Ethics and compliance

We believe the first requirement of good global citizenship is integrity. It is essential to earning the confidence and support of our employees, investors, customers and other stakeholders around the world.

Our integrity depends on being open, honest and direct in all our dealings. We work to create a culture of integrity built on trust, respect and dignity for all. This is as true today as it was when HP was founded in 1939. We maintain our integrity by adhering to global laws and regulations, as well as HP’s internal standards, policies and processes, while pursuing our business strategies and objectives.

In 2007, we took immediate action to regain our standing following HP’s investigation in 2006 into leaks of confidential information from the board of directors.

• We hired a chief ethics and compliance officer, who reports directly to the general counsel and to the board’s Audit Committee on HP’s investigative practices and ethics and compliance program.
• The board of directors and members of senior management received training on handling conflicts of interest, hiring independent counsel and conducting investigations.
• We expanded and strengthened our ethics and compliance training program and adopted a new code of conduct and guidelines for external investigative firms.

We have confidence in the renewed strength of our governance. More than merely protecting HP’s reputation, our goal is to be a recognized leader in ethics and compliance. We know that “ethics” and “compliance” are not the same, and recognize that while a particular course of action may be within the law, that does not automatically mean it is the right thing to do. HP’s shared values and objectives remain the foundation for building and sustaining a strong culture of integrity and accountability. We expect that all employees at all levels understand our company’s values and demonstrate them through their behavior every day.

It requires constant effort and the utmost diligence to maintain a consistent ethical culture in a global company. The constant stream of new employees joining HP presents an ongoing challenge, and we must consider many different legal requirements as well as varying cultural and societal norms in protecting our integrity. The Approach page describes the progress we made in 2007 in developing a model ethics and compliance program.