NCR’s Ethics and Compliance Program is the governance structure responsible for managing our adherence to our Code of Conduct. The key pillars include:
Our Ethics & Compliance Officer oversees investigations of reported violations of NCR’s shared values, Code of Conduct and policies and reports on those activities to NCR’s board of directors.
NCR employees are always encouraged to speak up and report any concerns of wrongdoing through the multiple independent avenues NCR provides to report ethical concerns. Employees can report concerns to their management teams, local human resources or legal departments, or directly to the company-wide Ethics & Compliance Office. Employees can also make anonymous reports via the NCR Alertline, available 24/7 and in over 150 local languages, or send an email to the Ethics & Compliance mailbox.
NCR’s Alertline is operated by an independent third party, Navex Global, Inc. Navex is unaffiliated with NCR. All anonymous reports made to the Alertline are made in strict confidence.
Reported concerns are shared only with those required to help answer questions or investigate matters, ensuring the prompt enforcement of NCR’s reporting standards. If appropriate, the Ethics & Compliance Office will determine disciplinary action. Further, any employee who reports a potential violation in good faith is not the subject of a retaliatory termination or other adverse employment action.
NCR's shared values form the foundation of our business relationships with each other, our customers, partners and suppliers, and are used to direct our behavior and guide our decisions as we drive to achieve our business objectives.
Our Code of Conduct embodies our dedication to upholding these values, as well as our commitment to conducting business against the highest standards of integrity in our relationships with one another and our essential stakeholders.
NCR has a zero-tolerance policy for bribery and corruption and requires all directors, officers, employees and all third-party NCR representatives to adhere to the highest legal and ethical standards of business conduct. With oversight by the Ethics & Compliance Office, all NCR associates and representatives are expected to comply with applicable anti-corruption laws, including the US Foreign Corrupt Practices Act and the UK Bribery Act.
NCR also has clear guidelines articulating the company’s efforts to keep accurate records that fairly reflect the transactions and disposition of assets of the company and its internal monitoring system to detect corruption.
All NCR employees undergo Code of Conduct training during the onboarding process. Then, NCR requires all employees to complete training and certification training on NCR’s Code of Conduct every year. This yearly training reviews, among other topics, NCR’s human rights, anti-corruption and business conduct policies. At the end of the training, each employee must certify that they will comply with the NCR Code of Conduct.
In 2019, NCR introduced additional training to individuals in its organization, such as supply chain managers, sourcing and compliance personnel who may require more in-depth knowledge about recognizing and addressing modern slavery and anti-money laundering laws.
NCR supports employee participation in the political process, for example, voting in elections or making personal contributions to support candidates or parties of their choice. Employees may express their views on government, legislation and other matters of local and national interest. However, these activities must be undertaken on an employee’s own time and at his or her own expense.
No employee will be compensated or reimbursed for personal political contributions or be given or denied employment or promotion due to making, or failing to make, a political contribution.
Political involvement activities that are prohibited or require authorization include: