Western Digital’s Global Code of Conduct (GCOC) informs our employees of their legal and ethical obligations to the Company and to its employees, customers, competitors, and suppliers. Western Digital embraces diversity in setting one global set of expectations for its workforce worldwide through our Global Code of Conduct. The standards set forth in the GCOC are supported by more detailed Company policies and procedures, which supplement or implement those standards. These policies and procedures provide clear, specific guidance concerning many of the business practices and expectations discussed in the GCOC.
We translate the GCOC into many local languages. It is available, in hard copy and/or online, to all employees. We also inform employees that they are expected to comply with the GCOC and that failure to do so can result in discipline.
Each year, we conduct mandatory training on the GCOC in English or translated into local languages. The training includes a certification to verify that each employee has read and agrees to comply with the GCOC. In addition, the Company conducts an annual disclosures questionnaire on GCOC topics for senior members of management and other key designated employees with special responsibilities. The results of this questionnaire as well as the GCOC training results are reported to the Audit Committee by the Chief Compliance Officer.
A copy of the Global Code of Conduct can be accessed by clicking here.