Speak Up
The Unisys Compliance Helpline operates as a toll-free phone line available 24/7/365 where reports can be made in over 100 languages. Reports can also be made via web entry. Anonymous reporting is supported where permitted by law, and all reports are investigated directly by or under the supervision of the Compliance and Ethics Office.
Integrity in all we do
Integrity is at the heart of Unisys, informing every decision, action, and relationship. This commitment is absolute and shapes the objectives of our Ethics and Compliance program. Our high ethical standards guide how Unisys does business with clients and each other, and we hold our suppliers and business partners to the same standards. Maintaining trust with clients, business partners, investors, governments, society, and each other is embedded in our culture.
Unisys Ethics and Compliance program overview
Our Ethics and Compliance program, first implemented in 1987, is designed to identify, assess, and mitigate ethics and compliance risk. We promote a speak-up culture through our Code of Ethics and Business Conduct (“the Code”), policies, and training, and assess ethics and compliance risk using data analytics, risk assessments, investigations, and other compliance initiatives.
We manage compliance risks through our annual risk assessment and internal audit testing. We also identify areas of concern through our associate engagement survey and by monitoring misconduct trends reported to the compliance helpline.
Our culture of trust and integrity depends on associates speaking up when they become aware of, or have concerns about, a potential violation of our Code or the law. Associates may raise concerns through numerous channels, including the compliance helpline, which operates 24/7/365 in multiple languages. While investigations and grievance processes vary by jurisdiction, we are globally committed to conducting fair, impartial investigations and encouraging associates to speak up without fear of retaliation.
All associates are required to complete annual ethics and compliance training, so they understand the importance Unisys places on ethical business conduct and the resources available to support ethical decision-making. Our training and communications campaigns focus on key risk areas and aim for a 98% or higher completion rate for each campaign.
The program continually evolves to address root causes, strengthen controls and processes, and adapt to new regulatory developments. Unisys undergoes numerous annual audits, including internal audit Sarbanes-Oxley testing of the helpline, compliance policies, and entity-level controls, as well as self-audits against the U.S. Department of Justice Guidelines for Effective Corporate Compliance Programs.
The Unisys Code of Ethics and Business Conduct
The Unisys Code reflects our values and culture of integrity, establishing the principles and expectations that guide associate behavior in accordance with our policies and the laws of the countries where we operate. It also points leaders and associates to additional resources that support sound legal and ethical decision-making. Associates who violate the Code are subject to disciplinary action, up to and including termination of employment.
Unisys expects our partners, suppliers, consultants, and contractors to be guided by our Business Partner Code of Conduct.
Speak Up – Reporting concerns and non-retaliation
The Unisys compliance helpline is available to all associates, contractors, and other third parties for guidance on compliance and ethics matters and for reporting suspected misconduct or potential violations of our Code or related policies. It operates via a web portal and toll-free phone line, available 24/7/365, with reports accepted in multiple languages. Anonymous reporting is supported where permitted by law, and all reports are investigated directly by, or under the supervision of, the Ethics and Compliance Office or Associate Relations.
Unisys has zero tolerance for retaliation against those who raise compliance concerns in good faith, and whistleblowers receive all legal protections afforded by applicable law. Any associate who retaliates against a person for raising a compliance concern is likewise subject to disciplinary action, up to and including termination of employment.
The EU Whistleblower Protection Procedure is used by Unisys to manage investigations of whistleblower reports submitted in accordance with EU Directive (EU) 2019/1937 on the Protection of Persons Who Report Breaches of EU Law.
Administration and oversight
Oversight of the Ethics and Compliance program rests with the Audit & Finance Committee of the Board of Directors, consistent with its charter. The Chief Compliance Officer reports quarterly to the Audit & Finance Committee and ad hoc to the full Board as needed and interacts regularly with the Unisys Leadership Team.