Ethics by the Numbers
The number of times Intel has made Ethisphere's list of "World's Most Ethical Companies."
WHAT IS:
14-time honoree
This communications practice should only be used when seeking legal guidance.
WHAT IS:
Attorney Client Privilege (ACP)
This comes in the form of cash payments, favors, hiring a relative of a government official, a gift, lavish travel or lodging, research grants to improperly influence a university professor, a donation to a charity connected to a government official.
WHAT IS:
A Bribe
This term is used when a reasonable person is likely to believe that a personal, financial, or outside business interest is likely to impair the ability of an Intel employee to act in the best interests of Intel.
WHAT IS?
A perceived or apparent conflict.
Examples
1) Passing around a relative or close friend’s resume for consideration without disclosing a conflict.
2) Input on the selection of supplier/vendor who is a friend or family member.
3) Conducting a side business on Intel time.
Any agreement to limit recruitment or hiring of employees is referred to as.
WHAT IS?
A no-poach agreement (Under Intel’s Antitrust Policy, legal approval is required in advance of any no-poach agreement with a competitor. Competitors include companies that compete with Intel for talent.)
Employees are more willing to take risks under threat or perceived pressure to achieve business goals or the fear of losing their job - shifting the balance towards this type of behavior.
WHAT IS?
Unethical
Side businesses may pose a Conflict of Interest and in turn require numerous steps, name one.
WHAT IS:
1. Disclose actual or perceived COIs in writing to your manager. Disclosure is mandatory.
2. Follow the Conducting Outside Business Guideline.
3. If conducting outside business:
-Obtain the approval of any new managers to whom you report
-Review and renew COI disclosures annually
https://circuit.intel.com/content/hr/legalandhr/work-env/Conducting_Outside_Business.html
Small payments made to low-level government employees as a personal benefit to them to obtain performance of a routine non-discretionary action to which the payer is entitled, such as processing a permit is referred to as.
WHAT IS:
A FACILITATION PAYMENT ("grease payments"). Not allowed at Intel
1) Although U.S. law allows facilitation payments under very limited circumstances, most other countries prohibit facilitation payments as a form of bribery.
2) Notify your manager and Intel Legal representative or Ethics Reporting Portal if a government official demands or requests that you pay a facilitation payment.
Inappropriate behaviors towards another Intel employee, customer or other 3rd party does not violate Intel's harassment guideline if the intent was not to offend? TRUE or FALSE.
WHAT IS:
FALSE
This is a Guideline Violation. Inappropriate, race-related or sexual comments/behaviors violate our harassment guidelines. The “joking” nature, innocent intent or the acceptance by a group do not change the answer.
Why we investigate issues and allegations.
WHAT IS:
Good practices
1) To listen to employees
2) Identify & fix an issue before it becomes problematic.
3) To ensure that employees are treated fairly, and that Intel performs as a long-standing ethical industry leader.
This % of employees surveyed in the 2023 EES reported they are confident that if they reported an ethics and compliance concern, they would not be retaliated against in any way.
WHAT IS?
90%
95% would be comfortable reporting an ethics or compliance concern to their manager. 96% through other channels.
92% are confident that if they reported an ethics or compliance concern, appropriate action would be taken.
If one person pays for an additional person(s) meal, this is the bucket it should be expensed under.
WHAT IS:
Business Meal.
When paying for meals/entertainment, the employee seeking reimbursement must submit the expense to a manager in the reporting chain who did not participate in the meal/entertainment. It can be COI for an approving manager to have participated in the item being expensed. This generally means that the most senior employee in the org pays the bill & submits the charges to his/her manager for approval.
This type of communication is one that is not accurate, clear, or professional.
WHAT IS:
Ambiguous or Unprofessional communication. Examples include.
exaggeration - overstating or embellishing the facts in a business communication.
inappropriate humor - distasteful jokes, disparaging comments, insulting comparisons or metaphors, and sarcasm.
language that is emotionally charged, inflammatory, profane, crude, offensive, threatening, or knowingly false.
This can include demoting, transferring or terminating an employee for speaking up in good faith about an issue of concern.
WHAT IS?
Retaliation
1) Non-Retaliation Policy: “Intel does not tolerate retaliation against anyone who in good faith reports possible violations of law, the Code, or other company policies or procedures, questions on-going or proposed conduct, or participates in an internal investigation. Retaliation can include, among other things, demoting, transferring, or terminating anyone for raising a question or speaking up in good faith about a possible violation of the Code, company policy, or law.”
