Summary
Air Products & Chemicals, Inc. (APD) filed an 8-K on May 22, 2012, to report an update to its Code of Conduct, approved by the Board of Directors on May 17, 2012. This revised code is designed to be more globally focused, updating and strengthening various aspects of employee conduct, ethical responsibilities, and compliance measures. Key changes include a greater emphasis on employee rights and reporting obligations with a non-retaliation policy, enhanced focus on sustainability and safety, and updated guidance on information management, intellectual property, and cybersecurity. Furthermore, the revised Code of Conduct significantly strengthens its global anti-bribery provisions to align with international legislation, including the UK Bribery Act 2010. The update also reflects the company's strategic divestiture of its homecare business by removing specific sections related to healthcare law compliance in that segment. The new code will be effective upon translation and distribution to employees worldwide.
Key Highlights
- 1Board of Directors approved a revised Code of Conduct effective upon global translation and distribution.
- 2Code of Conduct updated to reflect a more global perspective, moving away from a U.S.-centric view.
- 3Strengthened language regarding employee reporting obligations and robust non-retaliation policy for good-faith reporting.
- 4Enhanced focus on Sustainability within the Environmental, Health, and Safety (EHS) section.
- 5Updated guidance on information management, intellectual property protection, cybersecurity, cloud computing, and social media use.
- 6Strengthened global anti-bribery section to align with the UK Bribery Act 2010 and other international legislation.
- 7Removed specific healthcare law compliance section due to divestiture of the homecare business.