CORPORATE We also train our personnel on other corporate governance policies, GOVERNANCE such as our Worldwide Bribery & Anti-Corruption Policy. This policy boils down to: “Don’t o!er any bribe to anybody, anytime, for any reason (and when in doubt, please consult with the General Counsel or the Legal Department).” Additionally, we maintain and enforce an OFAC compliance policy, which allows us to make sure that we don’t participate in transactions with sanctioned countries, legal entities or individuals, such as terrorists or narcotics traffickers. We believe in regular and transparent communication with employees. We encourage Tesla employees to share their feedback openly (and anonymously if they prefer), and the company provides easy methods to do so. We regularly conduct employee surveys to identify strengths and opportunities for improvement. We have a robust action planning process to ensure we proactively address the concerns or feedback. As a result of recent feedback, we have invested additional resources in our performance and leadership training. We also have a whistleblower hotline through which employees can report concerns at any time. The company keeps information reported by employees in confidence, whether through the hotline or another channel. Our policies prohibit retaliatory actions against employees for raising concerns or making complaints. We are committed to maintaining an open and transparent culture where it is safe and acceptable for all employees to raise concerns about policy violations by their manager or colleagues or about the workplace overall. 46
Tesla Impact Report | 2019 Page 45 Page 47