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Global Code of Ethics

Frequently Asked Questions - English

   

Table of Contents

 
 

Bribery and Corruption

Q. In order to import certain PPG products into certain countries, a license is required. Is it all right to pay a broker/licensee a fee to obtain the license?
 
A.  If the fee is a contractual or published fee for a service, it should be itemized and included on the invoice to PPG. However, if the broker/licensee asks for an additional fee or payment to be paid to him directly, you should not pay it and report this to your PPG regional or business unit legal counsel.

Charitable Contributions

Q. My customer requested PPG to sponsor a dinner table at their charity event. I also sometimes receive requests from customers to donate PPG products to charitable events in which they are involved. Can I contribute to these charitable activities? A. Donations to legitimate charitable organizations are permitted in certain circumstances. Several factors need to be considered:
  • The charity must meet country and tax requirements for charitable organizations and pass a background check.
  • The mission of the charity and the intended use of the donation should align with PPG’s values.
  • The value of the donation should be reasonable and customary for the type of event.
  • Donations to the same charity should generally not be more frequent than once every 12 months.
  • The customer or a closely related person should not personally benefit from the donation.
It’s a best practice to send a brief memo/letter with the donation that conveys PPG’s understanding of the intended purpose of the donation.
 
Please consult your regional Compliance representative if you have any questions.

Communicating with External Parties

Q. What is PPG’s Social Media Policy? A. Read the policy here

Confidential and Non-public Information

Q. While traveling on business, I needed to print a price list to take with me to a customer meeting. I emailed the price list to my personal email account, and then accessed that email account from a computer in my hotel’s business center to print the price list. Did I do something wrong?                                                     A. You should not have emailed the price list to your personal email account or to the hotel’s email to print. Non-public Information should only be stored on your PPG computer. We have secure procedures for logging onto your PPG account from non-PPG computers that enable you to sign onto your PPG account using a remote access option at the hotel’s business center and print the price list from there.
 
The printed price list is non-public information and must be protected from unauthorized access, accidental loss, and disclosure.  
Q. I share a computer on the production floor with several other employees. We each have a PPG login ID to use, however I saw an employee give their login ID and password to another employee. Should I report this?
 
A. Yes. Employees should never share their login ID or password with anyone else.
Q. I received an email representing a request for customer information from what appeared to be a business partner’s email address. I checked and found that it was not a legitimate email from the business partner. What should I do? Q. You are correct to exercise caution before opening and responding to emails from unknown senders, from odd email addresses, or from a social media address — particularly when the email requests non-public information. This may be a phishing scam. Phishing scams are fraudulent email messages that appear to come from legitimate enterprises (such as a business partner in this case, your internet service provider, or your bank) or somebody with whom you are familiar (such as your company senior leaders or colleagues from your HR or Finance Department).
 
Ask for help from your local IT security team or your supervisor if you have doubts about the validity of an email address. If you have legitimate contacts at the business partner’s office, you may contact them directly to inquire about the request for information.
 

Data Privacy

Q. What is the Confidential Data Handling Policy? A. Read the policy here.
Q. A manager asked me for a list of everyone who participated in an event to thank them.  Is it all right to send a spreadsheet that includes phone numbers, addresses, and emergency contact information?
 
A. No, a spreadsheet that includes Personal Information should not be shared.  Only the minimum amount of information necessary for the manager to do her job should be shared – in this case, names and PPG email addresses.

Gifts, Entertainment, Meals, Trips

Q. In the U.S., what is PPG’s policy for Providing Gifts, Meals, and Entertainment to U.S. Public Sector (Government) Employees? A. Read the policy here.
Q. PPG signed a substantial contract with a vendor, and I will be the vendor’s contact at PPG. The vendor offered to take me to lunch and then offered two tickets for a nationally known recording artist’s concert. The vendor will not be accompanying me to the concert. Can I go to lunch and accept the tickets? A. It’s all right to go to lunch with the vendor, but, if the concert tickets are worth more than nominal value (i.e., more than US $25 or equivalent), you should not accept the concert tickets. It may be perceived that the vendor’s selection was influenced by the reward of a personal favor, or that future decisions will be improperly influenced. You should thank the vendor for offering the tickets, and inform the vendor that it would be against PPG policy to accept them.  
Q. I attended a supplier’s event and won an iPad in a random drawing.Can I keep it?
 
