Here’s to our employees: the guardians of good business practices and the embodiment of ethics in the workplace. They protect and practice our commitment to doing business the right way, every day. Our employees deserve the credit for Western Digital’s culture of ethics. They make it happen.
You can’t mandate an ethical culture, and you can’t just announce that you have one. You build it day after day, in the countless good decisions you make and – importantly – in the bad ones you don’t make. You build it in the conversations you have, in the questions you ask, and in the interventions you have the courage to make. You build it when you speak up about the things that don’t seem right, and when you don’t turn away from the things you see that you know are wrong.
And then eventually, after days and weeks and months and years of doing business the right way, you wind up with what we have at Western Digital: a culture where employees know that doing business the right way is what they are expected to do because it’s good for our business.
Excited to be One of the 2020 World’s Most Ethical Companies
I’m proud to announce that Western Digital has again been named one of the World’s Most Ethical Companies® by Ethisphere®, a global leader in defining and advancing the standards of ethical business practices.1 It’s our second year in a row receiving this prestigious recognition.
Accountability, honesty, transparency – all traits we embrace in our company culture – played key roles in our being recognized again this year. Putting these traits into practice allows us to earn the trust of our customers and business partners, to attract and engage our employees, and to deliver value for shareholders and to the communities where our employees live and work.
What does Ethisphere consider when deciding to put a company like ours on its list of the World’s Most Ethical Companies? It looks at the following criteria:
- Ethical business standards and practices
- Programs to help employees make sound, ethical choices
- Deployment of best practices today to help shape industry standards in the future
Our Ethics and Compliance program, our business practices, and our employees’ perceptions of our ethical culture met or exceeded Ethisphere’s WME evaluation criteria. In addition, Ethisphere was particularly impressed by other aspects of our business, a few of which I discuss below.
Making Ethics a Global Language We All Understand
One of the great things about Western Digital is that we are a truly global company with tens of thousands of employees throughout the world who come from different cultures and who speak a variety of languages. We work hard to make sure all employees – regardless of where they work and what job they hold – understand why it’s so important to do business the right way. One of the ways we do this is through our Compliance Awareness Month, or CAM. Ethisphere has noted that Western Digital leads the way in dedicating an entire month to focusing on the importance of ethics and educating our employees on how to make ethical decisions as they carry out their responsibilities.
In some ways, CAM is a month-long ethics seminar for our employees at Western Digital University. This annual initiative includes online and in-person compliance training, as well as certification of ethics-related disclosures. Our education and training efforts have been wildly successful. 99.8 percent of the nearly 20,000 employees who are asked to undertake training modules complete their training before the end of CAM. The remaining 0.2 percent complete their training within 2 weeks of the end of CAM.
But CAM is a lot more than online training about laws, policies and potential problems. CAM pulses with energy as employees at every one of our sites create energetic and fun events featuring dancing, singing, contests, and raffles — all designed to celebrate a culture where employees are encouraged to do the right thing. Throughout the month, we reinforce this message with ethics-related blog posts, presentations during all employee town halls, email reminders from senior leaders, and digital and physical signage. Our goal is to make sure everyone understands with certainty that Western Digital succeeds when employees commit to doing business the right way.
Doing Right Every Day with Every Decision
Holding a Compliance Awareness Month doesn’t mean we forget about ethics and compliance for the other eleven months of the year. We’re focused like a laser beam on making sure ethics informs our key business processes. For instance, we’ve thought through and assembled a sustainable and values-driven supply chain and go to market strategy, from sourcing to manufacturing to distribution to sale. In fact, we were recognized as 4th in the “Computer Hardware” industry, according to Responsible Sourcing Network’s 2019 Mining the Disclosures Report1. Our innovative use of data science, modeling, and smart logistics has resulted in reduced energy consumption and a smaller carbon footprint.
We work hard to prevent corruption from entering into the worldwide network of relationships we rely on to help us assemble and sell our products. We stay close to our suppliers and customers and make sure they understand the standards to which we are accountable and to which they, in turn, are accountable as well. Ours is a complex business. We ship thousands of SKUs to thousands of customers in more than a hundred countries and territories. Doing business the right way amid this complexity is challenging, but it’s a challenge that our leadership team and our employees throughout the world have come to embrace because they know that maintaining our commitment to doing the right thing will make us a stronger, more successful company.
Staying Ethical with New Programs and Policies
As proud as we are of being recognized for the second year in a row as one of the World’s Most Ethical companies, we continue to focus on improving because every company can get better. Sustaining an ethical culture is an ongoing process because cultures are organic. They have to be nurtured and reinforced, or they can morph and deteriorate. We have an ambitious ethics and compliance agenda for FY2020. Among the things we will be working on are the following:
Speak-up Culture – We’re working with employee groups at each of our sites around the world to enhance our speak-up culture. We want to make sure that every employee – regardless of his or her culture, language or position – feels empowered to speak up and let someone know when he or she sees something that is not in the best interests of Western Digital.
Just-In-Time Training – We’re building on the success of our company-wide education programs by creating special purpose training modules and materials that can be deployed instantly when teams see a need for training on an issue. If customers are asking us for different pricing in one region or new terms of sale in another region, we can quickly deploy training to our sales teams to help them understand what the antitrust rules allow. If the US government takes actions restricting the sale of products to a specific entity or region, we can quickly deploy training to our trade and logistics teams who need to update their processes to comply.
Data Analytics – We’re using data more frequently and in new ways to enhance our compliance programs. This includes experimenting with using data analytics to monitor transactions and detect excursions that might signal fraud or other inappropriate behavior. Also, we’re using data to conduct root cause analysis of misconduct validated by our investigations group.
Our ethics and compliance team, led by Chief Compliance Officer Tiffany Scurry, sets ever more ambitious goals each year as they search for new ways to train, educate and sensitize our colleagues to the criticality of ethics in the workplace. The challenges facing a large, global company increase in number and complexity each year, so the effort and commitment of our employees has to scale to meet those challenges. I have enormous faith in our employees, and the team we’ve assembled today is the most committed to doing business the right way than any other I’ve worked with in my 20 years with Western Digital. I’m looking forward to what we will accomplish together in 2020 and beyond.
- Read our press release with Ethisphere
- Explore our Corporate Responsibility & Sustainability Report
- Learn more about our diversity and inclusion initiatives
- Find out about our corporate philanthropy programs
- Mining the Disclosures 2019 – Responsible Sourcing Network. https://www.sourcingnetwork.org/mining-the-disclosures-2019
 “World’s Most Ethical Companies” and “Ethisphere” names and marks are registered trademarks of Ethisphere LLC.
Michael Ray is Executive Vice President & Chief Legal Officer of Western Digital, responsible for the company’s worldwide legal functions.