Our reputation for integrity is one of our most important assets. We hold ourselves to standards that not only meet those required by the laws and regulations that apply to us, but also to our principles, which are rooted in exceeding our clients’ expectations.
Our Code of Business Conduct and Ethics sets out basic principles to guide employee conduct. The code is supported by employee conduct policies and programs and reinforced through employee training.
We have zero tolerance in relation to illegal or unethical conduct and this is articulated in our relevant policies, including policies on conflicts of interest, gifts and entertainment, money laundering and counter terrorism, fraud, sanctions, outside activities, political contributions, and bribery and corruption. Any employee who violates the requirements of the Code of Business Conduct and Ethics, or many of our other policies, is subject to disciplinary action.
BlackRock expects the same high standards of those who represent us and we conduct appropriate due diligence on our business partners according to the risks they present, including corruption risk.
The trust our clients place in us must be earned every day.
Our Anti-Bribery and Corruption Policy explicitly prohibits any transaction, including facilitation payments, which could constitute a bribe or a corrupt payment to or from a public official or body, or a private entity or individual. Our policy applies to our employees and to those who represent us, including any business partners who operate on our behalf. We consider the anti-bribery and corruption policies of potential new business partners as we conduct our due diligence.
We seek to assess and mitigate our exposure – and our clients’ exposure – to corruption risk. We do this through assessing the risks associated with our activities and by putting in place governance and oversight in relation to higher risk transactions or relationships. Any potential violations of our policies are investigated and reported to relevant governance committees. See our latest proxy statement to learn about the role of our Board of Directors in the oversight of risk management.