Our compliance program fosters a culture of ethics and helps us respond to changing needs in the environment where we operate. We establish internal controls to ensure compliance with applicable laws and regulations as well as our company policies and contracts. Arthur R. Block, Executive Vice President, General Counsel, and Secretary of Comcast, is a “high-level person” within the meaning of the United States Sentencing Guidelines and has overall responsibility for compliance. Jennifer Heller, our Chief Compliance Officer, is responsible for the program’s day-to-day operations. Arthur and Jennifer report regularly on the compliance program to our Board of Directors or appropriate committees of our Board. For more information, click here.
We 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 employees speak 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. For more information, click here.
Political and trade association activities
Participation in political activities, whether directly or through our involvement with trade associations or other organizations, is important to achieving our business objectives. All of our activities in this area must rigorously comply with applicable laws, regulations, and our own standards of integrity. We spell out our essential policy regarding political activities in our Code of Conduct. Additional details on our implementation and compliance activities are in the Comcast Corporation Statement on Political and Trade Association Activity.
Privacy is crucial to our customers, audiences, and employees. At Comcast NBCUniversal, we work hard to protect people’s privacy by implementing internal practices and complying with all applicable laws. This includes building products and services with privacy in mind, delivering them securely, and reviewing our design and delivery to improve them over time.
We inform people about how we use their information, give them choices to control many of those uses, and make product, privacy, security, and other support information available to them.
And to help fulfill our responsibilities in the larger discussion around individual privacy, we publish transparency reports to make clear how we handle government requests for information. Comcast issued its first transparency report in March 2014, and we release a new report every six months.
To read our most recent report, click here.
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, wages, 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 except Japan, Australia, and those in North America and Western Europe. At NBCUniversal, business units contract with licensees that 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 closely with factories to build up their capacity for sustainable growth. We work with factory management to improve their labor and environmental performance.