Global Ethics and Compliance Committee
The Global Ethics and Compliance Committee is responsible to provide assistance to SunEdison’s management and Board of Directors to enable SunEdison to continue to operate according to the highest ethical business standards and in accordance with applicable laws and regulations.
The Committee is responsible for providing employees with the information, tools, guidance, training and support they need to comply with the Code of Conduct and other compliance policies when making day-to-day business decisions.
The Committee provides effective ethics education, training programs and communications designed to ensure that SunEdison’s ethics and values are integrated into its business practices on a consistent basis around the world.
SunEdison believes that a commitment to high ethical standards is an important competitive advantage. SunEdison is committed to ensuring that ethics is one of the areas in which SunEdison is, and continues to be, a recognized global leader.
The Global Ethics and Compliance Committee has been established by SunEdison to oversee and manage its ethics and compliance program. The Compliance Committee is under the direction of the General Counsel, with ultimate oversight by the Audit Committee and Nominating & Governance Committee of the Board of Directors.
Regularly assess and prioritize the risks pertaining to our business, the emerging issue and priorities in the US and internationally; monitor our activities and update our policies to control these risks.
Policies and Procedures
Develop and update appropriate compliance policies and procedures for the program, including the SunEdison Code of Conduct.
Training and Communication
Increase employee, and as appropriate, agent, customer, supplier and shareholder awareness of ethics and compliance-related policies and procedures through communication, training, and notification of the reporting methods available for possible violations and for other compliance communications.
Support managers in delivering effective, relevant and thoughtful ethics training and communications to employees.
Auditing and Monitoring
Audit and monitor adherence to the Company ethics and compliance-related policies and procedures, including periodically evaluating the effectiveness of the program.
Incentive and Reward Systems
Implement systems, as appropriate, that provide incentives for promoting the compliance program and complying with applicable laws, regulations and SunEdison policies.
Employee Reporting/Seeking Guidance
Establish mechanisms for employees and third parties to report suspected misconduct or violations of ethics and compliance-related policies and to receive guidance on ethics and compliance issues, including an anonymous reporting mechanism.
Establish and communicate policies and procedures protecting employees and others from retaliation for reporting suspected misconduct.
Application of Program to Third Parties
Evaluate the extent to which aspects of the Global Ethics and Compliance program will apply to affiliated entities such as joint ventures, agents and subcontractors.
Evaluation of Program Effectiveness
Monitor developments in applicable legal and regulatory standards, industry practice, and general best practices relating to global ethics and compliance programs.
Review the effectiveness of the Global Ethics and Compliance program under applicable legal and regulatory standards, including the effectiveness of our policies and procedures, training, auditing, monitoring, reporting, investigations, discipline, disclosure, and the awareness and promotion of an ethical culture within SunEdison.
Evaluate the sufficiency of the Financial, Ethics and Compliance Hotline, including the communication of its availability to employees and reviewing the performance of the outsourced organization used to manage the program.
Reporting to the Board
Meet with or report to the Audit and Nominating & Governance Committee of the Board of Directors on a regular basis regarding ethics and compliance issues and the status of the program.