Ethics and Compliance

Ethics and Compliance

At Dell, we value honesty, integrity and the highest level of ethical conduct. There are many reasons we devote ourselves to creating a culture that is based on high ethical standards. High standards enhance our reputation as a company and employer of choice. They also help in the acquisition and retention of the best and most talented employees and build stakeholder trust, confidence and loyalty. We also know that adhering to high standards minimizes the impact of ethical issues on company operations and financial performance.

The Soul of Dell

The Soul of Dell reflects the values and beliefs that define our shared global culture. Starting in 2000, Dell began the “Soul of Dell” initiative to redefine our values and elucidate what Dell aspires to be as a company.

Company leaders gathered input through a series of worldwide meetings. We hired an outside firm to perform a questionnaire-based “cultural audit” to identify our company’s strengths and weaknesses. The audit showed our strong push for winning and operational excellence, but revealed our need to improve employee teamwork and the balance between work and life.

With this feedback, the executive team drafted the “The Soul of Dell” statement. It reflects the company’s drive to win and its direct manufacturer-to-consumer business model. But it also emphasizes teamwork, a commitment to being a meritocracy, ethics, customer relationships, and global citizenship.

Core Elements of the Soul of Dell

The Soul of Dell defines the kind of company we are and aspire to become, serves as a guide for our actions around the world, and ultimately forms the basis of our "winning culture." The core elements of the Soul of Dell include the following:

Customers: We believe in creating loyal customers by providing a superior experience at a great value. We are committed to direct relationships, providing the best products and services based on standards based technology, and outperforming the competition with value and a superior customer experience.

The Dell Team: We believe our continued success lies in teamwork and the opportunity each team member has to learn, develop and grow. We are committed to being a meritocracy, and to developing, retaining and attracting the best people, reflective of our worldwide marketplace.

Direct Relationships: We believe in being direct in all we do. We are committed to behaving ethically; responding to customer needs in a timely and reasonable manner; fostering open communications and building effective relationships with customers, partners, suppliers and each other; and operating without inefficient hierarchy and bureaucracy.

Global Citizenship: We believe in participating responsibly in the global marketplace. We are committed to understanding and respecting the laws, values and cultures wherever we do business; profitably growing in all markets; promoting a healthy business climate globally; and contributing positively in every community we call home, both personally and organizationally.

Winning: We have a passion for winning in everything we do. We are committed to operational excellence, superior customer experience, leading in the global markets we serve, being known as a great company and great place to work, and providing a superior shareholder value over time.

Dell’s Code of Conduct

Just as The Soul of Dell articulates our values and beliefs, Dell’s Code of Conduct (“the Code”) acts as the touchstone of efforts to maintain our higher standard for personal and business integrity. The Code, found online at www.dell.com/codeofconduct, is consistent worldwide, and available in 17 languages. Before starting work at Dell, new employees are required to read and acknowledge the Code and agree to abide by the Code and related policies. In addition, our Code is shared with Dell suppliers and partners to ensure that they understand our expectations for business conduct.

Key Elements

Our Code of Conduct includes several key components:

  • Trust: Our word is good. We keep our commitments to each other and to our stakeholders.
  • Integrity: We do the right thing without compromise. We avoid even the appearance of impropriety.
  • Honesty: What we say is true and forthcoming — not just technically correct. We are open and transparent in our communications with each other and about business performance.
  • Judgment: We think before we act and consider the consequences of our actions.
  • Respect: We treat people with dignity and value their contributions. We maintain fairness in all relationships.
  • Courage: We speak up for what is right. We report wrongdoing when we see it.
  • Responsibility: We accept the consequences of our actions. We admit our mistakes and quickly correct them. We do not retaliate against those who report violations of law or policy.
All Dell employees — regardless of grade level, position or geographic location — are required to base daily actions and conduct on these standards.

New Policies for New Forms of Communication

Technology is changing. Customers, suppliers, the media and other stakeholders are using online communication tools such as Web logs (blogs) and other online channels (such as chat rooms) to communicate with us. Our policies must adapt if we want employees to maintain our higher standard of personal responsibility. That’s why in 2006 we issued the Dell Global Policy on Electronic Dialogue by Employees.

Following the launch of this internal policy in November 2006, Dell announced an industry-leading standard for ethical, accurate and transparent communication through Web logs, chat rooms, discussion forums and other online channels used to communicate with customers and other stakeholders. Dell’s new Online Communications Policy is aligned with or follows the recognized industry standard for online marketing and communications established by the Word of Mouth Marketing Association (WOMMA). For more information on Dell's online communications policy, see www.dell.com/blogpolicy.

Ethics Day

As part of our ongoing internal Ethics Campaign, we launched Dell’s Global Ethics Day. On May 11, 2006, Ethics Day events kicked off in 45 Dell sites around the world. More than 12,000 employees attended the different events and participated in Dell ethics activities that included external speaker conferences, trivia contests, sports games, consulting sessions and training. Members of the senior leadership team led the site events, which focused on the importance of “Raising the Bar” and “Winning with Integrity.” In a post event survey, 87 percent of attendees qualified the Global Ethics Day as a well-done, positive event, worth repeating every year.