2) Code of Conduct: “We do not tolerate any retaliation against employees for asking questions or making good faith reports of possible violations of law, the Code, or other guidelines”
3) Open Door Investigation Admonitions: “You should not retaliate against anyone for having involved you in this investigation nor should you be retaliated against for participating in this investigation.”
The DOJ's 2023 enforcement actions for FCPA violations can include both the Anti-bribery provision and the Accounting provision. TRUE or FALSE?
WHAT IS:
TRUE
Reporting accuracy is a must. Even a transaction that does not constitute a violation of the anti-bribery provisions can lead to prosecution under the accounting provisions if inaccurately recorded or attributable to an internal accounting controls deficiency. The Accounting provision includes
1) Books & Records - requires issuers to make and keep accurate books, records, and accounts that, in reasonable detail, accurately and fairly reflect the issuer’s transactions and disposition of assets.
(2) Internal Accounting Controls - requires that issuers devise and maintain reasonable internal accounting controls aimed at preventing and detecting FCPA violations.
The % of EES respondents that feel pressured to compromise our Code of Conduct, or the law in order to achieve business goals.
WHAT IS?
10%
Strict adherence to this policy is required if plans are in place to purchase lunch for the public university faculty members invited to attend your AI presentation.
WHAT IS?
GMET Policy
GMET covers the receiving or giving of GMET to an external party (including gov't officials) and may require manager & legal pre-approval.
University employees are considered gov't officials.
1) "Government Entity" includes state-owned companies, public universities and institutes, public hospitals, and public-school districts.
2) Government Official: Any officer, employee or person acting in an official capacity for any government entity or instrumentality, including state-owned or -controlled companies, public institutions, and public international organizations, as well as a political party official, or candidate for political office.
Personal purchases on the CTC are not allowed regardless of whether they will be expensed or paid by the employee. TRUE or FALSE?
WHAT IS?
True
https://circuit.intel.com/content/hr/mobility/travel/global-travel-expense-policy.html
This activity is a violation of Intel Policy if it interferes with the proper performance of your job at Intel.
WHAT IS?
Moonlighting
1) In addition, the activity being conducted may be a Conflict of Interest as well (actual or perceived)
2) Before accepting outside employment or engaging in any other business activity that might create the appearance of a conflict, fill out the Conflict-of-Interest Disclosure Form.
This policy applies to all employees, Board of Directors, and independent contractors, consultants, suppliers and others who do business with Intel.
WHAT IS?
Code of Conduct
The Code of Conduct sets the standard for how we win, how we work together, and how we work with our business partners and communities as we develop and deliver products and protect the value of Intel and its subsidiaries. The Code exemplifies our core values and our continuing commitment to corporate responsibility by setting forth how we work and win with integrity each day.
This action would lessen the gap between speak-up awareness, intent, and execution according to Ethisphere's 2024 world-wide culture survey.
WHAT IS?
See something say something
Managers are responsible for deciding if a behavior of a subordinate or supplier might fit the definition of harassment under the guideline or a violation of our Code of Conduct. TRUE or FALSE?
WHAT IS?
False
Managers are not responsible for deciding if the behavior might fit the definition of harassment under the guideline or a violation of the Code of Conduct. This is outside of their role.
They should listen to the employee/supplier; provide information about options to report (as appropriate), but also need to escalate if the employee/supplier does not indicate an intention to report.
A common reason an employee might make an unethical decision.
WHAT IS?
Pressure to Succeed
1) Cultural numbness: when others play along and gradually begin to accept and embody deviant norms.
2) When they don't see their action clearly causing harm; or when an employee feels that peers will not condemn their actions
3) When someone feels so overvalued and entitled that they believe the rules of decent behavior don't apply to them.
This is why you & you're work in this area is important in maintaining Intel's integrity.
WHAT IS?
Keep Intel legal, ethical & respected
Maintaining Intel’s uncompromising integrity depends on each of us living Intel’s core values, following the Code of Conduct, and asking any question or reporting any concern we may have about an action, behavior, or situation that appears inconsistent with Intel’s core values, the Code of Conduct, or an Intel policy or guideline.
Two ways to report an ethical issue.
WHAT IS?
1) Your manager
2) HR
3) Ask Ethics
4) Intel Legal