Hewlett-Packard Company
Contingent Worker
Code of Conduct
This training can be used by members of Hewlett-Packard Company’s Extended Enterprise to
provide training to their employees on the HP Contingent Worker Code of Conduct
© 2007 Hewlett-Packard Development Company, L.P.
The information contained herein is subject to change without notice
Contingent Worker Code of Conduct
Hewlett-Packard Company is committed
to the highest standards of business
ethics. Members of the HP Extended
Enterprise which provide Contingent
Workers agree to deliver services in a
manner consistent with this commitment.
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HP’s Commitment
•
HP is committed to the highest ethical standards in its
extended enterprise.
•
HP needs our suppliers who act on our behalf and perform
critical processes to act in accordance with ethical
standards expected by HP shareholders and customers.
•
It is for these reasons we have prepared a Code of Conduct
for our suppliers of Contingent Workers. This training will
help contingent workers understand actions expectations of
them while working on behalf of HP.
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Code of Conduct -- Application
•
A supplier of contingent workers shall ensure that any
member of its workforce (including employees, suppliers
and contingent workers) involved in the performance of
services for or on behalf of HP is aware of, trained on,
and adheres to HP’s Contingent Worker Code of
Conduct.
•
Definition: Contingent Worker (“CW”): A non-HP
employee performing services at the direction of his or her
respective employer for or on behalf of HP
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CW Code of Conduct
Local Law
Compliance
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• Comply
with all applicable local law, rules, and government
regulations
HP Confidenital Final Version
CW Code of Conduct
Equal
Opportunity
• Do
Work
Environment
• Harassment
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not discriminate on the basis of race, creed, color,
religion,
• gender, sexual orientation, gender identity/expression
• national origin, disability, age
• any other protected status
will not be tolerated, whether verbal, physical
or visual
• Actions directed at an individual based on their gender,
color, race, ancestry, religion, national origin, age,
disability, sexual orientation or gender identity/expression
are prohibited
• Sexual harassment in any form is not tolerated
HP Confidenital Final Version
CW Code of Conduct
Scenario – Harassment
Scenario
Marie is working for XQ under a contract to HP. Her job
requires that she be present at the HP site in the late
afternoon and evenings. For several nights in the past
week, Dave, a colleague of Marie’s who also works for XQ
has been hanging around Marie’s desk. One evening,
Dave made some comments to Marie about her
appearance. At first she was flattered, but when it
happened the second time, Marie felt uncomfortable and
told Dave she needed to get to work. Marie has tried to
avoid Dave but Dave is hanging around more.
What should Marie do?
A. Marie should not be so sensitive.
B. Marie should talk to her XQ supervisor.
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CW Code of Conduct
Scenario – Harassment
Answer
•
Answer: B
− All forms of sexual harassment are unacceptable in the workplace or
while performing services for HP. This includes unwelcome sexual
advances, requests for sexual favors or the physical or computer
image display of sexually-explicit posters, pictures, cartoons or
drawings and other verbal or physical conduct of a sexual nature.
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CW Code of Conduct
General
Conflicts of
Interest
Agency
Contractor
Conflicts of
Interest
• Do
not provide or receive business amenities, such as
gifts, meals or entertainment, that may create the
appearance of impropriety or undue influence
• During
HP assignment
• Do not work for HP competitor, partner, non-employer
supplier or OEM
• Do not work for an end-user customer in the purchase or
support of any HP products or services
• Disclose
to employer when conducting business with
family, friends, others of close personal relationship
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Conflict of Interest
•
Do not engage in an activity that results in personal interests competing
with those of your employer and /or HP
•Business Gifts and Entertainment
Do not accept gifts, meals, services entertainment or anything else of
value if doing so would create the appearance of undue influence.
•Special
Rules for Agency Contractors during HP Assignment
•May not work for an HP competitor
•May not work for a HP channel, alliance, marketing partners; OEM;
or other non-employer supplier.
•May not work for an HP end-user customer in the purchase or
support of any HP product or service.
•Should disclose to employer situations where business may be
conducted with family or friends.
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Scenarios -- Conflict of Interest
Scenario
Johannes is consulting on marketing plans for a
new HP printer. He has been contacted by an HP
competitor to prepare marketing research.
1.
Johannes can work for an HP competitor at the
same time he works for HP.
True, False or It depends.
Kye is on a temporary contract as a buyer for the
HP server manufacturing organization. One of
the suppliers she buys from is owned by her
brother.
2.
Kye should notify her employer or HP about this
situation.
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True,
False orHPItConfidenital
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Scenarios -- Conflict of
Interest
•
Answer
Answer #1: It depends
− If Johannes is an Agency Contractor, he is prevented from working
for a competitor to HP. If Johannes is an independent contractor or
consultant, he may work for a competitor but he must still adhere to
the remaining provisions of the Code.
•
Answer #2: True
− Kye should alert her employer or an HP agent who can determine if
there is a conflict of interest and make arrangements if necessary to
avoid the conflict or the appearance of conflict.
