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ABB treats all reported integrity concerns seriously and with diligence. All reasonable steps are taken to promptly and appropriately investigate concerns. If a concern is found to be substantiated, appropriate action is taken to resolve and remediate it.
ABB is committed to a sustainable culture of ethics and compliance. It is focused on preventing, detecting and remediating integrity concerns.
Our anti-fraud program, aimed at preventing and detecting integrity concerns, is monitored by Internal Audit, who regularly evaluate fraud risk exposure and developing trends in our business. Anti-bribery reviews of business units and countries globally are conducted frequently throughout the year. Each review includes examination of business processes, accounts and balances, and tests transactions to assess robustness of controls and identify potential violations. This is a cross functional analysis of 21 program elements and the response plan to prevent and detect potential fraud.
We conduct periodic reviews, testing and monitoring of the implementation of the ABB Code of Conduct and its supporting standards, policies and procedures. We do this to evaluate and improve their effectiveness in preventing and detecting violations of the Code, the local laws of the countries in which we operate, and ABB's global mandate to conduct business with integrity and transparency. We benchmark these practices against international industry standards, to maintain perspective on where our program is tracking on a global scale.
We enforce a zero tolerance policy for violations of the law or the ABB Code of Conduct, and will take disciplinary or other action against employees and those working for or on behalf of ABB, who have been found to violate law or policy. Steps may also be taken to remediate organizational or other shortcomings, wherever deemed appropriate to prevent recurrence and following root cause analysis.
All reported integrity concerns are initially submitted to ABB’s dedicated global investigations team, the Integrity Investigations & Monitoring team (IIM), which reports to Group Legal & Integrity at ABB headquarters in Zurich. If required by local law in EU countries, reporters can also ask for their report to be submitted to a local representative of their chosen ABB partner company for handling, instead of to IIM.
Depending on the severity and type of allegation raised, the investigation of the concern will be conducted by either IIM, an appropriate function, such as Human Resources, or it will be assigned to the appropriate business area for further handling.
If a concern is found to be substantiated following an investigation, root cause analysis is conducted to determine the contributing causes of the misconduct. In accordance with applicable law and policy, appropriate disciplinary or other action is taken against employees and those working for or on behalf of ABB, if they have been found to violate law or policy. Steps may also be taken to remediate organizational or other shortcomings, wherever deemed appropriate and as required to prevent recurrence.
As part of this process, ABB may review its internal controls or other processes to mitigate any risks and vulnerabilities which are identified during the course of the investigation.
ABB engages IIM in coordination with other internal functions, such as Internal Audit, Internal Controls, Human Resources and Group Legal & Integrity to review and resolve all reported integrity concerns in a fair, impartial, prompt and diligent manner. From time to time, and wherever appropriate, it may also use external resources to support on any aspects of an investigation at ABB.
ABB operates a formal process for dealing with the individual and institutional consequences of integrity and compliance breaches. If an integrity concern has been found to be substantiated, Disciplinary Committees comprising of internal stakeholders from a cross-section of ABB functions are convened to make decisions on accountability and remediation as appropriate based on investigative findings and consistent with applicable law and policy.
Remediation is an important part of the ABB Global Integrity Program and a key aspect of preventing future misconduct. ABB seeks to detect risk at an early stage, so that we can proactively address risks and vulnerabilities in our business rather than only reacting to them.
When we conduct remediation, we often taken cross-functional measures that may be necessary to help prevent the recurrence of an issue identified during investigation, and share root causes and lessons learned with the organization as a whole. We do this in order to learn from our mistakes, to transparently build awareness around risks, and to inform future planning of risk mitigation measures.