Goodyear’s Compliance & Ethics (C&E) Department provides updates on ethics and compliance activities to the Board of Directors multiple times per year. The Board Committee on Corporate Responsibility and Compliance reviews the activities and processes designed to uphold our commitment to ethical behavior.
Our global and regional C&E Committees – composed of top company leaders from business and functional areas – meet several times a year to discuss compliance and ethics matters, initiatives, and training. We also update policies and procedures as needed.
Goodyear’s Business Conduct Manual, updated in 2018, guides our Board of Directors, executive team, and all associates globally. It defines behaviors necessary to support our high standards and reinforces associate compliance with all applicable laws and business practices. The Manual is available on our corporate website, company intranet and in hard copy for associates without internet access. It is available internally in 16 languages to help ensure global comprehension. We regularly update our Manual to ensure it reflects the current workplace and regulatory landscape. On an annual basis, salaried associates must review and affirm their knowledge of the Manual, promise to abide by it and disclose any known violations of certain policies.
We expect every associate to know and understand our compliance and ethics policies and to abide by them. Goodyear requires almost all global salaried associates and new hires to complete online training covering the Manual and key compliance policies. In 2020, more than 96% of those associates completed online training courses on such subjects as workplace respect, discrimination and harassment, financial integrity, privacy and data protection, and anti-corruption and anti-bribery. We have a three-year training cycle that we review and amend annually to ensure our ethics and compliance training topics remain relevant and address the risks facing Goodyear.
Notwithstanding the pandemic, Goodyear was committed to reaching associates wherever they were during the year for compliance training and programs. We conducted in-person and virtual trainings across all strategic business units as well as focused compliance campaigns in many countries and plants on various subjects, such as respect in the workplace (including harassment and discrimination), conflicts of interest, competition law, speaking up, preventing and detecting fraud and bribery, gift and entertainment policies, and privacy. Additionally, our Compliance Week campaigns were held in selected locations around the globe for salaried and hourly associates and covered a wide range of topics through a variety of communication methods, including leadership messages or videos, electronic communications, newsletters, messages on internal digital screens, posters and team huddle sessions (in person and/or virtually).
Goodyear’s Quarterly Ethics Awareness Campaign, covering topics from the Manual, takes place in our company-owned retail, wholesale and commercial tire service locations in the U.S., United Kingdom, France, Germany, Canada, Japan, Africa, Australia, and in our Airship Operations and the Hebron facility. During the 2020 quarterly campaign, managers led their teams in conversations on compliance and ethics subjects such as wage and hour compliance, privacy and safety.
All associates are required to report any actual, suspected, or potential misconduct to management or through the Company’s Integrity Hotline. Available 24 hours a day, 7 days a week from anywhere in the world via toll-free telephone or by a dedicated website, our Integrity Hotline allows associates and third parties to report a concern or ask a question, including anonymously (where allowed by law).
The C&E Department reviews each Integrity Hotline matter and, in cases where an allegation of misconduct is substantiated, the Company takes appropriate disciplinary or remedial action. Goodyear strictly prohibits retaliation against individuals for making a report in good faith. Speak Up education and awareness campaigns are held to remind associates of the Integrity Hotline and to encourage them to raise questions or concerns.
Like many global companies, Goodyear faces data security risks, and monitors new and developing regulations and best practices to anticipate and mitigate such risks. For example, in 2018, the European Union’s General Data Protection Regulation (GDPR) replaced the Data Protection Directive 95/46/EC. In 2019, California passed a comprehensive new privacy law, which was amended in 2020, and many other countries and US states are contemplating or have passed similar legislation. As a response to these and other regulations, we updated our Global, Online, and Associate Privacy Policies to comply with these regulations and privacy best practices and implemented additional training programs for associates who interact with personal information. In addition, we took other actions designed to protect the personal data of our associates, customers and suppliers.
To ensure Goodyear’s compliance with all appropriate regulations, our C&E Department continually monitors and prepares for upcoming regulations and works to anticipate and mitigate any potential compliance and ethics risks.