A. It depends. If the drawing was clearly random (not set up in any way to deliberately select you as the winner), you are not in a position to influence new or continued business with the supplier, and your supervisor approves, it is likely acceptable for you to keep the iPad.  Depending on the value of the prize, you will need to consider whether there is any tax liability.
 
If, after considering the above, you keep the prize, before entering into any future business opportunities with this supplier you should consult with your supervisor and regional compliance representative.
 
As always, if you have any questions, consult with your PPG regional compliance representative.
 
Q. My department periodically employs a third party consultant to assist with project work. The consultant has invited a few of us in the department to attend a local sporting event. Can we attend the event with the consultant? A. Several factors need to be considered. Ask yourself:
  • Are you or the others invited in a position to influence whether the consultant continues to be hired for project work?
  • Have you or the others accepted similar event entertainment from the consultant in the last 12 months?
  • What is the value of the tickets?
If a reasonable person would conclude that you might be influenced to award future business to the consultant as a result of the gift, you should not accept the tickets. Please consult your regional Compliance representative if you have any question.
 
Q. My business would like to invite our most important customers to a major local sporting event. We will be attending the event with the customers. Is this a gift that needs to be pre-approved? A. Because you are attending the event with customers, this is considered entertainment, not a gift. Entertainment is not subject to gift pre-approval rules, but entertainment should be approved in advance by your direct supervisor. Check local gift, travel and expense, and purchasing policies and procedures before purchasing tickets.

Insider Trading

Q. A supplier representative at ABC Company, who is my good friend, told me that ABC Company just landed a big contract with PPG. Although an official announcement has not been made, can I purchase shares of ABC Company? A. No. Because ABC Company is a U.S. publicly traded company, this could be considered trading on the basis of material non-public information, which is a violation of PPG policy as well as federal securities laws.

Protecting Company Assets

Q. When I use my corporate credit card for personal purchases (at supermarkets, gas stations, and drug stores) I mark the purchases as ‘personal’ and am not reimbursed for them. Am I allowed to do this? A. No, you should not use the Corporate credit card for personal purposes. PPG policies do not allow it. Expenditures charged to the card must be for business purposes only.
Q. I can claim mileage expense up to US$500 per month. This month, my mileage expense is only US$300. Can I expense US$200 of my personal gasoline expenses as company mileage expenses?    A. No, you cannot expense your personal gasoline expenses as company mileage expenses. According to PPG policy, only actual business expenditures can be claimed and reimbursed.

Trade Compliance

Q. What are the “red flags” for export compliance? A. Certain circumstances (“red flags”) may indicate that an export is destined for an inappropriate end-use, end-user, or destination. Some examples of “red flags” are:
  • A customer or purchasing agent is reluctant to offer end-use information, has little knowledge about the business or product, or is otherwise evasive.
  • The product’s capabilities are incompatible with the customer’s business or country’s capabilities.
  • A customer is offering to pay cash or an excessive price for the product.
  • Routine installation, training, or maintenance is refused.
  • Unusual shipping routes or procedures are requested.
  • Packaging is inconsistent with the method of shipment or ultimate destination.

Working with Governments

Q. The Chinese government has recognized PPG for our history of prompt tax payments. They presented the local PPG facility with an imitation crystal horse memento and a letter of recognition.  Is it all right to keep and display?
 
A. Because this gift is proportionate to the occasion, the gift and letters may be kept and displayed in the PPG facility.
Q. If I meet with an elected or appointed official in my work with PPG, would all communications therein be counted as lobbying? 
 
A. Not necessarily. Lobbying has a broad definition that includes directly communicating lobbying requests with a public official, engaging in research or strategizing to engage those officials, and coordinating with a third-party such as a trade association or another company. Lobbying is strictly regulated; anyone looking to engage in such activity must seek guidance from your regional Government Affairs representative. 
Q. Should I thank a public official for visiting an office or facility location with a gift? A. Generally, a handwritten or emailed letter of appreciation is appropriate to express PPG’s appreciation of a visit. While gifts may be permissible if certain criteria are met, because the rules vary, it is best to avoid any gifts. Seek guidance from your regional Government Affairs representative if you have questions.