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American Express Company 2015 Corporate Social Responsibility Report

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GRI INDEX<br />

Business ethics policies and<br />

procedures<br />

Our policies hold us accountable<br />

to the highest legal, ethical and<br />

operational standards.<br />

ANTI-BRIBERY & CORRUPTION<br />

As a global company, we are subject to international anti-corruption and bribery laws. Bribery of any kind<br />

is prohibited. We also believe that our employees and the people or organizations acting on their behalf<br />

must engage in high standards of ethical and transparent business practices. We require all employees<br />

and third-parties to complete anti-corruption and bribery training to ensure they are informed of all<br />

laws and regulations we must abide by and understand the consequences of non-compliance. We hold<br />

employees accountable for completing the training by tying it to annual compensation.<br />

ANTI-MONEY LAUNDERING<br />

Beyond conforming to relevant statutes, we ensure that our employees understand the actions that may<br />

be violations of anti-money laundering or terrorist financing laws. If there are any potential violations, we<br />

immediately escalate to Compliance and Legal staff.<br />

We make every effort to combat money laundering by:<br />

• Taking reasonable steps to determine the true identity of all customers who maintain accounts and/<br />

or relationships with <strong>American</strong> <strong>Express</strong>.<br />

• Taking appropriate measures, such as ending relations with a customer, closing or freezing an<br />

account and/or filing a suspicious activity report when we have a reasonable suspicion that<br />

funds held in an account are from money laundering or other criminal activity, or are owned by a<br />

government-designated terrorist entity.<br />

• Complying with all anti-money laundering and counter-terrorism laws and regulations, and fully<br />

cooperating with law enforcement and regulatory agencies.<br />

WHISTLEBLOWER PROGRAMS<br />

It is our policy to closely scrutinize and respond to allegations from employees, suppliers, customers,<br />

merchants or contractors that the company is not meeting its legal or ethical obligations. More<br />

information about this can be found in the Ombuds Office section.<br />

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