Welcome to the · Welcome to the Challenge! AGDC ‐Code Challenge Debrief ‐For Internal Use Only ‐2012 1 Our Story AGDC ‐Code Challenge Debrief ‐For Internal Use Only ‐2012

1

Welcome to the Challenge!

AGDC ‐ Code Challenge Debrief ‐ For Internal Use Only ‐ 2012 1

Our Story


Last summer, the AGDC Compliance Champions embarked on an exciting journey to our nation’s capital, the home of the United States Constitution. Similar to how the

Constitution outlines the principles that govern our country, our Code provides us guidance on how we should approach our work.

2

Our Story


Working in teams, the Champions explored the National Mall to decipher clues, answer questions, and learn how to use the Code to make sound decisions.

Our cameras were there to capture the adventures of one of the five teams.

Now it’s your turn to join the adventure

Your Team

• Working in units, you’ll compete in the Code Challenge

How It Works

• Follow clues, decipher puzzles and answer Code of Conduct questions

How to Win

• Winning is based on speed and accuracy

• Email your team’s time to the DM

You’ll Need

• One computer to play the disc

• One computer to access the e‐Code


Let’s take a closer look…

3

Code Challenge Preview


Are you ready for the Challenge?

Divide into Teams

• Units should position themselves around the room to reduce audio from other teams

• The Challenge is approximately an hour

Insert the Disc

• Place the Challenge disc into the CD ROM drive

• Do not select “The Code Challenge” chapter until directed

Get Connected

• Test online connectivity prior to starting the Challenge

• You will need access to the Altria intranet –and the e‐Code of Conduct


4

Begin the Code Challenge


DebriefGroup Discussion


5

Why do we have a Code of Conduct?

Our Code is the cornerstone of our Compliance Program

It helps us run our businesses responsibly and comply with all applicable laws so we can enjoy success with

integrity

By committing to living by our Code, we are

creating a company we can all be proud to

work for


Let’s discuss the decisions your team made in the Challenge

Code Challenge Decisions


What did your team decide?

Why did your team make this decision?

How does this apply to our everyday work?

What direction does

the Code provide?

6

Code Challenge Decisions

Our Code is a commitment to do what is right. Each employee must uphold this commitment.

Our Code is not a prescription, but

rather a framework for operating with

integrity.

Whenever we’re confronted with a situation where the proper course of action is not clear, we should ask ourselves:

• Is it legal?

• Does it follow company policy?

• Is it the right thing to do?

• How would it look to those inside and outside the company?

Accepting the stamp from another team is a shortcut that ultimately

resulted in lack of productivity and cost the blue team precious time in the

Challenge.


Let’s discuss the topics covered in the Challenge

Code Topics for Discussion

Call FalsificationGiving and Receiving Gifts

Conflict of Interest

Speaking Up

Weapons in the Workplace

Company Vehicles

Social Media


7

Financial Guidance

• Report business information that is complete, accurate and timely

• Never deliberately make a false or misleading entry in a report or record, or encourage or facilitate someone else to do so – this includes inaccurately recording call coverage


Call Falsification

Discounts Travel expenses Loans Cash

Favorable terms on any product or service

Services Prizes Transportation

Use of vehicles or vacation facilities

Stocks or other securities

Home improvements

Tickets Gift certificates


What is considered a gift?

Gifts and entertainment are anything of value. For example:

Giving and Receiving Gifts

8

Workplace Conduct

• While business gifts and entertainment can build goodwill, they can also make the recipient biased (or give the appearance of bias)

• Gifts and entertainment can create actual or apparent conflicts of interest, so we must use good judgment when giving or receiving them


Giving and Receiving Gifts

A conflict of interest generally arises when a personal, financial or other activity or relationship affects our ability to make loyal and objective business decisions on behalf of our companies.


• We must avoid conflicts of interest, or even the appearance of a conflict, by making unbiased decisions.

• If you have a potential conflict of interest, you must disclose the situation in writing to your company's compliance officer, the Altria Group Chief Compliance Officer or the Compliance & Integrity department.

• Having a conflict is not necessarily a violation of our Code, but failing to disclose it is.

Conflict of Interest

9

Speaking Up

Do you know how to speak up?

* Source: Compliance & Integrity department as of 9/27/11


• Start with your manager• Other options include:

• Your management (e.g., DM, SSD, RVP)• Your company's compliance officer• The Compliance & Integrity, HR or Law departments• The Altria Group Chief Compliance Officer• The Integrity HelpLine

35% of calls from field sales were to the wrong line*

Do you know the difference between the Integrity Helpline and the Trade Compliance Hotline?

