Ombudsperson Process

Empowering Employees to Be Successful

Ombuds Network

GE’s extensive ombudsperson process serves as a mechanism for individuals to ask questions and report integrity concerns without fear of retaliation. With a global network of approximately 500 ombudspersons, coverage is provided for every business and country in which GE operates. Employees know their local business and regional ombudsperson through frequent communications, articles and various Company intranet sites. Ombudspersons are introduced at all employee meetings within the businesses and regions, including integrity events and trainings.

As GE employment and business activity has globalized, we have updated the ombudsperson appointment process to reflect our increased global activity. For example, all ombudspersons speak the local language and understand the culture and business environment of their locations. The ombudsperson network is assessed and measured to ensure that it is operating with peak efficiency while providing the most comprehensive global coverage. GE ombudspersons are trained in procedures for receiving concerns, initiating investigations and monitoring case progress and closure. Training for ombudspersons is digitized to allow for self-directed course instruction. In 2014, a total of 187 ombudspersons were trained. Digitized refresher courses are available to all trained ombudspersons.

Prompt corrective action and discipline are elements of a strong integrity culture at GE. Confirmed violations of Company policies and procedures result in corrective actions such as training, strengthening routines, and simplifying or updating processes. Although many policy non-conformances result from unintended mistakes, disciplinary actions are taken in appropriate cases involving intentional wrongdoing.


A Strong Culture of Integrity

A hallmark of GE’s compliance program is a steadfast commitment to a vibrant, well-publicized and effective “open reporting environment,” in which employees are encouraged to raise integrity concerns and feel confident that they can do so without fear of retaliation. In today’s environment, GE employees remain the Company’s first and best line of defense for the early detection of potential compliance issues. Early detection and reporting depend on maintaining a compliance culture in which all employees:

  • understand their responsibility to promptly report concerns about potential violations of GE policies, laws or regulations;
  • know and use the channels available to them to report concerns, including managers, compliance officers and GE’s comprehensive network of approximately 500 ombudspersons; and
  • trust that the process is confidential and has no tolerance for retaliation.

In 2011, GE launched an initiative that has become known as “Open Reporting”—communicating to colleagues around the world the channels through which they can raise concerns. In parallel, we created a new “Manager Open Reporting Tool,” whereby any management, HR, Compliance, Legal or Corporate Audit Staff professional is able to submit a compliance concern that has been raised with him or her directly and not through the ombuds channel. Since June 2011, we have trained more than 28,000 GE professionals via the Manager Open Reporting Tool on their responsibility in managing compliance concerns that are raised with them. Since mid-2011, as a result of the training and the creation and implementation of the new manager’s tool, reported concerns regarding The Spirit & The Letter policies have increased by 50% (+8% in 2014 over 2013).

During 2014, 3,325 integrity concerns were reported through the open reporting & ombudsperson process (36% anonymously), covering a variety of issues. The 3,325 integrity concerns led directly to 1,006 disciplinary actions being taken. These included 243 employee separations, 686 warnings, 23 job changes and 54 financial measures taken. Disciplinary actions are up slightly over last year. Of all disciplinary actions, approximately 52% occurred outside the U.S. Ombudspersons monitor investigations to ensure timely closure and prompt feedback to those who have raised concerns. As of February 18, 2015, 97% of 2014 investigations had been closed, averaging approximately 43 days to complete.

We recognize that it takes courage to raise an integrity concern. In 2014, GE Capital gave out more than 4,300 compliance awards. GE Capital’s reward program is one of many examples of GE’s efforts to drive integrity in action and to foster an open reporting culture across the Company by valuing and appreciating the courage of our employees in continuing to keep GE safe and secure.


Integrity and Privacy

How we achieve results in our business is as important as the results themselves. GE seeks to lead in workplace and marketplace integrity by respecting the human rights of everyone touched by our business—employees, suppliers, customers, partners—and by enforcing legal and financial compliance.

