Case study: How Goodyear promotes compliance and ethical business behaviour
Employing approximately 61,000 full-time and temporary associates worldwide and operating 46 manufacturing facilities in 21 countries, Goodyear is one of the world’s leading tire companies, developing, manufacturing, marketing, and distributing tires for most applications, including automobiles, trucks, buses, aircraft, motorcycles, racing, earthmover, mining, industrial and farm equipment. Upholding its commitment to ethical behaviour, compliance, and to demonstrating ethical values, is a top priority for Goodyear. Tweet This!
This case study is based on the 2019 Corporate Responsibility Report by Goodyear published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.
Abstract
To make sure high ethical standards are applied across its operations, Goodyear’s global and regional Compliance and Ethics Committees meet several times a year, to discuss compliance and ethics matters, initiatives, and training. In order to promote compliance and ethical business behaviour Goodyear took action to:
- implement a Business Conduct Manual
- provide compliance and ethics training
- establish an Integrity Hotline
- promote data privacy and protection
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With this case study you will see:
- Which are the most important impacts (material issues) Goodyear has identified;
- How Goodyear proceeded with stakeholder engagement, and
- What actions were taken by Goodyear to promote compliance and ethical business behaviour
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What are the material issues the company has identified?
In its 2019 Corporate Responsibility Report Goodyear identified a range of material issues, such as product quality, business continuity, sustainable raw materials and sourcing, talent development, community engagement. Among these, promoting compliance and ethical business behaviour stands out as a key material issue for Goodyear.
Stakeholder engagement in accordance with the GRI Standards
The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:
Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.
Key stakeholder groups Goodyear engages with:
To identify and prioritise material topics Goodyear engaged with its stakeholders through the following channels:
| Stakeholder Group | Method of engagement |
| Board Members
| · Board meetings · Committee meetings · Annual shareholders meeting |
| Customers
| · Daily communication via emails, calls and meetings · Occasional on-site visits · Annual Customer Conference (North America) |
| Distributors
| · Daily communication via emails, calls and meetings · Occasional on-site visits · Annual Customer Conference (North America) |
| Suppliers
| · Daily communication via emails, calls and meetings · Occasional face-to-face meetings at Goodyear or supplier facility |
| Regulators
| · Engagement with governments in countries of operation, as necessary |
| Industry Associations and Non-Governmental Organisations (NGOs)
| · Tire Industry Project (TIP) ongoing workgroups · Trade associations, including US Tire Manufacturers Association (USTMA), European Tyre and Rubber Manufacturers’ Association (ETRMA), Japan Automobile Tyre Manufacturers Association (JATMA) and Automotive Industry Action Group (AIAG) · Frequent interaction with NGOs |
| Investors
| · Quarterly earnings calls · Annual shareholders meeting · Frequent investor calls and emails |
| Collaborators
| · Various collaborator engagements throughout the year on a variety of projects |
| Community Members
| · Charitable contributions · Regular volunteer activities · Community programme development |
What actions were taken by Goodyear to promote compliance and ethical business behaviour?
In its 2019 Corporate Responsibility Report Goodyear reports that it took the following actions for promoting compliance and ethical business behaviour:
- Implementing a Business Conduct Manual
- Goodyear’s Business Conduct Manual, updated in 2018, guides its Board of Directors, executive team, and all associates globally. It defines behaviours necessary to support Goodyear’s high standards and reinforces associate compliance with all applicable laws and business practices. The Manual is available on Goodyear’s corporate website, company intranet and in hard copy for associates without internet access. It is available internally in 14 languages, to help ensure global comprehension. Goodyear regularly updates its Manual to make sure it reflects the current workplace and regulatory landscape and on an annual basis, salaried associates must review and affirm their knowledge of the Manual, promise to abide by it and disclose any known violations of certain policies.
- Providing compliance and ethics training
- Goodyear requires almost all global salaried associates and new hires to complete online training covering the Business Conduct Manual and key compliance policies. In 2019, more than 96% of those associates completed online training courses on such subjects as competition law, anti-corruption and anti-bribery, and being a compliance leader. Goodyear has a three-year training cycle that it reviews and amends annually to ensure its ethics and compliance training topics remain relevant and address the risks facing Goodyear. Throughout 2019, Goodyear conducted in-person trainings across all strategic business units and focused compliance campaigns in many countries and plants on various subjects, such as respect in the workplace (including harassment and discrimination), conflicts of interest, competition law, speaking up, preventing and detecting fraud and bribery, gift and entertainment policies, and privacy. Additionally, Goodyear’s Quarterly Ethics Awareness Campaign, covering topics from the Manual, takes place in its company-owned retail, wholesale and commercial tire service locations in the United States, United Kingdom, France, Canada, Japan, Africa, Australia, and in its Airship Operations. During the 2019 quarterly campaign, managers led their teams in conversations on compliance and ethics subjects such as workplace violence, speak up, theft, and substance abuse.
- Establishing an Integrity Hotline
- All Goodyear associates are required to report any actual, suspected, or potential misconduct to management or through the company’s Integrity Hotline. Available 24 hours a day, 7 days a week from anywhere in the world via toll-free telephone or by a dedicated website, Goodyear’s Integrity Hotline allows associates and third parties to report a concern or ask a question, including anonymously (where allowed by law). The Compliance and Ethics Department reviews each Integrity Hotline matter and, in cases where an allegation of misconduct is substantiated, Goodyear takes appropriate disciplinary or remedial action. Goodyear strictly prohibits retaliation against individuals for making a report in good faith and Speak Up education and awareness campaigns are held, to remind associates of the Integrity Hotline and to encourage them to raise questions or concerns.
- Promoting data privacy and protection
- Like many global companies, Goodyear faces data security risks, and monitors new and developing regulations and best practices to anticipate and mitigate such risks. For example, in 2018, the European Union’s General Data Protection Regulation (GDPR) replaced the Data Protection Directive 95/46/EC and, in 2019, California also passed a comprehensive new privacy law. As a response to these and other regulations, Goodyear updated its Global, Online, and Associate Privacy Policies to comply with these regulations and privacy best practices and implemented additional training programmes for associates who interact with personal information.
Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?
The GRI Standard addressed in this case is: Disclosure 205-2 Communication and training about anti-corruption policies and procedures
Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:
- Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
- Targets: 16.5
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References:
1) This case study is based on published information by Goodyear, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:
http://database.globalreporting.org/
2) https://www.globalreporting.org/standards/gri-standards-download-center/
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