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CW Code of Conduct
Use of HP
Resources
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• Any
use of assets and resources only for HP business
• Use must be consistent with HP policies and guidelines
• Do not allow family and friends to use HP assets
• Do not use assets for illegal or harassing purposes,
solicitations, pornography
HP Confidenital Final Version
Use of HP assets
Specifics
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Use only by the HP Can’t violate law. No
CW for business threats, pornographic,
purpose harassing, demeaning
Friends and families can’t
use
HP CW should not HP owns emails,
have expectation of voicemails stored or
privacy transmitted on/by HP
equipment
HP may access or retrieve
data at any time consistent
with local law
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No personal gain,
solicitations, chain letters
Scenarios – Use of HP
Assets/Resources
Scenario
1. During his assignment in the HP Finance Department, Marcus has
use of an HP notebook computer. He also owns a business repairing
clocks.
May he load the laptop with a billing software to use in his repair
business?
A. Clock repair is not an HP business. Marcus can load the software.
B. Marcus can’t use HP equipment for personal use.
2. Eric is working at HP on an assignment from his employer inputting
contract information into a computer database. On his breaks, he
surfs the web where he places orders and occasionally visits adult
entertainment sites.
Do any of his actions violate the HP Contingent Worker Code of
Conduct?
Yes or No
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Scenarios – Use of HP
Assets/Resources
•
Answer
Answer #1: B
− Contingent Workers can’t use HP equipment for personal use. Any
use of HP assets and resources, including the company’s computers
and information systems, must be consistent with all HP policies and
guidelines. Unreasonable or inappropriate personal use of any HP
asset is prohibited
•
Answer #2: Yes
− Eric’s actions violate the SBC. His personal use of the computer is
excessive and violates the Code of Conduct for personal use.
Viewing adult content violates other parts of the Code of Conduct.
− Contingent Workers may not use any HP resource in violation of the
law and must not allow others, including friends and family, to use
HP resources for any purpose. HP resources may not be used to
create, transmit, store, copy or display messages, images or
materials that are: for personal gain; solicitations; chain letters; or
messages, images or materials that HP deems to be threatening,
pornographic, sexually explicit, harassing or demeaning to any
person or group.
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CW Code of Conduct
AntiCorruption
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• Do
not bribe government officials
• Do not pay ‘finders fees’
• Document all payments made on behalf of HP
HP Confidenital Final Version
Anti-Corruption
Specifics
Bribery •May not directly or indirectly give
gifts, payments, entertainment
Finder Fees •May not pay a commission or fee
Records •Must document any payments on
behalf of HP
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•Applies
in all countries
Unless in approved
written document
•If
the payment is to win or
keep business
Must be bona fide
distributors, sales reps
agents, consultants
Scenarios – Corruption
Scenario
1. HP has contracted with Horatio’s employer to provide sales
representatives to sell HP printers. Horatio is about to close a large
sale when Ana Lucia, the customer’s buyer, asks for a special fee to
be paid in cash. She says that if the fee is not paid the order will go to
an HP competitor who is willing to pay.
Should Horatio pay the special fee to ensure HP gets the order?
Yes or No
2. Song is a contingent worker who wants to sell an HP IT solution to the
Education Ministry but is having difficulty setting up a meeting with the
Ministry. Harry tells Song that he can introduce him to the Ministry
purchasing officer for $1000. The sale will be for $30 million.
Should Song pay Harry?
Yes or No
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Scenarios – Corruption
Answer
•
Answer #1 & #2: No
− These special fees are violations of the Contingent Worker Code of
Conduct and moreover are illegal in most countries. Ana Lucia is
asking for a bribe. Even if it means losing the order, Horatio can’t pay
a bribe.
− Likewise, the special fee Harry is asking for should not be paid for
introductions.
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CW Code of Conduct
Gray
Marketing
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• Ensure
that HP products are not diverted into unauthorized
channels
• Follow processes for discounting and special promotions
HP Confidenital Final Version
Gray Marketing
“Gray” products are those that enter into
the marketplace without HP’s
authorization. This typically happens
when a channel partner orders more
product than it can use at a substantially
discounted price. It then sells the product
to unauthorized customers. HP has to
compete against these suppliers. Channel
partners who follow rules are at a
disadvantage. HP pays contra revenue
(discount), decreasing profit.
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Scenario -- Grey Marketing
Scenario
Michelle is a contingent worker helping HP
process orders for servers. BIG, a global
partner, qualifies for a large volume discount. A
person claiming to be the employee of a
company affiliated with BIG has placed a
product order under BIG’s discount schedule.
Michelle should:
A. Investigate to see if the affiliate company is
eligible for the discount
B. Find out if the affiliate is a real company
C. Trust the caller and grant the discount because
the order will help the country meet quota.
D. Both A and B.
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Scenario -- Grey Marketing
Answer
•
Answer: D
− Discount authorization must be verified. HP could lose real money if
it gave a discount not earned. Scams do exist using non-existent
company names or addresses.
