Compliance Ethics

The Company’s Compliance and Ethics program is designed to foster a culture of ethical conduct and ensure compliance with Company policies and applicable laws.

The Company’s Compliance and Ethics organization consists of (i) the Compliance and Ethics Executive Committee, whose members are the Company’s Chief Legal Officer, Controller, VP of Internal Audit and Chief Compliance and Ethics Executive, and (ii) the Office of Compliance and Ethics, which is managed by the Chief Compliance and Ethics Executive who reports to the Chief Legal Officer.

The Company’s Compliance and Ethics program seeks to achieve continuous improvement through a holistic approach that emphasizes our Company’s core value of "Integrity Always." It has many components, including communications and training on the Company’s Code of Conduct, legal compliance training, outsourced telephony and web reporting facilities, periodic legal compliance risk assessments and culture surveys.

The Office of Compliance and Ethics issues regular reports on significant developments and program activities to the Company’s Executive Chairman and Chief Executive Officer. In addition, the Office of Compliance and Ethics reports periodically to the Audit Review Committee of the Board of Directors.