Open Reporting

A hallmark of GE’s compliance program is a steadfast commitment to a vibrant, well publicized and effective “open reporting environment,” where employees are encouraged to raise integrity concerns, and feel confident that they can do so without fear of retaliation. In today’s environment, GE employees remain the Company’s first and best line of defense for the early detection of potential compliance issues. Early detection and reporting depend on maintaining a compliance culture in which all employees:

• Understand their responsibilities to promptly report concerns about potential violations of GE policies, laws or regulations
• Know and use the channels available to them to report concerns, including managers, compliance, and GE’s comprehensive network of approximately 700 ombudspersons
• Trust that the process is confidential, with no tolerance for retaliation

As we previously reported, GE launched a multiyear corporate-led initiative that was designed to review and assess the health of this essential culture. We commenced the initiative by obtaining data from a sample of more than 45,000 employees through an anonymous third party–administered survey and focus groups across every business and region. We analyzed the data with the help of 77 senior managers at our Crotonville facility, through a Management Development class dedicated to the theme of Open Reporting.

We learned through these efforts that employees wanted more information about how our open reporting system was performing, and how our process works once an integrity concern is raised. Employees also want more communications featuring the local business environment. Our initial response included:

• The launch of the inaugural edition of “Spotlight on Compliance,” an intranet site dedicated to sharing real-life compliance cases and how they were resolved
• Emphasizing local videos and compliance stories. Compliance leaders overseas have been armed with “flipcam” cameras to capture video from employees speaking about our process
• Providing more information about our reporting process, including a document titled “What Happens after I Raise an Integrity Concern”

Our efforts were successful; in a companywide employee survey, employees provided the following responses:

• 94% would report observed misconduct
• 93% are confident they can recognize compliance issues
• 92% know how to report compliance issues

Despite these strong scores, there is still more work to be done. In particular, in 2011 we will continue to ensure that employees feel comfortable reporting concerns without fear of retaliation and that there are no compromises on conducting business in an ethical way.

To address these points, we have convened a cross-business and global working group that is tasked with further improvements to our process. This group will develop a new in-person training course on open reporting for the Company’s managers, and drive a new focus on increasing recognition and rewards for employees who report concerns that have a significant impact, and managers who create the right environment for reporting.