In February 2008, the board approved an updated version of our comprehensive Code
of Business Conduct and Ethics (the Code), which governs our business behavior
and ethical conduct and applies to each member of the board and to every associate
in every country in which Avon does business. The Code describes Avon’s policies
and practices, which, collectively, are intended to promote ethical and lawful behavior
and deter wrongdoing and improper conduct. For instance, the Code’s policies address
compliance with regulations in all countries in which we operate; fair dealing;
conflicts of interest; improper payments and bribery; insider trading; equal opportunity
and nondiscrimination; and safety and health. The Code also provides information
about how to ask the right questions and appropriately report any possible noncompliance.
We have published a handbook of the Code for of our associates, which has been translated
into in ten languages.
Avon continues to provide ethics training on the Code for associates worldwide.
Our training is designed to enhance associate awareness and understanding of the
Code and to further promote lawful and ethical associate conduct and deter improper
conduct. Because our associates are extensions of our company, our expectations
for associate behavior apply not only in formal business conduct but also in personal
interactions. Today, the ethics course is offered in a convenient, online format
to every online associate, and our managers present the materials to their off-line
staff in face-to-face meetings, with the assistance of a detailed training manual.
Every associate is expected to participate in the ethics course and to fully understand
the Code. Avon also utilizes a periodic survey of associates, including its executive
officers, which asks specific questions regarding compliance with our Code, and
requires certification of compliance with the Code.
All Avon associates are required to report any violation of the Code. They are encouraged
to speak to their managers and/or report any possible violation directly and confidentially
to the Avon compliance committee—which consists of senior financial, legal, and
human resources management—via the compliance telephone or email hotline. It is
Avon policy that failure to report a violation is itself a violation of the Code.
Avon will not tolerate any retaliation whatsoever by any director, officer, or other
associate, or by any outside vendor or contractor, for any report provided in good
faith. Under the Code, any associate who commits a violation will be subject to
disciplinary action, up to and including dismissal.