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Anti-Corruption Program

Anti-Corruption Program

 

Anti-Corruption Program Overview:

At Motorola Solutions, we are committed to conducting our business with integrity. Our Code of Business Conduct and annual Corporate Responsibility Report outline our values, as well as our expectations for our employees, suppliers and all those we do business with.

Additionally, we have a robust and dynamic anti-corruption program based on compliance guidance issued by government agencies in connection with the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act, as well as other extraterritorial and local anti-corruption laws and regulations. Our anti-corruption program is managed by a dedicated team of compliance experts, including a Chief Compliance Officer and legal counsel.  

Our executive leaders champion a culture of ethics and compliance for the company, and our Office of Ethics and Compliance reinforce this through up-to-date policies, global training for employees and business partners, and regular anti-corruption program briefings and disclosures to our CEO, General Counsel and members of our Board of Directors. Our Office of Ethics and Compliance also works closely with internal audit services, external auditors and outside counsel to monitor compliance and consults with company management to update policies and processes, as appropriate.  

Risk Based Approach:

We apply a risk-based approach to developing, modifying and managing our anti-corruption program and associated ethics policies. The Office of Ethics and Compliance meets quarterly with internal stakeholders to analyze risks and performs ongoing review of evolving business, legal and regulatory environments to ensure alignment of our policies and business practices. In addition, our internal and external auditors regularly review our policies, processes and controls to ensure compliance and bridge gaps. 

Anti-Bribery Statement:

Our policies, including the Code of Business Conduct and accompanying internal policies, prohibit bribery and corrupt payments, which are defined as the offering, authorization, commitment or provision of anything of value (e.g., cash, travel, gifts, scholarships, etc.) to a government official or to an officer, director, employee, agent, representative or consultant of a commercial entity, in an attempt to induce the recipient to misuse his or her position and grant favorable action, to refrain from official action contrary to our business interests, to use their influence to secure action or inaction of a third party to advance our business interests or otherwise to obtain an improper business advantage. 

Gifts and Entertainment:

Our Code of Business Conduct and supporting policies describe the appropriateness of gift giving and receiving and prohibit employees and our representatives from paying or receiving bribes in any form, including gifts and entertainment. Although gift giving practices vary by location and culture, we require that all gifts comply with applicable law and be made in accordance with our policies. 

Facilitation Payments:

Employees and our representatives are prohibited from making improper or illegal payments to accelerate administrative or ministerial actions, often referred to as “facilitation payments” or “grease payments.” 

Reporting Concerns:

The Office of Ethics and Compliance established the EthicsLine and EthicsLine Interactive tools so that our employees, business partners and others may ask questions and report concerns related to compliance with our Code of Business Conduct, or the laws, regulations and contract provisions that govern our business. Except where prohibited by local law, the EthicsLine is available globally to all Motorola Solutions employees and other parties (internal and external) as one of several means to communicate directly with the Office of Ethics and Compliance confidentially and without fear of retaliation. We encourage people to use the EthicsLine to seek help, ask questions and report matters of concern. The EthicsLine may be reached by phone, email, voice mail, SMS/text or direct contact with members of the Office of Ethics and Compliance or one of our dozens of Business Conduct Champions located in offices throughout the world. For internal employees, the Office of Ethics operates EthicsLine Interactive, an online confidential reporting tool available globally where permitted by law to all employees and non-employees with access to Motorola Solutions’ intranet.

Whistleblower Protection / Non-Retaliation:

Our whistleblower policy applies globally and incorporates specific protections afforded by applicable local laws. Retaliation in any manner for raising issues and concerns honestly is strictly prohibited. We will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any employee in the terms and conditions of employment based upon any lawful actions of such employees with respect to good faith reporting of complaints as specified in Section 806 of the Sarbanes-Oxley Act, section 1553 of the American Recovery and Reinvestment Act, section 846 of the National Defense Authorization Act or other applicable law.

Conflicts of Interest:

Our policy requires that business decisions and actions must always be based on the best interests of our company, and must not be motivated by personal considerations or relationships. Our employees and business partners are required to disclose any situation that may be, or appear to be, a conflict of interest to their manager and the Office of Ethics and Compliance. In order to minimize the occurrence of conflicts of interest, the Office of Ethics and Compliance maintains an online tool to document potential conflicts and appropriate mitigations steps.

Third Party Resellers:

We believe that it is essential that third parties representing us meet our ethical standards and comply with all applicable anti-corruption treaties and laws in every country where we do business. To ensure that our third party resellers understand their obligations and that appropriate due diligence is conducted we adopted certain controls, including:

●      Requiring a risk assessment and due diligence review for all third party resellers to ensure that only persons and entities with satisfactory reputation and proper qualifications are engaged to represent us;

●      Engaging in clear communication of our expectations to third party resellers;

●      Providing training to all third party resellers and their internal sponsors;

●      Execution of a written agreement before the third party reseller may represent us;

●      Requiring partners in higher risk countries to recertify on an annual basis;

●      Application of appropriate anti-money laundering protocols and compliance with all applicable accounting and banking regulations in connection with payments to third party resellers; and

●      Maintaining complete and accurate records related to third party resellers’ activities.

Donations and Sponsorships:

We are proud of the long history of philanthropy by our company and employees. Our policies help guide us in making the right decision when donating to charitable causes, disaster relief and to support the communities where we do business and our employees live, as well as when sponsoring industry, customer and company events. To ensure that our philanthropic resources are used in an efficient, responsible and legal manner, all donations and sponsorships, including donations to charitable organizations, are reviewed and documented via an online tool that requires management and legal approval. 

Regional Supplements:

Our policies apply wherever our employees are located and in every country in which we do business. From time to time, we supplement our policies with additional language that applies on a regional or national basis to ensure compliance with applicable laws.

Training:

We provide ethics and anti-corruption training to all employees, third party resellers and other representatives in live and online sessions conducted by members of the Office of Ethics and Compliance, our Business Conduct Champions, our regional legal teams and external resources. Training cadence, annually to triennially, varies based on course curriculum, region and job function and the Office of Ethics and Compliance monitors and reports on employee and contract resource training progress. 

Audits:

In order to identify and bridge gaps in our policies and processes, the Office of Ethics and Compliance partners with our Audit Services team to measure compliance at regular intervals, in some cases annually, on topics such as training, travel and entertainment, third party resellers and service providers, fraud risk assessment, gifts and political activities. 

Compliance Encouragement and Disciplinary Actions:

Performance management matters. We believe that employees deserve to know where they stand. We set clear expectations regarding both performance and demonstration of our company’s values.  In addition to the Code of Business Conduct, our policies set forth expectations for employee behaviors as well as a process for dealing promptly with employees who violate our policies, whose actions are disruptive to a normal business environment or whose conduct may have a negative impact on the employment relationship or Motorola Solutions’ reputation and standing in the community. Discipline may occur in any case where an employee’s actions appear to be detrimental to the operation of the business or to other employees.