GE believes that employees and others with connections to the company must have confidence that they can freely report concerns about legal or ethical violations, and that their concerns will be objectively investigated by subject matter experts in Finance, Legal and Human Resources (and outside specialists, if necessary), with appropriate individual and remedial action and without fear or favor.
Employees are subject to discipline if they fail to report a known or suspected concern. In addition, GE prohibits retaliation against those who raise integrity concerns and imposes discipline on anyone who is found to have engaged in retaliation.
GE has an extensive ombudsperson process that serves as a mechanism for individuals to ask questions and report integrity concerns without fear of retaliation. Employees may raise their concerns anonymously if they choose, and investigations are conducted with the highest level of confidentiality when concerns about possible violations of GE policy or the law are raised. GE has processes in place for objectively investigating and resolving integrity concerns, and ombudsperson system activity is regularly reported to the Audit Committee of the Board of Directors.
With an extensive global ombuds network of approximately 700 ombudspersons, coverage is provided for every business and country in which GE operates. As GE employment and business activity has changed, increased rigor around the ombudsperson appointment process has been added. The ombudsperson network is continually assessed and measured to ensure it is operating with peak efficiency while providing the most comprehensive global coverage.
It is critical that all GE employees worldwide understand how to raise their integrity questions and concerns and trust the system. Employees come to know their local business ombudsperson through postings, articles and various company intranet sites, and by ombudsperson introductions at all-employee meetings within the businesses, including integrity events and training.
All ombudspersons speak the local language and understand the culture and business environment of their locations. GE ombudspersons are trained in procedures for receiving concerns, initiating investigations, monitoring case progress and closure. Training for ombudspersons is digitized to allow for self-directed course instruction. In 2009, a total of 184 ombudspersons were trained. Existing ombudspersons may also access the digitized training when a refresher is needed.
Prompt corrective action and discipline demonstrate a strong integrity culture at GE. During 2009, 1,641 integrity concerns were reported through the ombudsperson process (38 percent anonymously) covering a variety of issues. Robust usage of the ombudsperson process demonstrates that GE leaders have set the right integrity culture, creating an environment that encourages employees to come forward with their questions and concerns without fear of retribution.
The results of the 1,641 investigations in 2009 led directly to 420 disciplinary actions being taken, including 118 employee separations, 271 warnings, 9 job changes, and 22 financially impacted employees. Of the disciplinary actions, approximately 46 percent occurred outside the United States. Ombudspersons monitor investigations to ensure timely closure and prompt feedback to those who raise concerns. As of May 12, 2010, 98 percent of 2009 investigations have been closed, averaging approximately 51 days to complete.
Confirmed violations of company policies and procedures result in corrective actions such as training, strengthening routines and simplifying/updating processes. Although many policy non-conformances result from unintended mistakes, disciplinary actions are taken in appropriate cases involving intentional wrongdoing.