1. Policy Governance

2. Policy Governance Model
Governed by committees aligned with the Corporate Compliance Program
Policy Board Committee (“PBC”)
Members: Chief Financial Officer, General Counsel, Chief Human Resources Officer, Chief Audit Executive, Chief Compliance Officer (“CCO”)
Chair: CCO
Provides overall governance
Ratifies all requests for new policies, amendments & retirements
Enacts changes in policy framework
Ensures ongoing program effectiveness
Policy Management Committee (“PMC”)
Members: Executives from key functional areas
Reviews all requests for new policies, amendments and retirements prior to PBC review
Manages communications within their functional area related to policy governance/approval
Business Units
May implement their own Business Unit-level standard management committees
Policy Board Committee
Policy Management Committee
SVP, Human Resources
Chief Accounting Officer
SVP, Litigation, Employment Law and Government Relations
SVP, Internal Audit
SVP, Strategic Development and Sourcing
Chief Information Officer
Business Unit Compliance Officers
Chief Compliance Officer

3. Policy Governance Triangle

4. Policy Structure Policy Standard Process
High-level business rules that act as the “law” of a Company.
All policies will be at the Corporate-level (e.g., Global Anti-Corruption and Anti-Fraud Policy)
Standard
Provides more detailed requirements as to how a Policy must be implemented.
Standards can be global (e.g.., Anti-Corruption and Anti-Fraud - Gifts, Travel, Contributions & Entertainment Standard), Business Unit-specific (e.g. XX Business Unit – Dress Code Standard), or Region-specific (e.g., U.K. Travel & Entertainment Standard).
Standards may be more restrictive than the Code of Conduct/Business Principles or a Policy but they cannot be less restrictive.
Process
Defines the who, what, where, when and why to ensure that there is a procedure in place to comply with a given Policy or Standard.
Business owners maintain responsibility over development of processes.