Business Integrity And Ethics

Global Code Of Conduct

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.

Code Of Business Ethics

Western Digital’s Board of Directors has also adopted a Code of Business Ethics, the goals of which are to:

  • Promote honest and ethical conduct, including the ethical handling of conflicts of interest
  • Promote full, fair, accurate, timely and understandable disclosure in Company reports
  • Promote compliance with applicable laws and governmental rules and regulations
  • Promote prompt internal reporting of violations of this Code
  • Ensure the protection of the Company’s legitimate business interests, including corporate opportunities, assets and confidential information
  • Deter wrongdoing

The Code of Business Ethics provides a framework for ethical business conduct and is not intended to establish rules governing every possible instance that could arise. The Code of Business Ethics sets forth general legal and ethical principles, and directors, officers and employees must use good judgment and common sense in applying them, and in deciding when to seek guidance from others as to the appropriate course of conduct.

A copy of the Code of Business Ethics can be accessed by clicking here.

Ethics Helpline

As part of its commitment to maintaining the highest standards of workplace integrity, Western Digital maintains a toll-free Ethics Helpline. The Helpline is managed by a third party provider, and is staffed 24 hours a day, 365 days a year. While primarily intended for current Western Digital employees, the helpline is available to third parties, including business partners and former employees.

Employees may report suspected instances of ethical misconduct within Western Digital, including but not limited to:

  • Trading on inside information or providing illegal tips
  • Workplace harassment or discrimination
  • Illegal gifts or bribes
  • Fraud, embezzlement or theft
  • Questionable accounting or auditing matters

The Ethics Helpline is intended to provide employees with another avenue for reporting suspected misconduct. Employees may use the Helpline to report a concern or ask a question at any time. Western Digital prohibits retaliation against an employee who reports suspected misconduct in good faith.

The Ethics Helpline can be accessed by clicking here.

Anti-Corruption

Western Digital believes it is essential that its employees and business partners comply with applicable global anti-corruption laws.

Western Digital prohibits any of its or its subsidiaries’ employees, consultants, agents or representatives from offering, paying or receiving bribes, or from authorizing the same.

Western Digital has published a comprehensive anti-corruption policy, which is published on the Company’s internal website. In addition, compliance with the provisions of global anti-corruption laws is discussed in multiple Company policies including its Global Code of Conduct. Employees are regularly trained on the anti-corruption policies and procedures.

Corporate Governance Guidelines

Our Board of Directors has adopted a set of corporate governance guidelines which represent the Board's current thinking with respect to selected corporate governance issues considered to be of significance to stockholders. These guidelines, along with the charters of the committees of the Board, provide the framework for the governance of the Company. The guidelines are only guidelines and not rigid rules. The Board’s Governance Committee will continue to assess the appropriateness and efficacy of the guidelines and recommend from time to time changes for approval by the Board as it deems appropriate in the best interests of the Company or as required by applicable laws and regulations.

A copy of the Company’s current corporate governance guidelines can be accessed by clicking here.

A copy of the charters of the committees of the Board (Governance Committee, Executive Committee, Compensation Committee and Audit Committee) can be accessed by clicking  here.