day-to-day business practices. We expect our employees and business partners to follow the highest ethical standards. By operating ethically and leading with integrity, we’ve earned the trust of our employees, customers, suppliers, investors and the communities where we live and work.
Provided tone-at-the-top live training at 38 sites located in 13
countries, representing 81% of total headcount
Provided training in a variety of forums, including leadership
conferences, regional and corporate staff meetings and site-level
Ninety-seven percent of our employees completed the CoBCE
Flex Corporate Compliance Program links compliance-related activities and teams through a common management system designed to prevent violations of regulatory requirements. The program is led by a council of compliance directors who are subject matter experts in specific areas of legal compliance. Each compliance director is responsible for an internal controls system that includes written policies and procedures, training, monitoring and assessment.
Code of Business Conduct and Ethics (CoBCE)
The CoBCE serves as the foundation of our Ethics and Compliance program. Endorsed by executive management and the Flex Board of Directors, it details the values, standards and responsibilities that help guide our behavior and decision-making processes. It also outlines the employee’s obligation to report suspected ethical violations and reinforces our open-door and anti-retaliation policies. The Code is available in 16 languages and accessible on our internal and external websites.
Ethics and compliance training
Our Code of Business Conduct and Ethics training is required annually, and anticorruption training is assigned every two years. We actively monitor the completion rates of these trainings and broadly communicate their importance in maintaining our culture of compliance. We rolled out a new online Code training course in January 2016.
In addition to online training, we provide live training globally on key compliance issues for our executives and employees in leadership conferences, regional and corporate staff meetings and site level trainings. In 2016, we provided Tone-at-the-Top training at our highest risk sites. This live training was conducted by our Chief Compliance Officer and the VP of Audit and Risk Management.
We conduct regular internal audits and maintain metrics around compliance to monitor performance and drive continuous improvement. Flex has an internal Ethics and Compliance program website and a quarterly newsletter, where we promote awareness of the program and policies. We periodically send out surveys to employees throughout the world to gauge the state of the company’s ethical culture and to identify areas of opportunity. All employees complete training annually on key compliance issues. Officers and senior managers also certify that there are processes in place to support the company’s Ethics and Compliance program.
The Code of Conduct prohibits unethical behavior such as conflicts of interest, kickbacks, bribery, fraud, improper accounting and the inappropriate use of company assets or funds. It mandates compliance with the laws of the countries in which we do business. It also requires the protection of confidential information and intellectual property, the selection of suppliers in accordance with set business criteria and strict adherence to all public reporting requirements. We vet third-party representatives, potential merger and acquisition targets, suppliers and other key associates and supply chain partners to help ensure that we only engage with legitimate parties that have a reputation for integrity.
Flex provides multiple avenues for reporting suspected violations of our Code of Conduct. In addition to local reporting channels, Flex also has a toll-free hotline and an online reporting channel, available 24 hours a day, every day of the year, in multiple languages. See list of toll-free numbers.
We’ve a cross-functional team from Brand Protection, Human Resources, Internal Audit and Legal who investigate allegations. We follow a formal, consistent method for addressing alleged violations and complaints and direct them to the appropriate functional area for investigation, resolution and closure. Violations of our Code of Conduct result in some form of disciplinary action, including counseling, training, warning letters, or in some cases, the employee’s contract is rescinded. Resolution may also involve changes to internal processes or policies to prevent further violations.