Business Integrity and Ethics

WD is committed to the highest standards of integrity in its business practices. Integrity is one of our core values because we believe it is an important component in our success.

Global Code of Conduct For years, WD has operated under a Global Code of Conduct which informs all employees of their legal and ethical obligations to the Company, its employees, customers, competitors and suppliers, taking into account varying practices due to cultural differences throughout the world. The standards set forth in the Global Code of Conduct are supported by more detailed Company policies and procedures, which are issued in various geographic regions to supplement or implement those standards. These policies and procedures provide clear, specific directions concerning many of the business practices and behaviors discussed in the Code.

A copy of the Global Code of Conduct in the appropriate language is given, or is available online, to all of our employees. In addition, new employees are given a copy of the Code of Conduct on their first day of employment. All employees are informed that they are expected to comply with the provisions of the Code of Conduct and that failure to do so is regarded as misconduct that can result in disciplinary action.

Each year, senior members of management and several hundred key designated employees worldwide are required to complete an online questionnaire certifying that they have complied with the provisions of the Global Code of Conduct. This certification process is required by the Audit Committee and is managed by the Chief Compliance Officer.

A copy of the Global Code of Conduct can be accessed by clicking here.

Code of Business Ethics Our Board of Directors of Western Digital Corporation has also adopted a Code of Business Ethics whose goals are to:

  • promote honest and ethical conduct, including the ethical handling of conflicts of interest;
  • promote full, fair, accurate, timely and understandable disclosure in Company reports;
  • promote compliance with applicable laws and governmental rules and regulations;
  • promote prompt internal reporting of violations of this Code;
  • ensure the protection of the Company’s legitimate business interests, including corporate opportunities, assets and confidential information; and
  • deter wrongdoing.

The Code provides a framework for ethical business conduct and is not intended to establish rules governing every possible instance that could arise. The Code sets forth general legal and ethical principles, and directors, officers and employees must use good judgment and common sense in applying them, and in deciding when to seek guidance from others as to the appropriate course of conduct.

A copy of the Code of Business Ethics can be accessed by clicking here.

Ethics Hotline As part of its commitment to maintaining the highest standards of workplace integrity, Western Digital maintains a toll-free Ethics Hotline. The Hotline is managed by a third party provider, and is staffed 24 hours a day, 365 days a year. While primarily intended for current Western Digital employees, the hotline may be used by other interested parties, including vendors, customers and former employees.

Employees are encouraged to report suspected instances of ethical misconduct within Western Digital, including:

  • Trading on inside information or providing illegal tips
  • Workplace harassment or discrimination
  • Illegal gifts or bribes
  • Fraud, embezzlement or theft
  • Questionable accounting or auditing matters

The Ethics Hotline is intended to provide employees with another avenue for reporting suspected misconduct. Employees may use the Hotline for any reason and at any time. Western Digital will not allow any retaliation against an employee who contacts the Hotline and reports suspected misconduct in good faith.

The Ethics Hotline can be accessed here.

Anti-Corruption Western Digital Corporation believes it is essential that its employees and business partners comply with global anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and the anti-bribery laws of the countries in which the Company operates.

Western Digital prohibits any of its or its subsidiaries’ employees, consultants, agents or representatives from corruptly seeking to obtain or retain business by offering, paying or offering to pay money or provide other things of value to foreign or commercial officials for the purposes of:

  • Influencing any act or decision of such official in his/her official capacity, or
  • Inducing such official to do or omit to do any act in violation of his/her official duty, or
  • Inducing such official to use his/her influence with a foreign government or instrumentality thereof to affect or influence a governmental act or decision, or
  • Securing an improper advantage

Western Digital has published a comprehensive policy relating to Anti-Corruption, which is published on the Company’s internal website. In addition, compliance with the provisions of global anti-corruption laws is discussed in both the Company’s Global Code of Conduct and Employee Handbook.

Corporate Governance Guidelines Our Board of Directors has adopted a set of corporate governance guidelines which represent the Board's current thinking with respect to selected corporate governance issues considered to be of significance to stockholders. These guidelines, along with the charters of the committees of the Board, provide the framework for the governance of the Company. The guidelines are only guidelines and not rigid rules. The Board’s Governance Committee will continue to assess the appropriateness and efficacy of the guidelines and recommend from time to time changes for approval by the Board as it deems appropriate in the best interests of the Company or as required by applicable laws and regulations.

A copy of the Company’s current corporate governance guidelines can be accessed by clicking here.

A copy of the Company’s Compensation Committee Charter, Audit Committee Charter, Governance Committee Charter, and Executive Committee Charter, along with information on the composition of each committee, can be accessed by visiting the “Governance” section by clicking here.