Apple launched a new ethics and compliance website this week, one that seems to be a clearinghouse of its compliance policies and procedures and a public display of the company’s commitment to good conduct — all with a thick helping of Apple’s sleek visual design, too.
You can reach the site at https://www.apple.com/compliance. To find the site from Apple’s home page one does need to scroll down to the bottom, where an “Ethics & Compliance” link is under the About Apple heading, but that’s all the navigation necessary.
What’s on the ethics and compliance site itself? Figure 1, below, shows the main screen. As usual, Apple tries to do more with less and embraces simplicity.
Further down the main page are large icons that emphasize the business conduct policy; corporate compliance efforts; “bringing policy to life,” which seems just a fancy way of saying “training;” and accountability.
For woke consumers curious about good business conduct as they purchase Apple products, the main page of the site does an effective job telegraphing the key messages Apple wants to convey. For compliance officers curious about the details, however, you should explore those tabs on the upper right labeled “training,” “policies,” “third parties,” and “speak up.”
Into the Apple Details
Training. This page of the website mostly talks about how Apple trains its employees and business partners, with a few details about the actual amount of training. For example, now we know that all Apple employees receive two two five hours of compliance training annually, on issues such as privacy, workplace respect, anti-corruption, antitrust, and other matters. Managers get more training depending on their responsibilities.
Speak Up. This page is really just a spiffy way to drive employees to Apple’s internal compliance hotline (managed by Navex Global, apparently), with the obligatory declaration that retaliation against reporters will not be tolerated.
Policies. This is a much more meaty page that compliance professionals will want to study. Apple lists eight categories of ethics and compliance issues, with one or more relevant policies under each category — like, you can download the actual policy Apple uses and study it, if that’s your interest. Figure 2 shows what the page looks like, using the same sparse Apple design.
What are the eight regulatory compliance concerns discussed on this page? They are:
- Business conduct
- Export and sanctions
- Labor, environmental, human rights in the supply chain
- Antitrust and competition
- Channel Member Code of Conduct (that is, the code for resellers and distributors of Apple products
- Human rights
- Public policy advocacy
Third Parties. Same concept as the Policies page above, but with issues more directly related to third parties. This page includes policies about due diligence of third parties, suppliers who are working with Apple on government contracts, and human trafficking (including Apple’s annual report on anti-trafficking efforts, which is a compliance requirement for the U.K. Modern Slavery Act).
The only material notably missing from the ethics & compliance website is any mention of who Apple’s chief compliance officer actually is. That person is Kyle Andeer, who’s held the role since 2018 and is also vice president of corporate law at Apple.
Does a company need to call out its chief compliance officer by name? No. But if the business is going to put so much emphasis on ethics and compliance, matching a human person to the compliance program wouldn’t hurt. (Then again, maybe Apple doesn’t want people to notice that for all its attention to ethics and compliance, Andeer isn’t a member of the leadership team.)
Anyway, if you’re looking for examples of how to communicate your firm’s ethics and compliance expectations in a crisp, easily understood format — Apple’s website is worth a look. More companies should devote the time, effort, and elegance to something so important.