Global Ethics — Regional Implementation

While we consider ethics an overarching global value, we recognize the importance of respecting the distinct cultures and business needs specific to each region. After all, Dell employees live on six continents and speak more than 28 languages. We restructured our management team to include an Ethics, Privacy, and Compliance organization which oversees all the ethics and privacy functions at Dell. Our regional ethics leaders, reporting to the corporate team, are responsible for localizing these corporate values to be effective at the regional level. Ultimately, regional leaders implement their own strategy, training and communication and are accountable for driving our ethical values.

Ethics and compliance plans are based on regional business plans, but all employees have the same ethical and privacy commitments and standards of behaviour. The commitments and behaviours spring from the Dell Code of Conduct.

Our CEO and Board also play an important role. Our CEO participates on our global Ethics Council. The Board gets updates from our chief ethics and compliance officer on compliance progress, issues, strategy, and direction.

WOMMA Ethics Code

  1. Consumer protection and respect are paramount.
  2. We follow the Honesty ROI: honesty of relationship, opinion, and identity. That is, you say who you are speaking for, you say what you believe, and you never obscure your identity.
  3. We respect the rules of the venue.
  4. We manage relationships with minors responsibly.
  5. We promote honest downstream communications.
  6. We protect privacy and permission. For further information, see http://www.womma.org/ethics.


Dell has won recognition and numerous awards for its efforts in Global Ethics, Privacy, and Compliance in 2006.

FORTUNE Magazine’s Most Admired Companies

Dell was ranked among the top ten most admired companies globally by FORTUNE’s annual survey. For this “All-Star” list, FORTUNE asked 13,000 industry executives, directors and securities analysts to vote for the companies that they admired most, from any industry. More than 500 companies in over 60 industries were rated on the following eight critical reputation drivers: quality of management; quality of products and services; innovation; long-term investment value; financial soundness; ability to attract, develop and keep talented people; social responsibility; and use of corporate assets.

Business Ethics Magazine’s Top 10 Best Corporate Citizens

Dell ranked No. 9 in Business Ethics’ list of “100 Best Corporate Citizens” among major U.S. companies. The annual “100 Best Corporate Citizens” list evaluates the top 1,000 largest publicly-traded companies in the U.S. and is based on a statistical analysis of performance in the following eight stakeholder categories: shareholders, community, governance, diversity, employees, environment, human rights and product. Dell scored highest this year in the categories of employee relations, community engagement and environmental responsibility. Dell has been ranked for six of the list’s seven years of publication. In recent years, Dell has won acclaim for the company’s commitment to corporate citizenship, notably as the 2005 winner of the Business Ethics Environmental Progress Award. For more information, see www.thecro.com.

Employee Tools

We encourage employees to raise Code and related inquiries or concerns to their managers or a member of our global ethics team. Building direct relationships is a core value at Dell, and it starts with direct and open communication between managers and employees. If employees prefer anonymous communication, they can call our third-party-managed Ethics Helpline to ensure privacy.

We promptly and thoroughly investigate ethics issues. We protect employees who make good faith reports of suspected misrepresentation or impropriety from retaliation or damage to their career, reputation, and employment at Dell.

Global Privacy — Protecting Personal Information

We value our customer and employee privacy. When customers visit www.dell.com, we help them maintain control over their personal data. We keep all information confidential and use it only to support their relationship with Dell. Dell proudly displays the Better Business Bureau Online Privacy Seal on U.S. Web sites, which certifies that we adhere to industry-standard privacy practices. For more information on Dell’s comprehensive privacy policy, see www.dell.com/privacy.

TRUSTe/Ponemon Institute Most Trusted Company for Privacy Award Finalist

Consumers selected Dell as one of the companies they trust most with their personal information in a survey conducted by the Ponemon Institute. Partnering with the independent trust authority organization TRUSTe and Watchfire, a leading maker of online risk management software, the Ponemon Institute evaluated 30 elements of Web site and e-mail privacy, Web site security and customer service that correspond to consumer-friendly standards. The list ranked Dell as one of the top 20 companies based on our performance in these areas.

For example, the Ponemon Institute looked at e-mail disclosures and permission levels, ease of finding contact information for privacy issues, presence of a third-party dispute resolution process and level of security on pages requesting personal or sensitive information. The Ponemon Institute also conducted “secret shopping” questions on privacy by contacting each of the top 20 companies through Web site, e-mail or Call Center customer service.

Thurmond B. Woodard

Thurmond B. Woodard, Chief Ethics, Privacy and Compliance Officer and Vice President, Global Diversity died April 4, 2007. He joined Dell in 2000 as the company's first vice president for Global Diversity.

As Dell’s first vice president for Global Diversity and Chief Ethics, Privacy and Compliance Officer, Thurmond had immense influence on Dell’s growth as a company. He was instrumental in helping us define and promote our distinctive winning culture. His vision and dedication to diversity and ethics were critical in helping us extend Dell’s global reputation for business ethics and integrity. Thurmond’s impact was wide reaching. His sensible counsel, generosity of spirit, tireless dedication and optimism were appreciated and admired by all he touched. His passing leaves a void impossible to fill.


Dell’s Global Ethics Day

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