− Contingent Workers must report any situation that could lead to the
diversion of HP products to the gray market, such as noncompliance
with permitted territorial assignments or abuse of pricing and
promotional programs. Contingent Workers should promptly report
any suspected gray marketing activity to their employer as well as
the HP Ethics and Compliance Office.
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CW Code of Conduct
Insider
Trading
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• Do
not use material, non-public information about HP to
make personal investment decisions
HP Confidenital Final Version
Scenario --- Insider Trading
Scenario
•
Jake works for Axis Co., which is providing consulting
services to HP with respect to an acquisition of a software
company, Radar.
Can Jake buy stock in Radar or
HP?
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Scenario --- Insider Trading
Answer
• Answer: No
• Jake should not buy stock in Radar or HP because he cannot profit
from this material, undisclosed information he obtained from his
work at HP.
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CW Code of Conduct
Confidential
Information
Dealing with
the Press or
Media
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• Adhere
to specific confidentiality obligations agreed to
between employer and HP
• Presume that information from HP is confidential,
including that received from other HP suppliers,
customers or partners
• Contingent
Workers are not authorized to speak to the
media on behalf of HP
HP Confidenital Final Version
Scenario – Confidentiality
Scenario
Anna is working for as an agency contractor as a Procurement
Specialist for HP. She regularly receives parts from suppliers to build
notebook computers.
Anna’s friend Peter is a purchasing agent for an HP competitor in the
notebook computer space. Peter tells Anna about his excellent
negotiations with DISPLAY TECH and that he has been able to get a
great price of 132 Euros for a 17 inch LCD. Anna knows that HP is
currently paying DISPLAY TECH 120 Euros for a similar LCD.
Which of the following are correct?
A. Anna can disclose the price to Peter because there is a chance the LCDs
are not the same model.
B. Anna can’t disclose HP’s price to Peter because the price is confidential
information and Anna would violate the HP Contingent Worker Code of
Conduct by sharing this information with Peter.
C. Anna can disclose the price to Peter because HP’s lower price is
probably because HP buys in higher volumes than Peter’s company.
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Scenario – Confidentiality
Answer
•
Answer: B
− Anna can’t disclose confidential information obtained in her work at
HP.
− Contingent Workers are expected to be familiar with and adhere to
any specific confidentiality terms agreed to between their employer
and HP. If a separate confidentiality agreement does not exist,
Contingent Workers should presume that all information available
from HP is confidential. This includes information that HP may have
received from its suppliers, customers or business partners.
Confidential information may only be used or disclosed as necessary
and appropriate to perform assigned duties on behalf of HP.
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CW Code of Conduct
Privacy
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• Protect
data that is personally identifiable, whether
obtained from HP employees, customers, or partners
HP Confidenital Final Version
Scenario – Privacy
Question
Under a contract to provide IT support to
HP, Roberta is working on a new
employee information database
containing the government identification
numbers for all HP employees. An HP
manager has called Roberta and asked
for a file that contains the names,
salaries and social security numbers of
all his employees in the US.
Roberta should give the manager this
information.
True, False, or It depends
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Scenario – Privacy
Answer
• Answer: It depends.
• Roberta should not give this information to anyone who is not
authorized to have it. She needs to verify with an appropriate HP
decision maker that the manager has a legitimate business need to
have access to the data before she discloses it.
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CW Code of Conduct
NonSolicitation
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• Contingent
Workers may not solicit any HP employee
during his or her work time
• Do not distribute literature or other materials in HP’s
working areas
• Do not hand out materials for non-business reasons
including charitable organizations
HP Confidenital Final Version
Scenario - Solicitation
Scenario
Ravi’s father-in-law asked him to post discount coupons for
his local sandwich shop in the employee lounge areas at
the HP Roseville site. Ravi is an employee of
TEAMWORK, the outsourced contractor managing the food
service needs at the site.
Should he post the coupons?
Yes or No
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Scenario --- Solicitation
Answer
•
Answer: No.
− Ravi should not post the coupons
• This conduct would be considered improper solicitation under
HP’s Contingent Worker Code of Conduct.
• Contingent Workers may not solicit any HP employee during the
HP employee's working time. Further, Contingent Workers may
not distribute literature or other materials in HP's working areas.
The preceding policy prohibits soliciting or handing out materials
for any non-business reason, including for charitable purposes
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Report Misconduct
Talk:
To your employer
Telephone:
Email:
Mail:
corporate.compliance@hp.com
Hewlett-Packard Ethics and
Compliance Office PO Box
692015, Houston, TX 772692015
GuideLine1-800-424-2965
(Outside U.S., first dial AT&T
Access Number)
Code of Conduct for Contingent Workers
•
•
•
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HP expects all suppliers of Contingent Workers to take the
required steps to ensure that members of their workforce
comply with the HP Contingent Worker Code of Conduct..
HP expects that all Contingent Workers will perform
services on behalf of their employees in a manner that is
consistent with this Code of Conduct.
Contingent Workers must report potential violations of this
Code to their employers, their HP engagement manager, or
to the HP Ethics and Compliance Office.
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