Ethics and compliance

Our Ethics and Compliance Office, led by our Chief Compliance Officer, sets the direction of our ethics and compliance program, and helps reinforce a culture of integrity through a layered strategy of policies, procedures, tools, education and communication.

Anti-Bribery/Anti-Corruption Compliance Policy

We reinforce our commitment to integrity through our Anti-Bribery/Anti-Corruption Compliance Policy (ABAC Policy). The ABAC Policy applies to all employees and officers of United and its subsidiaries — as well as third-party representatives — and provides specific guidance for individuals who interact with government officials. We understand that even the appearance of impropriety can jeopardize the Company’s interests and is inconsistent with our business principles. Accordingly, nearly all transactions with government officials require approval from the Ethics and Compliance Office.

Human rights

We incorporate practices into our processes to help ensure that modern slavery, human trafficking and child labor do not exist in our global business operations and supply chains. These include:

• Conducting risk and due diligence compliance reviews of our suppliers and other third parties to help ensure that they are complying with applicable laws (including with respect to ethical labor practices, safe working conditions and responsible sourcing standards)
• Growing and cultivating relationships across our supply chain
• Regularly training our employees with content specific to recognizing possible signs of slavery and human trafficking and mitigating risks
• Encouraging the reporting of concerns

We also reinforce our commitment to protecting and advancing human rights in our policies. Our commitment — detailed in the Human Rights Policy Statement included in the Code — is guided by the principles reflected in the International Bill of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and the United Nations Guiding Principles on Business and Human Rights.

As stated in the Human Rights Policy Statement, we strive to have transparent operations and supply chains that are free from "modern slavery" risks; support the elimination of all forms of forced, bonded or compulsory labor; condemn all forms of exploitation of children; support the elimination of exploitative child labor; and support laws duly enacted to prevent and punish the crime of sexual exploitation of children. As further discussed in our Working Together Guidelines, we are an equal opportunity employer committed to providing our employees with a nondiscriminatory work environment that promotes open and honest communication and embraces dignity, respect and fairness in all aspects of our business operations.

We regularly highlight the multiple avenues for employees to raise concerns or seek guidance — from managers to Human Resources to the Ethics and Compliance Office, including the Ethics and Compliance Helpline and the Web Reporting tool. These channels are confidential, accessible 24/7 and provide multi-language support, with the option to report anonymously where permitted by law.

Protection for individuals who speak up

The Code makes clear that United prohibits retaliation against anyone who, in good faith, files a report about suspected illegal or unethical behavior or participates in an investigation.

Taking action

The Ethics and Compliance Office reviews all reports, and dedicated investigators are tasked with ensuring appropriate investigations of improper conduct. We have also established corrective action procedures for review by a multi-disciplinary team of leaders of substantiated improper conduct.