The Ethisphere Institute 2015 Ethics Quotient Survey Guidance on Recommended Support Documentation Ethisphere reviews supporting documentation to ensure that candidates receive proper credit for good performance and so that Ethisphere can validate the self-reported EQ score. Ethisphere may discount self-reported EQ scores if it is unable to validate certain aspects of a candidate s self-reported performance. This document provides guidance regarding what type of supplemental information to provide in support of your company s World s Most Ethical Companies (WME) application and how to submit such documentation. How Documents Should Be Submitted Documents can be submitted via email to wmeapplications@ethisphere.com. Alternatively, hard copy materials or physical media storage (such as thumb drives) can be sent by mail to: Ethisphere Institute Attn: World s Most Ethical Companies Application 6263 N. Scottsdale Road, Suite 205 Scottsdale, AZ 85250 Alternatively, Ethisphere can provide a secure FTP site for uploading large digital files. To request FTP access, please send your contact information to wmeapplications@ethisphere.com. Ethisphere strongly recommends companies organize the supplemental documentation. Examples of effective organization include providing an index of documents submitted and either separating the documents by the categories and subcategories of the survey or by the questions they support. For example, an electronic submission would contain separate folders for documents supporting each category, and a paper submission would have tabs or some other separation by category and subcategory. In addition to providing supplemental documentation, Ethisphere recommends companies provide a short executive summary for each category. This summary should include a description of what documents are being submitted, as well as any other information you think would be helpful to Ethisphere in understanding your company or its programs. Using the example above, the governance documents would be contained in their own electronic folder with a short narrative introducing them and any information your company wishes to highlight or explain regarding its governance structure. 1
What Documents to Submit Each company is unique and there is no set list of documentation that should be submitted. The purpose of the list below is to offer guidance, not to be an exclusive or required list of documents to be submitted. Please submit those documents that you think best enhance the credibility of your company s submission. Ethisphere recommends companies submit documentation that (i) supports the responses given in the questionnaire, (ii) showcases what the company would like to highlight about its compliance program, governance structure, CSR program, efforts in exemplifying ethical leadership, examples of an outstanding reputation, and an ethical culture, and (iii) provides context or clarification for questions where your company believes the answer options did not accurately reflect your unique situation. Please ensure that all documentation provided is written in English. Documents may be redacted where necessary. Corporate Governance Performance evaluations of the Board, its committees and/or the individual directors this could include evaluation templates, evaluation results, survey templates, or documentation showing the scheduling and process for conducting evaluations Any formal succession plan for the chief executive officer (or equivalent title) Performance reviews of the chief executive officer (or equivalent title) conducted by the Board or governing authority this could include templates of reviews, review results, or documentation showing the scheduling and process for conducting reviews Documents demonstrating or evidencing training to the Board or governing authority this could include documentation concerning code training or any other specific training the Board or other governing authority receives Documents demonstrating or evidencing continuing education provided to the board or other governing authority Compliance and Ethics Program Documents demonstrating or evidencing the structure of the compliance function within the company this could include a high level organization chart showing reporting lines/organizational structure and job descriptions 2
Documents demonstrating or evidencing the compliance function reporting to the Board or other governing authority this could include a template report, a report, or Board meeting minutes Internal compliance committee charter or similar documentation Company code of business conduct ( Code ) Written requirement documenting the frequency with which the Code is formally reviewed and/or updated Stand-alone policies (separate from the Code) on issues regarding compliance and ethics, such as anticorruption, antitrust, social media, privacy, etc. Third party (e.g., supplier, agent, intermediary, reseller, etc.) Code of Conduct Documents demonstrating or evidencing compliance and ethics training this could include your company s compliance and ethics training curriculum or plan, examples of training on compliance and ethics topics, evidence of tracking completion of Code training (i.e. what percentage of employees have completed), and documents showing the evaluation of the effectiveness of any training (including those showing that your company is attempting to do such an evaluation) Examples of training or communications targeted at managers and supervisors on their special responsibilities with regards to compliance and ethics Documents demonstrating or evidencing compliance and ethics communication this could include the documented compliance and ethics communication plan, and examples of communications from senior executives and others Documents demonstrating or evidencing a formal evaluation or benchmarking of the overall compliance and ethics program this could include a template of the evaluation, the evaluation itself, and documentation showing the schedule and process for conducting such an evaluation Procurement policy that addresses compliance and ethics aspects of third party selection Documents demonstrating or evidencing efforts taken to measure the company s culture this could include surveys or assessments used, results from surveys, questions used for focus groups, or results from focus groups Documents demonstrating or evidencing compliance and ethics program reports this could include any dashboards or analysis of the effectiveness of your company s compliance program 3
Documents demonstrating or evidencing steps taken to protect employees who report suspected misconduct this could include policies, communications, training, and procedures Documents demonstrating or evidencing mechanisms utilized to incentivize employees who engage in ethical conduct, or who actively support compliance initiatives this could include template reviews/evaluations, policies and procedures, and examples of rewards or recognitions Exit interview questions designed to assess whether the departing employee was aware or concerned about potentially unethical events that were taking place at your company Citizenship, Sustainability, and Responsibility Your company s most recent Corporate Citizenship/Responsibility/ Sustainability Report(s) Documents that illustrate how your company incorporates sustainability & social responsibility into core business and operational activities Reports or scorecards benchmarking your company s CSR Report against a standard framework such as the Global Reporting Initiative Documents demonstrating or evidencing innovative or unique workforcerelated programs/initiatives and environmental programs/initiatives Documents demonstrating or evidencing a formal community involvement strategy Documents demonstrating the extent to which employees support local communities Reports illustrating the nature and impact of key philanthropic programs and initiatives Reports showing the priorities, scope, and outcomes of your organization s charitable foundation, if applicable Leadership, Innovation, & Reputation Metrics, dashboards, and/or reports that demonstrate the company is managing its reputation across a variety of medias and methods 4
Reports, articles, awards, or other materials that support a positive perception from your company s stakeholder groups, including customers, employees, media outlets, neighboring communities, suppliers, vendors, government or regulators, and other external organizations Certificates, awards, or other accolades that support a culture of stakeholder engagement, reputational excellence, or leadership in the area of ethical practices National news publications, customer/supplier satisfaction reports, employee wellness data, or any other documentation demonstrating a positive reputation among your company s stakeholders Any additional documentation that identifies your company as a leader and/or innovator in the areas of compliance, social responsibility, sustainability, and/or ethical business practices. 5