How the CEO Sees It

Compliance and Ethics

In this regular feature, CEO Steve Loranger takes a closer look at ITT's corporate priorities. Here, he outlines the company's commitment to compliance and ethical behavior.

 

ITT is currently dealing with the fallout from a very serious non-compliance issue. The actual violation occurred several years ago when our Night Vision business failed to secure proper export licenses for technology and component specifications being shared with an overseas supplier. We are paying the price for those actions now -- not only in the payment of significant fines, but in the questions being asked about our culture and our ethics.

I'm sure many of you have the same response when you hear and read stories about this case: That's not the ITT I know.

And there's some truth to that. Over the years, your actions and decisions have helped ITT earn respect as a company with a strong value system and a commitment to ethical behavior. We aren't a company where employees are afraid to pick up the paper each morning because of what they might read about their business, or dread the drive into work because they know they will be asked to check their conscience at the door. 

But at the same time, the Night Vision incident didn't happen at another company. It happened here at ITT and serves as a reminder that we are not immune from mistakes and misjudgments.   

We can never relax in our ongoing effort to live up to our value system and code of conduct. I'm asking all of you -- every ITT employee -- to accept responsibility for doing the right thing always. That phrase has been part of our company culture for many years, but I urge everyone to hear it again for the first time and embrace it anew. Use it as a guide in everything you do and never set it aside because you think it's of secondary importance to profits, deadlines, winning new business or making our plants more productive.

Doing the right thing is always our first priority.  Always.

To keep us on the right path, we have strengthened our compliance program. I expect everyone to commit themselves fully to taking part, using our new and existing resources and following proper procedures for everything we do from filing expense reports to the processes and procedures associated with exporting our products overseas. 

Here is what you can do to ensure we operate with integrity every day:

  • Embrace Training. An enhanced ethics and compliance training program is being rolled out to all employees worldwide and covers a more comprehensive list of topics -- from government contracting to sexual harassment to the Foreign Corrupt Practices Act. During the session, take the time to understand all the rules and regulations that govern our company and think about how they apply to your business or job. 
  • Know Your Compliance Team. In the past year, we have created a dedicated compliance team, led by Craig Johnson, chief compliance officer. He is supported by Cornett Lewers, director of compliance programs; Sue Ringler, senior counsel for international compliance; Dave Tarbell, director of international trade and compliance, and the entire compliance staff. In addition, we have begun training compliance experts at your value centers to serve as an additional resource. These team members are focused on developing programs to enhance compliance, and any of them are available to help you with questions in their areas of expertise.
  • Speak Up. It's vital that all employees feel they have a voice in our compliance efforts.  It starts with our leaders. I expect them to create an atmosphere of openness so that employees feel comfortable raising issues.

    For employees, if you are not sure how to handle a particular situation where you think our ethics might be compromised, please ask. Contact your supervisors, HR representatives, the legal department, or my office.

    You can also get in touch with your local ombudsperson. Contact information is located in the Code of Conduct, or on the posters and wallet cards that have been distributed to all our sites. Your communication is confidential -- and can be anonymous if you wish. In those cases where you can't reach an ITT ombudsperson -- or don't feel comfortable talking to someone within ITT -- you can call EthicsPoint, where trained representatives are available 24 hours a day. All calls are confidential. You can reach EthicsPoint at 866.294.8691 or 503.352.7158.

    We are also currently conducting a confidential survey to assess how well our company is walking the talk when it comes to our values. Your honest feedback will help us identify and address high-risk areas for our company.
  • Know the Code. Take the time to read through our Code of Conduct, or consult it if you find yourself in an ethical "gray area." Every site should have hard copies available, and an electronic copy is currently available in 17 languages on our website and employee portal.
  • Follow Export Control Procedures. The recent Night Vision incident has brought the issue of export control to the forefront at ITT. Our compliance training will focus on this hot-button area, and we have implemented a comprehensive computer tracking program to monitor all packages being sent from our facilities. As a Defense company, we all need to be especially vigilant in this area.
ITT is committed to earning the trust of our customers, partners, suppliers, communities, regulators and coworkers each and every day. We should all be proud -- and protective -- of our reputation as an ethical company, and by doing your part to do the right thing, we can show the world that even though we made some serious mistakes, we have learned from them. We should all be committed to ensuring that a similar situation never happens at ITT. Because that's not the ITT we will be. We will be the ITT that earns our customers' loyalty and respect by the quality of our actions and the behavior we demonstrate each and every day... doing the right thing, always.