ABOUT THIS REPORT The information in this report is ... - Cummins

Governance, Risk Management and Security
2011 COMPLIANCE TRAINING
Sustainability built
on good governance
OUR PRINCIPLES
Cummins ethics and governance initiatives are built
around the 10 Statements of Ethical Principles
in the Code of Business Conduct:
These figures are accumulated enrollments going
back to when the courses were first implemented.
Course Enrolled Completion
Rate
Cummins believes that a sustainable company
is built on a foundation of good governance
1 We will follow the law – everywhere.
2 We will embrace diverse perspectives
and backgrounds and treat all people
Anti-bribery 17,723 88%
Antitrust and Fair Competition 7,990 92%
GOVERNANCE & RISK
that promotes ethical behavior at all levels.
Highlights
»»
Cummins establishes
an ethics and compliance
organization independent
of its business units.
»»
Board of Directors
travel to China to review
operations and strategy.
»»
Risk Management
takes a more holistic
The Company took an important step
in its governance efforts in 2012 by
creating an ethics and compliance
organization independent of our business
units and corporate functions, led by
an officer at Cummins.
The move was made not in response to
any problem but in recognition of the critical
role ethics and governance play in the
success and sustainability of a company.
“Cummins already has successful
compliance efforts in most aspects
of our business,” said Cummins CEO
Tom Linebarger in announcing the move.
“This new group will be looking to build
on these successes and develop our
processes and resources to ensure
continuous improvement.”
Linebarger reminded employees that
ethical behavior remained the responsibility
of every employee at Cummins.
“Acting in accordance with our Code
of Business Conduct is the responsibility
of every employee at Cummins and the
creation of this new ethics and compliance
organization does not change the primary
accountability each of us has to live
Cummins’ values in every aspect of
our work,” Linebarger said.
Mark Sifferlen, formerly the Company’s
Deputy General Counsel, was named
the Company’s first Vice President –
Ethics and Compliance.
with dignity and respect.
3 We will compete fairly and honestly.
4 We will avoid conflicts of interest.
5 We will demand that everything we do leads
to a cleaner, healthier and safer environment.
6 We will protect our technology, our information
and our intellectual property.
7 We will demand that our financial records
and processes are clear and understandable.
8 We will strive to improve our communities.
9 We will communicate with honesty and integrity.
10 We will create a culture where all employees
take responsibility for ethical behavior.
Cummins puts these principles into practice
through a comprehensive compliance training
program targeting appropriate employee
groups to promote ethical behavior.
The Company has required courses on topics
Careful Communication 22,991 90%
Code of Business Conduct 16,204 100%
Conflict of Interest 23,663 89%
Export Compliance 17,643 100%
Fair Labor Standards Act 512 90%
Global Competition
Principles and Practices 11,384 82%
Information Protection 22,858 88%
Intellectual Property 5,522 93%
Lobbying and Political Action 567 91%
Managing within the Law 458 97%
GOVERNANCE & RISK
approach that includes
key global functions.
ranging from Anti-bribery to Lobbying and
Political Action and Information Protection.
Records and
Information Management 22,689 100%
Indiana Gov. Mitch Daniels,
sitting closest to Chairman
The Company’s policies and procedures
in these areas are periodically updated.
Treatment of Others 15,154 100%
and CEO Tom Linebarger (far
right) attended the Company’s
expansion announcement in
For example, in 2012 the Company will
update its Code of Business Conduct.
Seymour, Ind. in the spring of
2012. Part of the project is a
commitment on behalf of local,
state and company officials to
focus on education in the city.
92 SUSTAINABILITY REPORT 2011–2012