Best compliance and ethics program (large cap) Ingersoll Rand
Robert Mayfield, Ingersoll Rand
The combination of Gardner Denver and Ingersoll Rand’s industrials segment in 2020 led to both a new company and the challenge of creating a successful combined compliance and ethics program.
Robert Mayfield is the director of global compliance at Ingersoll Rand and together with his team led the successful integration of legacy Gardner Denver and legacy Ingersoll Rand compliance programs. ‘We understood that this was a journey, including from a compliance and ethics perspective,’ he says.
One of the challenges, Mayfield explains, was ‘the speed at which we could move’ during a merger process. Among other things, the team had to learn where the biggest risks were for both legacy businesses and to understand their operational and cultural differences.
Ingersoll Rand’s code of conduct was developed during the merger. Mayfield says everything is derived from the code and both sides of the transaction leaned on each other in developing it. The team had to start from scratch, so it looked at both companies’ historical frameworks and used principles from both, he says.
Key to the code’s design was a focus on the ‘we’ as a company, Mayfield says. Where many other firms view codes as sending down instructions from the top of the business, Ingersoll Rand’s is designed as a means for conveying how everyone at the company is going to work and succeed, he adds.
The company also recognizes that a code of conduct is effective only if it is understood and followed and, as such, employees are expected to read, comprehend and attest each year their adherence to it.
Ingersoll Rand in 2021 reported that 100 percent of its almost 16,000 global salaried and hourly employees had attested to and been trained on its code.
Supplier code Ingersoll Rand has also created a supplier code of conduct, which it expects suppliers to uphold as they adhere to the company’s principles of responsible global sourcing. ‘Our suppliers are essential to the success of our organization,’ Mayfield explains.
The company works to assure external stakeholders that the supplier code is effective by assigning a dedicated team of compliance professionals to train, monitor and enforce the code. It also commissions an independent third party to conduct annual entity-level control auditing of the code of conduct compliance program.
This process includes annual confirmation of the global code of conduct certification process, verifying the global ethics hotline is in operation – including upward reporting to the board’s audit committee – and requiring quarterly written certification from company leaders.
Should a violation of the code of conduct occur, the company encourages both internal and external stakeholders to submit good faith reports and requests for guidance on internal policies and procedures. Reports can be made anonymously by the stakeholder, if preferred.
Ingersoll Rand is keen to provide constant reminders of its purpose and values and, as a result, promotes its integrity materials at every company location globally, using local languages and in-country phone numbers to help with the reporting process if employees have concerns or questions.
Mayfield describes a standout aspect of the firm's compliance and ethics program as having team members who are experts across the compliance spectrum.
The company’s award submission states: ‘Ingersoll Rand believes that individual responsibility makes a successful ethics and compliance program. To establish and execute this accountability, Ingersoll Rand tracks its code reports and is transparent in the reporting in the company’s annual sustainability report as part of its [ESG] efforts.’
