Alcatel-Lucent

Alcatel-Lucent Code of Conduct establishes minimum standards of behavior; it is based not only on the laws and regulations that affect our business, but also on the concepts of integrity, respect, fairness, diversity and ethics.
The Code of Conduct provisions dedicated to corporate social responsibility detail our pledge to respect the rights of all of our stakeholders, enhance and serve the communities where we do business, promote environmental responsibility and minimize the health and safety impact of our activities and products.

In those countries where permitted by local regulations and legislation, employees can use a 24/7 hotline to report compliance issues, concerns, violations or suspected violations of law or company policy. Deployed in more than 88 countries worldwide by year-end, the hotline provides a mechanism for our people to report, in good faith, suspected unethical business conduct or any dishonest, destructive or illegal actions. Operated by a third-party vendor, the hotline supports virtually any language. Our Office of Business Conduct has also created a mailbox where employees can obtain compliance information or ask questions. The OBC Mailbox is monitored constantly to ensure that employees receive responses within one working day. The OBC Mailbox is monitored constantly to ensure that employees receive responses within one working day.
As part of the effort to regularly sensitize our people to ethical and compliance issues, the OBC manages a regularly updated internal communications program, which includes easy access to robust compliance resources across key compliance program areas. In 2009 it will include such features as “Frequently Asked Questions” on important topics, “What Should I Do?” scenarios, senior leader talking points and scripts, and senior leader e-mail templates.

policy toward bribery, as well as developing an effective internal program to prevent it from happening within their own companies. Alcatel-Lucent is the first partner from the telecommunications industry.

commitment to business ethics and integrity. Working with senior management, members of the OBC team seek to engage all Alcatel-Lucent employees in their personal commitment to compliance and integrity, to promote integration of these values into everyday business operations and to achieve employee awareness and engagement in the process. To achieve its goal, the OBC develops and implements various legal compliance and business conduct programs that are integrated into business operations. To ensure that the company benefits from a comprehensive set of policies, the OBC published eight global compliance policies in 2008. Designed to complement the Code of Conduct, the policies cover such areas as antitrust, competitive intelligence, export compliance, information security, and anti-fraud issues.
In 2008, the OBC undertook steps to strengthen our compliance management infrastructure. Specifically, the OBC reviewed and revised membership in our Ethics & Compliance Council and Operating Unit Compliance Council to ensure that both reflect evolving business requirements.

The courses cover a wide range of topics, from general ethics and awareness courses to instruction focusing on specific policies and laws. Some courses are mandatory for all employees; others are required only for specific job functions.

makes it clear that we expect the same high standards of social responsibility from our suppliers and subcontractors. The policy states our commitment to protect and enhance the human dignity of everyone who works for the company and anyone who has dealings with it. Furthermore, it spells out our support and respect for the principles of human rights as defined in the U.N. Universal Declaration of Human Rights, the International Labor Organization’s fundamental conventions and the U.N. Global Compact.

11,000

visits on the dedicated Office of Business Conduct internal website.

28,215

employees participated in 18 web-based courses in 2008.

Headed by a Chief Compliance Officer, the Office of Business Conduct helps our people understand their personal responsibilities as well as the company’s obligation to legal compliance and commitment to business ethics and integrity.