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.
The Helpline is managed by Navex Global, a leading provider of customized helpline services, and is staffed 24 hours a day, 365 days a year. While primarily intended for current Western Digital employees, the helpline may be used by other interested parties, including vendors, customers and former employees.
To make a report via telephone, please use the following telephone numbers by country. Concerns are always confidential.
Japan: 0066-33-830444 (Softbank); or 00-539-111 (KDDI); or 0034-811-001 (NTT)
Philippines: Dial 105-11 or 1010-5511-00 (PLDT), then dial 855-216-6129 at the prompt
United States: 1-877-548-6716
All other countries: Dial your country’s AT&T Direct Access Code from this list, then dial 877-548-6716 at the prompt
All other countries: Dial your country’s AT&T Direct Access Code from this list, then dial 877-548-6716 at the prompt. To make a report via the web, access the web-based Ethics Helpline reporting system at: www.EthicsHelplineWDC.com.
Employees are encouraged to report suspected instances of ethical misconduct within Western Digital, including:
Trading on inside information or providing illegal tips
Workplace harassment or discrimination
Illegal gifts or bribes to or from government officials, vendors or customers
Fraud, embezzlement or theft
Questionable accounting or auditing matters
Conflict mineral sourcing
The Ethics Helpline is intended to provide employees with another avenue for reporting suspected misconduct. Employees may use the Helpline if they believe that a problem cannot be addressed through their supervisors or the human resources staff, and employees may remain completely anonymous when they communicate with the Helpline’s operators. Western Digital will not allow any retaliation against an employee who contacts the Helpline and reports suspected misconduct in good faith.
Western Digital Corporation’s Global Code of Conduct provides information about the minimum standards of integrity that Western Digital Corporation expects all of its employees worldwide (including those of WDC’s subsidiaries) to follow and takes into account varying practices due to cultural differences in international locations. The standards set forth in the Global Code of Conduct are supported by more detailed Company policies and procedures, which are issued in various geographic regions to supplement or implement those standards. These policies and procedures provide clear, specific directions concerning many of the business practices and behaviors discussed in the Code.
A copy of the Global Code of Conduct in the appropriate language is given, or is available online, to all employees of Western Digital Corporation (including employees of domestic and foreign subsidiaries). In addition, new employees are given a copy of the Code of Conduct on their first day of employment. All employees are informed that they are expected to comply with the provisions of the Code of Conduct and that failure to do so is regarded as misconduct that can result in disciplinary action.
Each year, senior members of management and several hundred key designated employees worldwide are required to complete an online disclosure certification confirming that they have complied with the provisions of the Global Code of Conduct. This certification process is required by the Audit Committee and is managed by the Corporation’s General Counsel.
Western Digital’s Ethics & Compliance team conducts regular risk assessments, including both enterprise-wide risk assessments and subject-specific risk assessments in areas such as anti-corruption and privacy. Privacy risk assessments consider, among other things, Western Digital’s use of technology and its practices around user, partner, and employee data.
Western Digital Corporation believes it is essential that its employees and business partners comply with global anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and the anti-bribery laws of the countries in which the Company operates.
Western Digital prohibits any of its or its subsidiaries’ employees, consultants, agents or representatives from corruptly seeking to obtain or retain business by offering, paying or offering to pay money or provide other things of value to foreign or commercial officials for the purposes of:
Influencing any act or decision of such official in his/her official capacity, or
Inducing such official to do or omit to do any act in violation of his/her official duty, or
Inducing such official to use his/her influence with a foreign government or instrumentality thereof to affect or influence a governmental act or decision, or
Securing an improper advantage
Western Digital has published a comprehensive policy relating to Anti-Corruption, which is published on the Company’s internal website. In addition, compliance with the provisions of global anti-corruption laws is discussed in both the Company’s Global Code of Conduct and Employee Handbook.
Public Policy Activities
Western Digital participates in legislative, regulatory, and public policy affairs as deemed by management and the Board of Directors to be in the best interests of the Company. The Board of Directors’ Governance Committee, which consists solely of independent directors, reviews and approves on at least an annual basis the Company’s political and lobbying strategy, activities and expenditures, including payments to trade associations, and the policies and procedures regarding the foregoing. The Company’s Government Affairs function directs all political activity on the federal, state, and local level, in compliance with the Western Digital U.S. Political Activities Policy, where applicable.
The Company does not have or support a political action committee. Prior approval by the Governance Committee is required to use corporate funds or resources for donations to local, state, or national elections, whether to candidates, political parties, non-candidate organizations, Section 501(c)(4) organizations, Section 527 organizations, or local or state ballot measures.
Information regarding Western Digital’s trade and industry association memberships can be found here.