We are committed to fostering a work environment that promotes integrity and ensures compliance with international, federal, state, and local laws and regulations in our relationships with customers and other businesses. We aspire every day to earn the respect and trust of our stakeholders — customers, employees, shareholders, and the people in the communities we serve — and view them as partners in a collaborative effort to preserve our legacy of integrity.
We maintain an effective compliance program that fosters a culture of ethics throughout the company, and helps us respond to changing needs and the external environment in which we operate. We proactively establish internal controls to ensure compliance with applicable laws and regulations, as well as our company policies and contracts.
Arthur R. Block, our Corporate General Counsel, is a "high-level person" within the meaning of the United States Sentencing Guidelines and has overall responsibility for the compliance program. He has appointed Jennifer Heller as Chief Compliance Officer, and she has day-to-day operational responsibility for the program. Both executives report regularly on the compliance program to our Board of Directors or appropriate committee(s) of our Board.
Comcast and NBCUniversal are committed to creating an open environment where our employees feel comfortable raising concerns and are not distracted by unresolved problems at work. Whether it is about a day-to-day or more significant workplace problem, a concern about suspected illegal or unethical conduct, or even an idea for a better way of serving customers, Comcast Listens offers a process to help all of our employees feel comfortable speaking up. We encourage employees to report misconduct, and the company takes those allegations very seriously. We strictly prohibit retaliation for raising an issue.
Comcast Listens gives employees several different ways to report workplace or integrity issues, including a toll-free, 24/7 helpline and a web portal. An independent, third-party company administers the Comcast Listens helpline and web portal, giving employees the option to remain anonymous when reporting issues. Concerns received through the Comcast Listens helpline or web portal are logged, acknowledged, and when necessary, investigated by a trained investigator from the Human Resources, Security, Internal Audit, or Law department. If an investigation confirms wrongdoing, we’ll take the appropriate disciplinary or corrective action, regardless of the position of the individuals involved.
POLITICAL AND TRADE ASSOCIATION ACTIVITIES
Participation in political activities, whether done directly or through our involvement with trade associations or other organizations, is important to achieving our business objectives. It is critical that all of our activities in this area rigorously comply with applicable laws, regulations, and our own standards of integrity. For this reason, our essential policy regarding political activities is set forth in our Code of Conduct. Additional details on our implementation and compliance activities in connection with the policy are contained in the Comcast Corporation Statement on Political and Trade Association Activity.
Millions rely on us for timely, accurate information about local, national, and international issues and events. NBCUniversal’s News Standards Unit sets standards for newsgathering and reporting, prepares NBC News policies and guidelines, and holds mandatory training sessions regularly to ensure adherence to the highest levels of ethics and integrity throughout our news organizations.
We also provide training to journalists across NBC News, including MSNBC, CNBC, our owned local television stations, Telemundo, and other program areas. This ensures all of our news content — whether delivered by broadcast, cable, the Internet, mobile, or other devices not yet invented — maintains the highest standards of journalism.
Learn more about our news standards.
Privacy is crucial to our audiences, customers, and employees, and helping to protect it is a responsibility we take seriously. Across Comcast and NBCUniversal, we take measures to meet strict standards of the many national, regional, and local privacy laws that apply to our industry.
We inform customers about our privacy policies and practices through privacy notices. At Comcast, we also publish our privacy policies and practices related to video, high-speed Internet, and voice services on our website. NBCUniversal informs audiences and users of its privacy policies across its digital properties.
We’ve put protections in place to safeguard our Comcast customers from pretexting, hacking, and other attempts at identity theft or unauthorized access to account information. Our globally positioned security team investigates and responds to privacy and security issues, and ensures that our product design and deployment process includes the appropriate privacy and security practices.
To learn more, see our story on keeping our customers' information safe and secure.
Credospeak is an annual employee engagement survey distributed to all Comcast Cable and Comcast headquarters employees. More than 80% of our employees participate year after year, sharing their perspectives on topics such as the company’s leadership, policies, customer service, diversity, and ethics. In addition to providing feedback on nearly 70 questions in 2012, our employees contributed more than 150,000 written responses to open-ended questions. Results from the 2012 survey revealed that Comcast employees feel most positive about the company’s leadership, strategy, and culture of open communication. In addition, Comcast’s overall results exceeded external benchmarks based on survey data from other leading U.S. companies. Our company leaders use feedback from Credospeak to improve our business operations and our relationship with employees.
EVOLUTION OF THE INTERNET AND COMCAST
As consumer use of the Internet continues to evolve, so has Comcast. Four years ago, when we had a static 250-gigabyte (GB) monthly data plan, streaming video and other high-bandwidth activities were not common consumer experiences. As a result, very few customers used more than that amount of data in a month. Over time, however, consumers began streaming more online video, in part due to the widespread adoption of smartphones, tablets, and gaming consoles. In addition, families began to connect numerous devices to the Internet using WiFi and ran them all simultaneously, which started to add up to more data consumption per household. We saw this change in consumer behavior and recognized that we needed to adapt to give our customers a great online experience. As a result, in 2012, we announced that we were replacing our static 250GB data plan with an improved data-management approach that gave our customers more choice and flexibility.
In 2012, we tested two pilot programs. The first, in Nashville, Tennessee, increased our monthly data plan to 300GB for all customers regardless of their Internet speed tier. In addition, we offered customers the ability to purchase additional buckets of data in 50GB increments for an additional $10 each, with no limit on the number of buckets a customer could choose to buy. The second pilot, in Tucson, Arizona, offered different monthly data plans for each of our speed tiers. The lowest-speed tiers started with a 300GB monthly data plan and rose to higher amounts with each successively faster speed tier, up to a 600GB monthly data plan. We also gave customers the option to purchase additional buckets of 50GB for $10 each with no limit.
Both pilots were designed to ensure fair treatment and a consistent, superior experience for all of our high-speed Internet customers. We continue to study customers’ reactions to the two approaches to make sure they are easily understood. We may make periodic adjustments, as needed, based on what we learn from customer feedback, as well as qualitative and quantitative research.
As new technologies emerge, we will continue to work with our customers to understand how their needs and behaviors are changing online. At the same time, we remain committed to an open Internet and have supported the Federal Communications Commission (FCC) Open Internet rules. No matter what, we will continue to innovate, adapt, and bring great new experiences to our customers.
SUPPLIER SOCIAL RESPONSIBILITY
NBCUniversal’s supplier social responsibility (SSR) audit program includes environmental and labor inspection points validating key exposure areas related to involuntary labor, underage labor, wage, working hours, working conditions, emergency preparedness, fire protection, industrial hygiene, personal protective equipment, waste management, and environmental permits. We take a triangulation approach to SSR audits, including employee interviews conducted globally, in-depth documentation review, and on-site inspection.
Our audit scope is applicable for all countries excluding North America, Western Europe, Japan, and Australia. At NBCUniversal, business units contract with licensees who select the factory to produce the product. We emphasize protecting labor, human rights, and environmental practices for all sourced factories that produce NBCUniversal logo or branded products. Our goal is to work with factories closely to build up their capacity for sustainable growth. We work with factory management in taking an active role to improve their labor and environmental performance.