Ethics

The Ethics Compliance Group oversees Sysco’s ethics and compliance program, which is driven by Sysco’s commitment to ethical conduct, honesty, integrity, and fairness in all business affairs. We inform and educate our associates and others who conduct business on our behalf about the legal requirements and behaviors we expect in order to successfully drive our Vision of being our customers’ most valued and trusted business partner.

Our commitment to ethical and compliant behavior is expressed through multiple means, including our Employee Code of Conduct (Employee COC) which sets expectations for our associates to deliver excellence with integrity, be accountable for their actions, and to report actual or suspected violations. The Employee COC applies to all associates in every operating company, subsidiary, division and all affiliated companies. In addition, we expect and encourage our contractors and their employees to act in a way that is consistent with our Employee COC and we take appropriate actions where we believe they have not met our expectations or their contractual obligations.

We have established separate codes of conduct for our Board of Directors as well as for our suppliers (Supplier COC)

Major features of our ethics and compliance program include:

  • Oversight by our Board of Directors through its Corporate Governance and Nominating Committee;
  • An Ethics Advisory Board, which champions Sysco’s culture of compliance of ethics and compliance by ensuring that it is the foundation of the company’s strategy, goals, and objectives;
  • A Compliance Council, which consists of senior management from the company’s functions. Members are apprised of compliance related matters and provide input and recommendations to compliance priorities, policies, and decisions;
  • Written policies and supporting documentation such as the Employee COC and our global corporate compliance policies;
  • Annual training and education on our ethics and compliance program, its requirements, and how to apply the code’s principles.Targeted antitrust and anticorruption training is provided to associates whose job responsibilities may be impacted by related regulations;
  • A confidential helpline, AlertLine, through which anyone, internal or external to Sysco, can report suspected or actual misconduct without fear of retaliation. Callers may remain anonymous unless they are from countries where anonymity is discouraged or not permitted by law;
  • Routine monitoring of our compliance risks through normal processes embedded in our operations and audits that use a unified approach across our business operations;
  • Timely and appropriate investigations into reported concerns and potential compliance violations;
  • Operating company reviews by Sysco's Internal Audit Department, including confirmation of Code of Conduct receipt and ethics training for new hires and annually for incumbents.

SUPPLIER CODE OF CONDUCT

We explicitly require that our suppliers adhere to all applicable laws and regulations to provide and recognize a basic level of human rights for workers within their own supply chains.

As a condition of doing business with Sysco, suppliers are informed they may be audited on the Supplier COC by Sysco or independent agencies at any time, with or without advance notice. Suppliers must allow unrestricted access to facilities and relevant records for the purpose of monitoring compliance with the Supplier COC.

If a supplier violates the Supplier COC, either generally or with respect to a particular supplier facility, we may either terminate its business relationship with Sysco or require the affected facility to implement a corrective action plan. Read more about how we monitor suppliers here.

REPORTING CONCERNS

We encourage associates and third parties to report concerns to us about suspected unethical behavior promptly. They can do this through any of the vehicles below.

  • The AlertLine Reporting System: Partnering with a third-party vendor, Sysco utilizes the AlertLine as a formal, confidential communication reporting channel for associates and members of the public. The system includes online web reporting and a global, 24-hour, toll-free hotline with translators available. AlertLine is our primary formal mechanism for reporting ethical concerns. Its case management system is used to track and document all reports, regardless of whether or not the case is initiated via AlertLine.
  • Sysco Speaks: This engagement survey includes opportunities for associates to communicate whether or not they feel comfortable reporting unethical practices without fear of retaliation and whether or not they feel senior leadership would act on reports of violations. Read more about the Sysco Speaks Survey here.
  • Corporate Governance: Associates, investors and the public may contact the Board of Directors. Concerns may be communicated via mail in care of the Office of the Corporate Secretary or the Audit Committee of the Board and by phone or web messages through the AlertLine. Corporate Governance and Contact the Board communication is provided via links on Sysco.com.