Ethics and Compliance Program

 

Alcoa is a global company with operations in diverse cultural, political and economic environments. In all of our operations, our Values and integrity remain the driving force as we achieve our objectives. Our commitment to be open, honest and accountable, and to make decisions with the highest ethical standards, has guided the company and our employees since 1888.

 

Our ethics and compliance approach is grounded in our Values. We insist that our employees worldwide understand and are committed to acting with integrity, complying with all applicable laws and regulations, and adhering to our policies and procedures.

 

The Ethics and Compliance organization is responsible for the development and implementation of our Ethics and Compliance Program, including our global Anti-Corruption and Trade Compliance programs.

 

Our Ethics and Compliance Program includes:

  • Guide to Business Conduct and other directional documents;
  • A Global Integrity Champion Network that partners the businesses, resource units, and the Ethics and Compliance organization to further embed the Ethics and Compliance Program into business operations;
  • Anti-Corruption Program;
  • Trade Compliance Program;
  • Training on all aspects of ethical behaviors, including business conduct, anti-corruption, and trade compliance;
  • An Ethics and Compliance Line available 24 hours a day, 7 days a week in 14 languages;
  • Investigations and risk assessment procedures and tools;
  • Annual Business Conduct and Conflict of Interest Survey Certification;
  • Advice to business and resource units on ethics and compliance matters; and
  • Records Retention Program.

 

Guide to Business Conduct

Our Guide to Business Conduct applies to all company directors, officers, and employees. The guide sets forth expectations regarding how we conduct business worldwide, consistent with our values and applicable laws and regulations.

 

Available on alcoa.com in 16 languages, the guide defines our commitment to always do the right thing; protect those who report ethics and compliance concerns; and discipline those who do not meet Alcoa’s high ethics and compliance standards.

 

Supplemental Guides

The Guide to Business Conduct in a Manufacturing Environment discusses business conduct issues most relevant to our manufacturing employees. Topics include health and safety, respect and fair treatment, non-retaliation, responsible use of company assets, human rights, harassment, and employee privacy.

 

The Alcoa Supplier Standards  outline our expectations concerning supplier conduct. We set high standards for conducting business and expect our suppliers to share these standards.

 

Our Speak Up for Ethical Leadership Guide emphasizes that every Alcoan is a leader in promoting an ethical culture.  It encourages all employees to create a “speak-up” culture in which all views and opinions are respected.

 

Integrity Champion Network

In October 2013, we launched our Integrity Champion Network to better integrate our Ethics and Compliance Program into business operations.

 

The champions, nominated by our senior business and resource unit leaders and confirmed by the Ethics and Compliance organization, play a key role as they work at the local level to:

  • Ensure that ethics and compliance are an integral part of decision making and business strategy;
  • Promote a culture of integrity, where employees are encouraged to speak up about ethics and compliance issues and concerns;
  • Raise awareness of the role that ethics and compliance plays in all aspects of Alcoa’s business; and
  • Serve as a trusted advisor and resource on issues related to ethics and compliance.

 

Partnering with their management teams and the Ethics and Compliance organization, the Integrity Champions work to further embed and enhance a values-based culture of integrity and compliance.

 

Anti-Corruption Program

Our Anti-Corruption Policy reflects our strong commitment to conducting our operations around the globe ethically and in compliance with all applicable laws. Our directors and management believe that the way we achieve results is as important as the results themselves. 

 

Vigilance in complying with anti-corruption and anti-bribery laws, including those based upon the OECD Convention, the U.S Foreign Corrupt Practices Act, and other local anti-corruption laws, is critical for a global company.

 

Our Anti-Corruption Program includes:

  • Anti-Corruption Policy;
  • Due Diligence Review Process for Intermediaries;
  • Gifts and Hospitality Procedure;
  • Charitable Contributions Policy and Procedure;
  • In person and web-based trainings; and
  • Monitoring, audit, and assessment

 

Trade Compliance Program

Our Global Trade Compliance Program demonstrates our commitment to trade compliance in the purchase, sale, and use of our products, technologies, and services worldwide. The hallmarks of this program are:

  • Export / Import Compliance Policy and procedure;
  • Trade compliance leads in all Alcoa business units;
  • Specialized procedures;
  • Monitoring, audit and assessment; and
  • Focused training.

 

Ethics and Compliance Training

All newly hired Alcoa employees are required to participate in our “Do What’s Right!” training, which serves as an introduction to our corporate Ethics and Compliance Program and our Values. As part of the on-boarding process, employees receive a copy of our Guide to Business Conduct and information about the Ethics and Compliance Line.

 

Alcoa employees who meet certain criteria must also participate in online ethics and compliance training, available in 16 languages. The selected courses provide education on a variety of business and compliance issues and reinforce our business conduct standards. Those enrolled in the online training program complete approximately four courses per year.

 

Employees who do not participate in the online training program complete annual shop floor training, which emphasizes the importance of knowing and complying with laws, regulations, and company policies; asking questions in uncertain situations; and raising concerns when suspected or known violations occur.

 

Ethics and Compliance Line

We encourage our employees to report concerns and issues to their local supervisors, work teams, legal, ethics and compliance, or other professionals by using their normal communication channels and problem-solving processes.

 

Our global Ethics and Compliance Line provides employees and any other concerned parties another confidential channel for raising concerns and issues about workplace activities and business practices. Employees are encouraged to use the line, as permitted by local law, to obtain guidance on legal or regulatory requirements, seek clarification of Alcoa policies or procedures, or simply ask for advice on appropriate behavior.

 

Toll-free compliance line numbers are available worldwide with calls answered in the caller’s native language. We also offer an ethics and compliance e-mail address, fax number, and a postal mail address for submission of written inquiries. Web reporting is available in certain jurisdictions, providing another confidential mechanism for individuals to report concerns and ask questions.

 

With regard to allegations of breaches of law or policy, we address 100% of all issues raised to the Ethics and Compliance organization, no matter how they are received. Of the total issues raised during 2013 (as of May 24, 2014):

  • 28% of all closed matters were substantiated;
  • 92% of all substantiated matters resulted in some form of discipline; and
  • 48% of all substantiated matters resulted in process improvement changes.

 

Alcoa’s business conduct policies prohibit retaliation against employees who report matters in good faith.

 

Internal Investigations

The Ethics and Compliance organization manages and conducts internal investigations of alleged misconduct by employees and business partners. We use a team approach working with legal, human resources, finance, internal audit, and other departments, as appropriate.

 

We periodically update our Internal Investigations Guidelines and investigator training. Any employee who is asked to participate in an investigation must complete our investigator training.

 

 

Business Conduct and Conflict of Interest Survey Certification

Each year, selected employees are required to reaffirm their commitment to our values and ethics-related policies through the Business Conduct and Conflict of Interest Survey Certification, a confidential reporting mechanism.

 

Survey participants declare any potential conflicts of interest and certify compliance with Alcoa’s Business Conduct, Anti-Corruption, Insider Trading, and Conflict of Interest policies.

 

Awards and Recognition

Ethisphere Institute—Research-based Ethisphere Institute is a leading international think-tank dedicated to the creation, advancement, and sharing of best practices in business ethics, corporate social responsibility, anti-corruption, and sustainability. In 2012 and 2013, the institute selected Alcoa as one of the World’s Most Ethical Companies.

 

Alcoa's Values Endure

A Letter from CEO Klaus Kleinfeld to Employees
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Guide to Business Conduct

Download a PDF version of our Guide to Business Conduct*, published for Alcoa employees.
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Business Conduct Policies

See the full text
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Insider Trading Policy

See the full text
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