Our Corporate Governance Commitment

We are committed to managing the company for the benefit of our stockholders and are focused on maintaining good corporate governance. Some of the ways in which we do that are through:

  • Board Diversity: The Nominating/Corporate Governance Committee of our Board of Directors is responsible for the effective composition and operation of our Board, including structure, membership, and refreshment, which is not only gender balanced, but diverse in terms of underrepresented communities, backgrounds, and expertise.
  • ESG Oversight: Our Board is briefed on ESG performance and plays an active role in assessing risks and identifying opportunities for building a more resilient portfolio.
  • Risk Identification and Management: An Enterprise Risk Management evaluation is conducted annually to identify and assess company risk, including climate-related risks.
  • Incentivizing Performance: Our Board Compensation and Talent Committee works with independent consultants to conduct annual compensation reviews for our key executives, such as current efforts to align to ESG performance.
  • Regulatory Compliance: Our Board’s Audit Committee oversees the integrity of our financial statements and compliance with legal and regulatory requirements.

Governing Sustainability

We believe that our commitment to corporate responsibility, which encompasses Environmental, Social and Governance (“ESG”) principles, is critical to our performance and long-term success. The Nominating/Corporate Governance Committee of our Board of Directors has direct oversight of ESG matters.

In 2019, we approved resources needed to advance our ESG agenda, including creating a Sustainability Department and creating a new dedicated Associate Vice President of Sustainability position.

Our ESG program is overseen by the Nominating/Corporate Governance Committee along with other standing committees of the Board to the extent issues come within the purview of their responsibilities. The Sustainability Department regularly reports to the Executive Vice President, Chief Legal Officer, General Counsel & Secretary, with oversight from the Nominating/Corporate Governance Committee and the Board of Directors. The Sustainability Department reports to the Board and its committees regarding client engagement activities and the company’s ESG framework and program development.

Business Ethics

We are committed to conducting our business according to the highest ethical standards and upholding our corporate responsibilities as a public company operating for the benefit of our shareholders. Our Code of Business Ethics was formed to codify and formalize certain of our long-standing policies and principles that help ensure our business is conducted in accordance with the highest standards of moral and ethical behavior. It includes our commitment to dealing fairly with all of our clients, service providers, suppliers, and competitors. We conduct annual training with our employees regarding ethical behavior and require all employees to acknowledge the terms of, and abide by, our Code of Business Ethics.

Other facets of ensuring ethical conduct across our value chain, include:

  • Anti-corruption: We operate in compliance with the U.S. Foreign Corrupt Practices Act (FCPA) and, as such, have adopted an Anti-Corruption & Foreign Trade Control Policy as well as an Anti-Money Laundering & Anti-Terrorist Financing Policy. These policies prohibit team members and third parties acting on behalf of our company from corruptly paying, offering, promising, authorizing, taking, soliciting, or accepting for personal benefit, any bribe, kickback, illicit payment, or advantage, in money or in any kind, to or from any foreign official or to or from any other person or entity, including terrorist- related groups.
  • Supply Chain Management: Though our suppliers are independent entities, the business practices and operations of our suppliers impact our business in material ways, and in order to enhance our corporate responsibility efforts, it is duly important that our suppliers acknowledge the guidelines set forth by our Supplier Code of Conduct.
  • Cybersecurity: Our management processes are aligned to the Federal Financial Institutions Examination Council (FFIEC) Cybersecurity Risk Framework and map back to National Institute of Standards and Technology (NIST) controls. The process is aligned to the Federal Financial Institutions Examination Council (FFIEC) Cybersecurity Risk Framework and maps back to National Institute of Standards and Technology (NIST) controls. The process, rooted in our Security Incident Response Policy, includes tabletop reviews, third-party assessments, training, and other compliance mechanisms.