Our Corporate Compliance Office has a comprehensive program in place to guide compliance with Ford Policies and Directives as well as key legal requirements. The Corporate Compliance Office is part of Ford's Office of the General Counsel, and our corporate compliance program is overseen by a senior management compliance committee and the Audit Committee of the Board of Directors. The compliance program includes a variety of activities. The program raises awareness of the Company's commitment to ethical practices, defines corporate practices through Policies and Directives, ensures an infrastructure that allows for the reporting of Policy violations or business-related legal violations through a number of avenues worldwide, oversees the investigation of such reports, conducts risk assessments, and provides training and education on key legal and ethical risk areas.
Our Policy Letters and Directives formally establish expectations for our employees and others working on behalf of the Company, and our Code of Conduct Handbook is the fundamental tool for communicating these expectations.
The Code of Conduct Handbook, our chief ethical guidance document, underwent a major revision in 2007. In this high-impact initiative, the document was restructured and revised to make it easier to understand and use as a reference manual. In its new incarnation, the Code of Conduct Handbook is a compilation of the most important and relevant Policies, Directives and standards for Ford employees. It is now more global in content and is available in 13 languages. The online version includes active links to the original source documents, thus providing a single source for the relevant information.
The revised Handbook outlines employee behavior requirements and provides background resources for a wide range of business-related situations, including:
Virtually all salaried employees around the world are required to certify that they have reviewed the new Handbook. Beginning in 2008, contract personnel will also be required to make the certification.
To reinforce information contained in the Code of Conduct Handbook, we will introduce a new mandatory training course in 2008 for our global employees and other targeted personnel. The course will focus on ethics, conflicts of interest, gifts and favors – topics on which we have long provided employee training – as well as additional issues that have global applicability.
In furtherance of our commitment to business ethics and compliance, every year we roll out mandatory online compliance training on various subjects. Not only do these courses increase awareness, they also help our employees worldwide to understand and access resources that enable responsible behavior and enhance regulatory compliance.
We continually review our Policies and Directives and make revisions and updates as necessary. This year we revised Policies related to anti-bribery, and provided additional information in other corporate documents. We also performed in-person anti-bribery training.
Another component of our compliance program is an infrastructure that allows for the reporting of any potential violations of our Policies and Directives and any violations of laws related to the business. Our nonmanufacturing workforce and contract personnel are regularly reminded of their responsibility to report any known or suspected violation of the law or Company Policy, as are our manufacturing workforce in plants through posters. There are many ways for individuals to report known or suspected violations, including direct communications to a member of one of the control groups – such as the General Auditors Office or the Office of the General Counsel – as well as telephone tip lines in many regions, email and Company intranet sites.
We assess compliance with our ethical standards through regular legal audits that cover a range of topics relating to legal requirements and internal Policies. These are in addition to audits regularly conducted on issues such as workplace health and safety.