Speaking Up

The purpose of the Trade Compliance Hotline is to address reports of potential non‐compliance as they relate to resellers of PMUSA, USSTB or JMC products, both

retailers and wholesalers

The purpose of the Altria Integrity HelpLine is to report allegations of non‐compliance as they relate to an Altria company, employee or

organization


* Source: Compliance & Integrity department as of 9/27/11

Helpline Hours of Operation Examples

Trade ComplianceHotline1‐866‐364‐5544

8:30a – 5:15p ESTMonday through Friday

Remote cigarette sales Contraband tobacco sales Coupon fraud Foot traffic in a store does not seem to substantiate the store’s volume Suspicious activity

Altria Integrity HelpLine1‐877‐781‐9324

24 hours per day7 days per week

Potential violations of law, policy or the Code of Conduct Bribery Conflicts of Interest Harassment or discrimination Improper use of company resources Inappropriate gifts or entertainment On the job drug or alcohol abuse Theft or fraud

To help guide you, below are examples of issues addressed by each helpline:

10

Speak up if:

• You are unsure about the proper course of action and need advice

• You believe that misconduct has taken place or is about to take place

• You believe that you may have been involved in misconduct


Speaking Up

We all have an obligation to speak up.It is the right thing to do and allows our companies to quickly address

potential issues.

What is a company weapon?


Firearms Explosives Clubs

Electronic control devices

Items designed or intended to inflict

bodily harm


The term "weapons" includes, but is not limited to:

11

It depends…

– Weapons are never allowed in the workplace without prior authorization

– Possession or transportation of weapons in a Company Vehicle during working hours, subject to applicable federal, state or local laws, is prohibited

– BUT ‐ the lawful, off‐Company premises possession or transportation of unloaded, secured firearms used for recreational shooting or hunting during non‐work hours is permitted


Is it OK to have a weapon in your Company car?


Did you know the cost of accidents per month for Field Sales is $147,000 dollars?


What does the Code say?

* Source: ALCS Fleet Dept. as of 2011: Per month average includes bent metal and rentals

Company Vehicles

12

Health, Safety and Security*

• Accidents involving a Company Vehicle must be reported immediately by contacting the vehicle leasing company

• Failure to report an Accident will result in disciplinary action up to and including termination of employment

• Employees who experience an Accident while operating a Company Vehicle are required to undergo post‐Accident substance abuse testing (unless such testing is prohibited by law in the location where the Accident occurred) no later than 24 hours after the incident


Company Vehicle and Substance Abuse Policies

Company Vehicles

*Source: Key point are derived from the Company Vehicle and Substance Abuse Policies which are linked to the Health, Safety and Security Principle within the Code

Did you know…Did you know…

Facebook has more than 500 million active users. The average Facebook user creates 90 pieces of new content each month.

Twitter has 175 million registered users and 200 million unique visitors per month

YouTube exceeds 2 billion views per day. More videos are uploaded to YouTube in 60 days than all three major U.S. networks created in

60 years.

LinkedIn has over 100 million users and is growing exponentially.


* Source: Altria and its Companies Adopt New Social Media Policy • Published: January 18, 2011

Social Media

13

Social Media

• The Social Media Policy does not prohibit Personal Use of Social Media

• But ‐ Use caution and good judgment when using social media because your communications could reach audiences (sometimes unintended audiences) including co‐workers and business contacts

• Remember, a variety of Company policies could apply even in the context of personal use of social media


Social Media Policy

Social Media

What about taking and posting pictures?What about taking and posting pictures?

Get permission to take pictures at meetings or Company events from your Director

Never post confidential information

Never use company logos, trademarks, product or facility images on social media

Don’t post pictures with POS or product in them (even in the background)


Social Media

14

Code Challenge

• The eCode is a great place to go for guidance

• It is searchable and contains links to related policies and other compliance guidance

• If you have any suggestions on ways to improve the eCode, please complete the survey which is on the eCode home page


Thank you

It is up to all of us to pursue our Mission and strategies by fully adhering to our Values and this Code of Conduct.

This includes thoroughly thinking through our decisions and actions and basing them on the solid foundation of our Values and commitment to compliance.

Of course, no compliance program is perfect.


In corporations as large and complex as ours, there will be employees who run afoul of the rules, often unintentionally.

We are all accountable for upholding the principles in our Code. It applies equally to all of us, regardless of position, and will be enforced fairly across our company. Take pride in your conduct and never compromise your integrity.

Thank you for your continued commitment to our Mission, Values and Code of Conduct.

Mike Szymanczyk, Chairman and CEO, Altria Group Inc.

Source: Altria Code of Conduct Message from the Chairman

15

Congratulations to the Winning Unit!!


Reminder…

At the end of the Challenge be sure to take a screen shot of your team’s time. The screen shot should be sent to your District Manager. The DMs will turn the times in to your Region Compliance

Champion.

We appreciate your commitment to enhancing the culture of responsibility at

AGDC and look forward to everyone completing the Challenge by

April 30, 2012.


Welcome to the · Welcome to the Challenge! AGDC ‐Code Challenge Debrief ‐For Internal Use Only ‐2012 1 Our Story AGDC ‐Code Challenge Debrief ‐For Internal Use Only ‐2012

Documents