: What the purpose of WDC’s Ethics & Compliance Program?
A1: The purpose of WDC’s Ethics & Compliance Program is to foster the highest ethical standards and a commitment to compliance with the law and policy amongst WDC employees, contractors and any third parties who transact business on our behalf. The Ethics & Compliance Program includes core programs on anti-bribery and corruption, competition law, trade compliance, insider trading, and IP compliance. It also includes programs designed to ensure employees, contractors and agents carry out their duties in accordance with law, policy, and the highest ethical standards.
Q2: What is a compliance risk assessment?
A2: A compliance risk assessment is a process to evaluate the strength of our ethics and compliance program. During the assessment we identify any significant compliance risks to WDC, evaluate the methods by which we are addressing those risks, and take steps to improve our ongoing effectiveness.
Q3: Doesn’t our internal audit team already do an assessment?
A3: Yes, our internal audit team does a broad risk assessment for WDC. However, that assessment is focused primarily on financial and business continuity risks rather than on compliance and ethics.
Q4: Does the scope of the assessment include both subsidiaries?
A4: Yes, the assessment will gather input from both the WD and HGST subsidiaries. We will seek input from all geographies, departments and levels within these organizations.
Q5: This seems like a lot of time and effort for everyone. Is it really necessary?
A5: The assessment is critically important. The WDC Board of Directors and our senior leadership team have recognized the need to closely evaluate our compliance processes and resources. This assessment will enable us to strengthen our business and help protect our employees and reputation.
Q6: Who is leading this effort?
A6: Eva Lehman, vice president, Litigation & chief compliance officer, is leading the assessment process. Eva has assembled a small team across the company to assist her.
Q7: How will the assessment be conducted?
A7: The team will conduct individual interviews and focus group discussions with WD and HGST employees globally.
Q8: What if I want to provide input, but don’t get interviewed or asked to participate in a focus group?
A8: We welcome input from everyone. In the future, we will send a survey to all employees requesting participation. In the meantime, we encourage employees to email the Compliance team if you have