Code of Conduct
Our Code of Conduct, established for our management team when the Company was founded and expanded to all associates in 1992, requires all associates to commit to ethical conduct, honesty, integrity and fairness in all business affairs.
The Code sets expectations for our associates to do the right thing, be accountable for their actions and report actual or suspected violations.
Signing the Code and attending annual ethics training are conditions of employment. New hires complete training on the Code within the first 30 days of employment and are required to complete annual refreshers on the Code. We last updated our Code of Conduct in November 2010. We continue to strengthen our ethics training and awareness efforts through the several strategies, including:
- Inclusion of frequently asked questions (FAQs) in the Code. The FAQs contain illustrative scenarios to better guide our associates.
- Annual training on the Code offered online or through live presentations. Targeted antitrust and anticorruption training is provided to associates whose job responsibilities may be impacted by related regulations.
- Development and external acquisition of companywide training materials. Each operating company has the flexibility to adjust annual training to meet local needs and state training requirements.
- Utilization of the AlertLine Reporting System (see below), including awareness campaigns, targeted education and training for related staff and expansion of customized training materials to cover the new system.
- Operating company reviews by Sysco's Internal Audit Department, including confirmation of Code of Conduct receipt and ethics training for new hires and annually for incumbents.
The responsibility for administering the Code rests with the Ethics Compliance Group, with oversight by the General Counsel, the Ethics Advisory Board and the Corporate Governance and Nominating Committee of the Board of Directors.
A separate Code of Conduct, similar in scope, was developed in November 2010 to cover the issues and concerns facing our directors.
The Codes of Conduct for associates and non-employee directors can be accessed here.
Supplier Code of Conduct
We explicitly require that our suppliers adhere to all applicable laws and regulations to provide and recognize a basic level of human rights for workers within their own supply chains. All suppliers are asked to review and agree to the principles outlined in the Supplier Code of Conduct.
As a condition of doing business with Sysco, suppliers are informed they may be audited on the Code by Sysco or independent agencies at any time, with or without advance notice. Suppliers must allow unrestricted access to facilities and relevant records for the purpose of monitoring compliance with this Code.
If a supplier violates this Code, either generally or with respect to a particular supplier facility, we may either terminate its business relationship with Sysco or require the affected facility to implement a corrective action plan. We will continue to develop monitoring systems to assess and ensure compliance with this Code. Read more about how we monitor suppliers here.
We encourage associates and third parties to report concerns to us about suspected unethical behavior promptly. They can do this through any of the vehicles below.
- The AlertLine Reporting System: Partnering with a third-party vendor, Sysco utilizes the AlertLine as a formal, confidential communication reporting channel for associates and members of the public. The system includes online web reporting and a global, 24-hour, toll-free hotline with translators available. AlertLine is our primary formal mechanism for reporting ethical concerns. Its case management system is used to track and document all reports, regardless of whether or not the case is initiated via AlertLine.
- Sysco Management and Sysco.com: Associates and members of the public may contact the company via direct communications to members of management through letters, phone calls and emails, as well as web messages via Sysco.com. Messages are captured in the AlertLine case management system for investigation and response.
- "Open door" reporting: Associates can speak with a manager or human resources representative via phone or correspondence, with reports captured in the AlertLine system for investigation and resolution.
- Sysco Speaks: This engagement survey includes opportunities for associates to assess whether or not they feel comfortable reporting unethical practices without fear of retaliation and whether or not they feel senior leadership would act on reports of violations. Read more about the Sysco Speaks Survey here.
- Corporate Governance: Associates, investors and the public may contact the Board of Directors. Concerns may be communicated via mail in care of the Office of the Corporate Secretary or the Audit Committee of the Board and by phone or web messages through the AlertLine. Corporate Governance and Contact the Board communication is provided via links on Sysco.com.
During FY2014, 498 reports were processed via the AlertLine, compared to 398 in FY2013. The AlertLine offered employees and others the opportunity for anonymous and confidential reporting and ongoing communication; 51% of reports were filed anonymously in FY2014.
Sysco developed a central repository for documenting annual ethics and compliance training when it began enterprise-wise training in February 2014. Core training requirements include ethics, food safety, antitrust and global anti-corruption. Historically, each local operating company determined whether to conduct annual training on a fiscal or annual calendar basis, so fiscal year statistics alone did not fully reflect training. Live training was tracked through sign-in sheets, which are retained for review of operating companies as well as to document training compliance. Online training completion is tracked through our online learning management system, Sysco Interactive University. Uniform training requirements and reporting now provide data on overall participation; more than 44,000 associates completed annual ethics and food safety training in 2014.
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