Philip Morris USA's Compliance & Integrity Program is part of an enterprise-wide
Altria Group Program. With support from this program, PM USA's Chief Compliance Officer:
- oversees PM USA's Compliance & Integrity Program and its adherence to Altria Group's Standards for Compliance & Integrity Programs;
- leads PM USA's compliance risk management process;
- develops an annual PM USA Compliance & Integrity Plan, which documents and monitors progress against our compliance initiatives;
- monitors and evaluates compliance priorities established in the Compliance & Integrity Plan and promotes continuous improvement;
- oversees and coordinates compliance allegations and investigations at PM USA;
- serves as a resource, along with other mechanisms, for employees to report potential non-compliance;
- reviews conflict of interest disclosures by PM USA employees;
- regularly communicates to PM USA employees regarding compliance and integrity;
- represents PM USA on the Altria Compliance Leadership Team; and
- develops a compliance training plan.
To support our Compliance & Integrity Program at the functional level, PM USA participates on the Compliance Leadership Team (CLT) comprised of representatives from Altria Group companies. CLT members share best practices and implement appropriate compliance processes within their respective company's functions.
Our Compliance & Integrity Program puts compliance processes in place to help employees meet their obligations to comply with applicable laws, regulations and policies. Ultimately, however, it is up to every employee to take accountability for helping PM USA live up to its commitment to act with integrity.
Our employees' compliance obligations include:
- knowing and complying with the company policies relevant to their job;
- speaking up by asking compliance-related questions and reporting potential issues of non-compliance;
- completing their compliance training;
- disclosing potential conflicts of interest; and
- always acting with integrity.
The following resources have been developed to assist PM USA employees with satisfying these obligations:
Altria Code of Conduct for Compliance & Integrity - The
Code provides an overview of the laws and policies that govern the activities within Altria Group and its companies, and reflects a commitment to protect those who seek advice, raise concerns or report misconduct.
Library of Principles and Policies - PM USA developed a comprehensive online library of company policies. The Library includes examples of things that PM USA employees should consider when making work-related decisions.
Communications - PM USA implements a Compliance & Integrity Communication Plan that includes internal website material, interactive programs to generate compliance conversations, and printed materials.
Training - PM USA works with the Compliance Institute, an internal compliance training organization for the Altria Group companies, to develop a strategic compliance training plan. This plan includes compliance training to educate PM USA employees on their compliance requirements and to increase overall awareness of selected compliance topics. These training courses are delivered through classroom and web-based formats, and the training is tracked.
Records Management - All PM USA employees must properly manage company information in accordance with business and legal requirements. The Records Management Program has been developed to assist PM USA employees with these requirements by providing electronic tools, communications and training.
Conflict of Interest Disclosure Process - PM USA employees participate in a variety of activities within and outside the company. We understand that conflicts of interest may sometimes arise when an employee's personal, social, financial or political activities or relationships have the potential to interfere with his or her loyalty to PM USA. We developed the Conflict of Interest Disclosure Process, which allows employees to disclose any potential conflicts, and receive proper guidance on how to avoid conflicts and, if necessary, advice on whether to disengage from a real or potential conflict of interest.
Raising Compliance-Related Concerns - It is critical that employees understand the importance of asking compliance-related questions and reporting potential issues of non-compliance. We have a variety of resources available for employees to do so, including: the Compliance & Integrity Office Line, the Compliance & Integrity Mailbox, Law, Human Resources or Compliance & Integrity support, our Chief Compliance Officer and the Altria Group Chief Compliance Officer. Employees are encouraged to have face-to-face dialogue, but they also have the option to report anonymously through the Integrity HelpLine. The HelpLine is managed by an independent third-party vendor and is available 24 hours a day, seven days a week. PM USA will not tolerate retaliation by management or co-workers against anyone who in good faith reports an actual or potential non-compliance concern.
