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 WD is committed to the highest standards of integrity in its business practices. Integrity is one of our core values because we believe it is an important component in our success.
Global Code of Conduct
For years, WD has operated under a Global Code of Conduct which informs all employees of their legal and ethical obligations to the Company, its employees, customers, competitors and suppliers, taking into account varying practices due to cultural differences throughout the world. The standards set forth in the Global Code of Conduct are supported by more detailed Company policies and procedures, which are issued in various geographic regions to supplement or implement those standards. These policies and procedures provide clear, specific directions concerning many of the business practices and behaviors discussed in the Code. A copy of the Global Code of Conduct in the appropriate language is given, or is available online, to all of our employees. In addition, new employees are given a copy of the Code of Conduct on their first day of employment. All employees are informed that they are expected to comply with the provisions of the Code of Conduct and that failure to do so is regarded as misconduct that can result in disciplinary action. Each year, senior members of management and several hundred key designated employees worldwide are required to complete an online questionnaire certifying that they have complied with the provisions of the Global Code of Conduct. This certification process is required by the Audit Committee and is managed by the Corporation’s General Counsel. A copy of the Global Code of Conduct can be accessed by clicking here. Code of Business Ethics
Our Board of Directors of Western Digital Corporation has also adopted a Code of Business Ethics whose goals are to:
A copy of the Code of Business Ethics can be accessed by clicking here. Ethics Hotline
As part of its commitment to maintaining the highest standards of workplace integrity, Western Digital instituted its toll-free Ethics Hotline in November 2002. The Hotline is managed by a third party provider, and is staffed 24 hours a day, 365 days a year. While primarily intended for current Western Digital employees, the hotline may be used by other interested parties, including vendors, customers and former employees. Employees are encouraged to report suspected instances of ethical misconduct within Western Digital, including:
Foreign Corrupt Practices Act
Western Digital Corporation believes it is essential that its employees understand and comply with the terms of the Foreign Corrupt Practices Act (FCPA), especially as it increases its presence in countries throughout the world. The FCPA makes unlawful certain conduct by or on behalf of U.S. companies abroad. The FCPA is comprised of two basic elements: (i) anti-bribery provisions which prohibit the payment of bribes to foreign officials to obtain or keep business, and (ii) accounting provisions which require public companies to maintain accurate books and records, and an adequate internal accounting system. Consistent with the terms of the FCPA, Western Digital prohibits any of its or its subsidiaries’ employees, consultants, agents or representatives from corruptly offering, paying or offering to pay money or other things of value to a foreign official (as that term is defined in the FCPA) for the purposes of:
Corporate Governance Guidelines
Our Board of Directors has adopted a set of corporate governance guidelines which represent the Board's current thinking with respect to selected corporate governance issues considered to be of significance to stockholders. These guidelines, along with the charters of the committees of the Board, provide the framework for the governance of the Company. The guidelines are only guidelines and not rigid rules. The Board’s Governance Committee will continue to assess the appropriateness and efficacy of the guidelines and recommend from time to time changes for approval by the Board as it deems appropriate in the best interests of the Company or as required by applicable laws and regulations A copy of the Company’s current corporate governance guidelines can be accessed by clicking here. A copy of the Company’s Compensation Committee Charter, Audit Committee Charter, Governance Committee Charter, and Executive Committee Charter, along with information on the composition of each committee, can be accessed by visiting the “Governance” section by clicking here. |
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