Compliance and Ethics at Unisys
Integrity in all we do
Integrity is at the heart of Unisys. It informs everything we do: every decision, every action, and every relationship. Our commitment to integrity is absolute and drives the objectives of our compliance and ethics program. Our high ethical standards define the way Unisys conducts business with our clients and each other, and we have the same expectations for our suppliers and business partners. Maintaining trust with our clients, business partners, society, governments, our investors, and each other is integrated into the Unisys culture.
Unisys Compliance and Ethics Program Overview
Our Compliance and Ethics program, which has been in place since 1987, is designed to assess and anticipate risk, and then address and mitigate those risks. We promote a speak-up culture of ethics and integrity through our Code of Ethics and Business Conduct, policies, and training. We assess risk using data analytics, an annual risk assessment, investigations, and other compliance initiatives to minimize potential risks.
Unisys anticipates compliance risks using our annual risk assessment and testing by our Internal Audit team. We also look for areas of concern using our Integrity Awareness survey and monitor misconduct trends reported to the Unisys Compliance Helpline.
Our commitment to building and maintaining a culture of trust and integrity depends on our associates speaking up and reporting if they are aware of, or have a concern about, a violation of our Code of Conduct or the law. Associates raise concerns via numerous reporting channels, including the Unisys Compliance Helpline, which operates 24/7/365 and is capable of handling reports in more than 100 languages. Investigations and grievance processes may vary depending on national laws, but we maintain a global commitment to conduct fair and impartial investigations and to encourage speaking up without fear of retaliation.
All Unisys associates are required to complete quarterly compliance training so that they understand the importance Unisys places on doing business ethically and the resources that are available to them to make good decisions. Our training and communications campaigns focus on key risk areas, and we achieve a 95% or higher completion rate for each training campaign. As part of quarterly training, all associates complete Code of Ethics training and certify compliance.
The Compliance and Ethics program continually evolves to address the root cause of problems and minimize reoccurrence, further develop our controls and processes, and remain current with legal trends. The Unisys program undergoes numerous audits on an annual basis, including Internal Audit Sarbanes-Oxley testing of our Helpline, compliance policies, and entity-level controls. We self-audit against established standards set out in the U.S. Department of Justice Guidelines for Corporate Compliance Programs.
The Unisys Code of Ethics and Business Conduct – Pathway to Success
The Unisys Code reflects our values and culture of Integrity. It provides the principles and expectations to guide associate behavior by following our policies and the laws in the countries in which we work and provide services. The Code provides a pathway to additional resources to enable leaders and associates to make good legal and ethical decisions. Associates who violate the Unisys Code face disciplinary action, up to and including termination of employment.
Unisys expects that our partners, suppliers, consultants, and contractors will be guided by our Business Partner Code of Business Conduct.
Speak Up – Reporting concerns and non-retaliation
Unisys maintains a helpline available to all associates, contractors, and other third parties. The helpline may be used to ask a question and obtain guidance on compliance and ethics topics as well as to report suspected misconduct or violations of our Code or related policies.
The Unisys Compliance Helpline operates as a toll-free phone line available 24/7/365 where reports can be made in over 100 languages. Reports can also be made via web entry. Anonymous reporting is supported where permitted by law, and all reports are investigated directly by or under the supervision of the Compliance and Ethics Office.
Unisys has zero toleration for retaliation against those who raise compliance concerns in good faith and reporters (whistleblowers) are also given any legal protections anticipated by applicable law. Any associate who engages in retaliation against someone for raising a compliance concern is likewise subject to disciplinary action up to and including termination of employment.
Administration and oversight
Oversight for the Compliance and Ethics program rests with the Audit & Finance Committee of the Unisys Board of Directors, in line with its charter. The company Chief Compliance and Privacy Officer reports quarterly to both the Audit & Finance Committee and the Security & Risk Committee and ad hoc to the full Board as needed. The Chief Compliance and Privacy Officer also interacts regularly with the Unisys Senior Leadership Team.