Corning’s Code of Conduct addresses how Corning employees align their behavior with the company's Values. By following the Code, we act in accordance with our Values and we ensure that we are in full compliance with the laws and government regulations that apply to Corning. The Code of Conduct provides guidance on risk areas that may arise in Corning’s businesses, informs employees how to report concerns, and states Corning’s commitment to investigate and remediate violations and to protect individuals from retaliation.
In order to ensure the effective implementation of Corning’s Code of Conduct, Corning maintains a Compliance Council, made up of senior leaders, that oversees Corning’s Compliance Program. Under the authority of the Compliance Council, employees are assigned to complete training regarding Corning’s Code of Conduct, as well as training on other compliance topics such as anti-corruption and antitrust and competition. The frequency of this training varies depending on employee role, level, and location.
Corning makes the Code of Conduct available to all employees electronically, in 13 different languages. We also provide posters in local language explaining how to report Code of Conduct violations and reinforcing our commitment against retaliation. Through a contract with a third-party, we provide a service allowing employees and persons outside of Corning the ability to report concerns anonymously, in local language, either by phone or internet, all day and every day, around the world. In order to ensure the effectiveness of our reporting mechanism, we regularly review and analyze data showing our reports by location and function. We also work with the third-party service provider to update and upgrade our reporting mechanism as required to ensure it is available to our employees and other stakeholders around the world.
As explained in Corning’s Whistleblower Policy, which applies equally to employees and those outside of Corning who report alleged misconduct, the leaders of Corning’s Compliance Program review all reports received and determine the level of action and investigation required. Corning’s internal processes are followed to ensure consistent investigation, reporting, and remedial actions are taken in each case. The results of all Code of Conduct investigations are periodically reported to the Audit Committee of the Board of Directors. Corning does not retaliate, and has not retaliated, against employees or others who have brought forward concerns in good faith.
For more information regarding the cases reported and investigated by Corning during the previous calendar year, see the linked document.