We clearly define the ethical and compliance expectations to which we hold ourselves and the third parties with whom we work, and we back up these expectations with governance and management systems to ensure we deliver on them.
Our Compliance program is led by our Vice President, Associate General Counsel & Global Chief Compliance Officer, who reports to PMI’s Senior Vice President & General Counsel and, periodically, to the Audit Committee of the Board of Directors.
PMI’s Code of Conduct sets clear standards and expectations and is closely aligned with our business transformation strategy and industry best practices. Its mandatory provisions apply to all PMI employees, officers, and directors. Key risk areas addressed in this document include, but are not limited to, anti-bribery and anti-corruption, anti-competitive practices, conflicts of interest, information protection security and data privacy, responsible marketing and sales, scientific integrity, supply chain responsibility, and workplace integrity, among others. Internal PMI policies provide more specific guidance on these and other topics.
The PMI Code of Conduct is reviewed and updated annually.
Integrity isn’t just a value we aspire to—it’s the foundation of how we conduct business every day. Our robust ethics and compliance framework empowers our employees to make the right decisions, while our continuous focus on training and transparent communication ensures we maintain the highest standards across our global operations. Building trust through ethical business practices isn’t just about following rules—it’s about creating sustainable value for our shareholders, stakeholders, and society.
Employee communication and training
At PMI, we use training and communication to help employees understand the compliance-related standards and rules that are relevant to their roles and how to apply them in their daily work.In 2024, we continued implementing our global Code of Conduct annual certification process. To date, 98 percent of targeted employees, including 100 percent of senior leaders, have completed the 2024 PMI Code of Conduct certification.1
The Compliance team launched a series of six e-learning courses (available in 31 languages) in 2024. Approximately 40,000 employees received training in the following key compliance risk areas: Anti-corruption, Code of Conduct (which is an annual requirement), conflicts of interest, insider trading, non-discrimination and anti-harassment (including sexual harassment, which is an annual requirement), and privacy.
Regional and local compliance officers supplemented these e-learning courses with in-person training sessions to address compliance risk topics specific to their respective region(s) and market(s). Overall, employees and third parties completed a total of over 440,000 Compliance training courses in 2024 (2023: over 500,000).
Also, in 2024, we continued to enhance and regularly update our Compliance intranet site, including publishing information on relevant compliance topics for our employees.
1 For the purposes of the 2024 PMI Code of Conduct Annual Certification, “senior leaders” are defined as employees at a salary grade of 17 and above.
Evaluating our compliance culture
We evaluate our compliance culture periodically, including, for example, via a global online survey to understand employee experiences and attitudes related to ethical business conduct. For the past 15 years, PMI has conducted this type of global employee survey every two to three years, including, most recently, in 2024.
In addition, from time to time, we work with external advisers and consultants to assess elements of our compliance program.
Speaking up
At PMI, individuals may ask questions, raise concerns, or report instances of observed or suspected misconduct by contacting any of the following:
- The individual’s supervisor, department head, or affiliate or function leadership
- Compliance key contacts (e.g., Regional and Local Compliance Officers)
- PMI Global Compliance confidential email address
- PMI Compliance Help Line (online or by telephone), which is a third-party-operated reporting channel available 24 hours a day, seven days a week, in all languages spoken at PMI. Individuals may use the Compliance Help Line anonymously, subject to local laws and regulations
PMI has also implemented a Global Speak Up Policy, the principles of which are reinforced by the PMI Code of Conduct and all PMI compliance policies.
There is a robust speak up culture at PMI. Most employees who speak up do so directly with the Compliance department and voluntarily disclose their identity when doing so. Specifically, in 2024, 23 percent of the reports received by Compliance were submitted anonymously (2023: 19 percent).
The Compliance team regularly communicates to employees about PMI’s speak up program. For example, the Compliance team publishes quarterly statistics about speak up reports, compliance violations, and disciplinary actions, and shares with employees anonymized real-life examples of misconduct and advisory guidance.
Compliance investigations
At PMI, we take all reports received through our Compliance Speak Up channels seriously and are committed to following up objectively and in a timely manner.
We investigate all reports that raise compliance concerns, and we involve other functions or line management as warranted. We implement corrective measures to address investigation findings and calibrate disciplinary actions against past outcomes to keep the process fair. When investigating suspected compliance violations, trained personnel adhere to PMI Investigations Standards, which are designed to ensure an equitable and respectful process. We have also implemented a targeted Retaliation Check program to detect, remedy, and prevent retaliation against people who speak up, as well as those involved in investigations.
We received 1,444 reports through Compliance Speak Up channels in 2024 (2023: 1,258). Around 37 percent of the matters that were closed in 2024 were investigated because they involved at least one compliance allegation. The remaining 63 percent were resolved through Compliance advisory services or referred to line management or appropriate departments, such as our People & Culture teams, for further action.
In 2024, we investigated and closed 541 reports that involved at least one compliance allegation (2023: 591). At least one violation was substantiated in 53 percent of these cases (2023: 55 percent), with “workplace integrity” accounting for 27 percent of substantiated violations (2023: 32 percent); “theft and fraud” accounting for 21 percent of substantiated violations (2023: 18 percent); and substantiated violations related to speaking up (such as failure to speak up or obstructing an investigation) accounting for 16 percent (2023: 18 percent).
The appropriate parties implemented corrective measures and disciplinary sanctions following these investigations. Specifically, in 2024, termination of employment accounted for 43 percent of the disciplinary actions arising from these cases, while suspension accounted for 4 percent, written warnings for 25 percent, and verbal warnings or counseling for the remaining 28 percent.
Preventing bribery and corruption
Our policy is clear: we do not bribe anyone, anywhere, for any reason. We recognize that our refusal to participate in corrupt activities may make conducting business more difficult in some markets, but bribery is unacceptable at PMI.Our Global Anti-Corruption Policy is available on our external-facing website, PMI.com. This policy, together with additional Standards, sets specific principles, rules, and review-and-approval procedures for providing gifts, travel, and hospitality, providing contributions, engaging business intermediaries, hiring government officials, and conducting due diligence in M&A transactions.
We publicly disclose on PMI.com the political contributions we make, and we adhere to lobbying regulations
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Read moreThis online content about our Integrated Report should be read in conjunction with PMI’s Integrated Report 2024. This report includes metrics that are subject to uncertainties due to inherent limitations in the nature and methods for data collection and measurement. The precision of different collection and measurement techniques may also vary. This report includes data or information obtained from external sources or third parties. Unless otherwise indicated, the data contained herein cover our operations worldwide for the full calendar year 2024 or reflect the status as of December 31, 2024. Where not specified, data comes from PMI financials, nonfinancials, or estimates.
Unless explicitly stated, the data, information, and aspirations in this report do not incorporate PMI’s wellness and healthcare business, Aspeya. Regarding the Swedish Match acquisition, completed late 2022, unless otherwise indicated, this report includes information pertaining to its sustainability performance. Please also refer to "This report at a glance" on page 2 of the PMI’s Integrated Report 2024 for more information. Aspirational targets and goals do not constitute financial projections, and achievement of future results is subject to risks, uncertainties and inaccurate assumptions, as outlined in our forward-looking and cautionary statements on page 206. In PMI’s Integrated Report 2024 and in related communications, the terms “materiality,” “material,” and similar terms are defined in the referenced sustainability standards and are not meant to correspond to the concept of materiality under the U.S. securities laws and/or disclosures required by the U.S. Securities and Exchange Commission.