The Reed Elsevier Code of Ethics and Business Conduct (Code), disseminated to every employee, is a guide to our corporate and individual behaviour. Encompassing topics like human rights, anti-bribery, acceptance of gifts and entertainment, company political involvement, safety, and fair competition, it encourages open and principled behaviour.
Our Code states that RE strictly prohibits employees from using corporate funds for any political contributions except in the United States, where such contributions and activities are permitted in certain states within allowable limits if they comply with stringent reporting and disclosure regulations. In the United States, we require employees to obtain prior approval from the US General Counsel and the Vice President of Government Affairs of Reed Elsevier Inc. for any proposed corporate political contributions; all corporate contributions are reported as required by law. In 2008, these totalled £39,000.
To aid employee understanding of the Code, we offer an online training programme developed in collaboration with the RE divisions. The course explains substantive policies, emphasises the importance of compliance, and highlights resources available to employees with questions or concerns. It begins with an introduction from the CEO and contains practical illustrations of provisions in practice.
70% of current employees received online training on the Code by the close of 2008. The RE CR Forum has annual responsibility for reviewing the Code to ensure it follows current best practice and legislation. The Code, last updated in 2006, will be updated in 2009 to improve readability, and a refresher Code course will be rolled out to approximately 12,000 US employees. We aim to expand Code training to employees in the Netherlands, France, Japan and China.
We maintain Code Compliance Committees for Reed Elsevier and each major division. We also offer a tool for filing anonymous complaints via a web-based or toll-free, confidential reporting line. The Code stipulates protection against retaliation if a suspected violation of the Code or law is reported. Substantiated Code breaches are subject to swift disciplinary action, up to and including termination. In 2008, fewer than ten employee dismissals were related to Code violations.
In addition to the RE Code of Ethics and Business Conduct for all directors, officers and staff, there is an additional Code of Ethics for Senior Officers that applies to among others, RE’s CEO,
“It was very educational. We could be and are faced with these situations every day and it is nice to have a strong understanding of our boundaries.”
“It was very easy to complete...substantive [and] comprehensive in content. I learned a lot in a short period of time.”
“This is a tricky area and while mostly obvious, the questions did highlight how sometimes the right answers can be deceptive.”
Comments from employees on our Competing Fairly course
We offer employees advanced ethics training. For example, because LexisNexis’ risk information services involve access to consumer data, we offer the course, Protecting Personally Identifiable Information, completed by over 8,000 LexisNexis employees in 2008. Read more about how LexisNexis protects privacy and security. In addition, the training course Competing Fairly, An Introduction to the Antitrust and Competition Laws, reached 3,500 executives, senior managers, sales managers and others in the US and UK last year. In 2009, we will expand distribution of that course, roll out a new workplace harassment course for all US managers, as well as an updated data privacy course.