Integrity has been central to RR Donnelley’s business
since its founding more than 140 years ago. Over
a decade before the enactment of Sarbanes-Oxley,
RR Donnelley published in booklet form its Now in its ninth printing,
this code describes long-standing principles of conduct
RR Donnelley has followed to ensure that its business
is conducted with integrity and in compliance with the
law. Every employee worldwide is expected to follow
this code.
 can be found on our public website, translated in nine
different languages. This code is the
centerpiece of RR Donnelley’s Ethics
and Compliance Program.
Our Ethics and Compliance Program is intended to
promote the company’s culture of integrity and prevent,
detect, and correct illegal or unethical conduct. The
Corporate Responsibility and Governance Committee of
the Board of Directors oversees the Program’s overall
design and structure. The Program is implemented
through a Chief Compliance Officer, an Ethics and
Compliance Committee chaired by the Chief
Compliance Officer, and designated employees, known
as Compliance Leaders, who execute different components
of the Program. This structure is designed to
provide senior-level oversight and monitoring of
RR Donnelley’s compliance efforts and performance.
An important function of the Program is to establish
standards for employee conduct, such as the . In addition to this general
code, the Program has established numerous other
policies designed to promote compliance with the law
in areas ranging from antitrust to insider trading.
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To ensure that our policies are followed, the Program
directs relevant training and communication. The
training is targeted to help employees understand and
follow the legal requirements applicable to their
specific job functions. For example, sales employees
take antitrust training courses that teach them how to
recognize and avoid anticompetitive conduct when
selling RR Donnelley’s products and services.
Through these and other components of RR Donnelley’s
Ethics and Compliance Program, RR Donnelley
continues to enjoy a strong reputation for integrity and
compliance with the law.
A creed signed by T.E. and Reuben Donnelley in 1919
expressed that “it has always been the aim of the officers
of RR Donnelley & Sons Company to act honestly
and fairly with both the firm’s employees and its customers.”
A part of this creed declared that the officers
of the company were ready and willing to hear from
any employee about any issue or suggestion they might
have. They further pledged to give such complaints
and suggestions careful and honest consideration.
This was the beginning of what is today known as
RR Donnelley’s Open Door Policy. RR Donnelley’s
culture of integrity is reinforced through a culture of
openness.
Under RR Donnelley’s Open Door policy, any employee
may report any workplace concern, including any concerns
relating to unethical and unlawful behavior, to
any level of management without fear of retaliation.
Additionally, an exists for employees who
choose to report such matters by phone or the Internet,
anonymously if they choose. All reports are taken seriously
and, when appropriate, corrective action is taken.
Through our Ethics and Compliance Program and Open
Door policy, we give life to the and embed these principles into
the daily decisions and actions of our employees. |
“Integrity is what we expect from all of our employees all the time. There is
no room for exception or compromise.”