GE’s commitment to perform with integrity is instilled in every employee as a nonnegotiable expectation of behavior. This expectation is guided by our Code of Conduct and global integrity policies, The Spirit & The Letter, and is underscored by an extensive system of policies, processes, training and communications.  In 2013, a new version of The Spirit & The Letter was made available to employees, including a simplified Code of Conduct, ethical decision-making guidance and plain-language “Rules to Remember.” We also updated the online integrity training for new employees to make it simpler, shorter, more global and more interactive. We have redesigned these resources with a goal of making our compliance communications and training more modern and effective, thereby helping employees understand why integrity matters and how to “do the right thing” in their jobs. Employees are further enabled by our ombudsperson process, which encourages them to report integrity concerns without fear of reprisal.

GE employees can access The Spirit & The Letter in an interactive eBook format on an employee intranet website, together with additional resources including a database of frequently asked questions, compliance stories, videos and links to online training.

GE is fervent about protecting information about our employees, our customers, our suppliers and our Company in an appropriate manner. Similarly, equipment and technology resources belonging to the Company and provided by GE to its workers, or in some cases, to individuals contracted to do work for GE, to process and store information, must also be used and protected appropriately. As such, GE has implemented detailed Privacy and the Protection of GE Information and Security & Crisis Management policies.

At GE, we take pride in our history of governance and our culture of integrity. No matter where we operate, every GE employee is responsible for knowing and complying with our integrity and privacy guidelines.

Ombudsperson Concerns by Area (reports per policy)

Policy 2007 2008 2009 2010 2011 2012 2013 2014
Fair Employment Practices 425 345 366 414 576 674 812 796
Conflicts of Interest 209 209 235 206 220 260 309 301
International Trade Controls 91 142 147 138 125 170 124 123
Security & Crisis Management (a) 91 114 111 123 208 220 163 149
Regulatory Excellence 58 90 98 127 110 135 140 203
Business Records (T&L, Time & Attendance) 81 133 98 91 124 174 175 226
Environment, Health & Safety 101 97 87 127 164 175 129 175
Routines, Documentation Internal Measurements 106 92 83 89 111 179 224 264
Supplier Relationships 72 86 74 94 121 137 170 222
Improper Payments 49 52 64 35 74 70 96 91
Cyber Security/Privacy (b) 54 69 63 59 80 111 193 201
Controllership (Accounting, Financial Reporting, Billing) 47 57 53 45 71 111 141 112
Intellectual Property 45 27 46 48 80 108 141 147
Theft 38 72 38 42 31 44 36 58
Working with Governments 30 28 38 22 14 30 31 27
Complying with Competition Laws 29 22 22 21 23 29 31 37
Violation of Law -- -- -- -- 7 20 31 34
Other Integrity Concerns 70 37 18 25 64 105 158 159


Ombudsperson Process - Investigation Results

Results 2007 2008 2009 2010 2011 2012 2013 2014
Concerns Reported 1,596 1,672 1,641 1,706 2,203 2,752 3,104 3,325
Disciplinary Actions 343 420 420 363 516 786 960 1,006


Geographic Breakout of Investigations Conducted (percent of investigations)

Region 2007 2008 2009 2010 2011 2012 2013 2014
U.S. and Canada 56% 55% 57% 57% 55% 52% 48% 44%
EMEA 15% 17% 17% 21% 21% 21% 23% 28%
Asia 16% 15% 15% 13% 16% 19% 19% 17%
Latin America 13% 13% 11% 9% 8% 8% 10% 11%


2014 Results

  • Closed as of February 18, 2015: 97%
  • Average Days to Close: ~43



(a) Removed IT risk to new Cyber Security / Privacy policy for 2013 & 2014

(b) Combined new Cyber Security policy with Privacy policy for 2013 & 2014

(c) 2014 data represents the concerns logged to the GE Spirit & Letter open reporting database as of February 18, 2015