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.

Health and Safety

Providing a safe workplace for our employees is a priority at WD. We believe that safety is everyone’s business, and so we ask our employees to

  1. comply with the Company’s safety regulations and use necessary safety equipment as required,
  2. strive to continually improve the safety of our facilities and prevent industrial injuries, and
  3. report possible safety hazards so that they can be addressed expeditiously.


Our manufacturing facilities in Asia all have occupational health and safety management systems which are OHSAS 18001 certified. Each has a comprehensive policy and set of supporting procedures addressing occupational safety, emergency preparedness, occupational illness and injury, industrial hygiene, machine safeguarding and physically demanding work.

All of our facilities worldwide have safety committees comprised of a cross-functional team of employees who meet regularly to assess the Company’s policies and processes and recommend improvements. Safety committee members work with health and safety personnel at each facility to keep track of occupational injuries, assess their root causes and recommend corrective action to avoid recurrences in the future. Committee members also conduct periodic inspections of our facilities and organize activities aimed at promoting safety within them.

All of our facilities also have Emergency Response Teams (ERTs) whose members are trained to respond to an incident (such as a fire, medical crisis, earthquake, etc.) and control its impact. Each ERT assists in developing a site-specific plan whose objective is to organize an effective response and minimize injury and damage.

Malaysia Certifications Thailand Certifications
ISO 14001 ISO 14001
ISO 9001 ISO 9001
OHSAS 18001 OHSAS 18001


Q&A for Health, Safety and Business Continuity Planning

Health and safety

Q. Does Western Digital have management representatives responsible for assuring compliance with respect to health and safety laws, regulations and codes?

A. Yes. Western Digital has management representatives at all critical sites whose core responsibility is monitoring, communicating and training employees in all aspects of both facility and employee health and safety.

Q. Does Western Digital have a written occupational health and safety policy?

A. Yes. Western Digital’s corporate environmental, health and safety policy statement is set forth below:


Western Digital Corporate pledges itself to becoming a worldwide industry Leader in the protection of the environment and employee health and safety. Consistent with our stated corporate values, we will adhere to this pledge by conducting all of our business activities in the light of the following environmental, health & safety (EH&S) values:

  1. We comply with all applicable EH&S laws and regulations as our minimum threshold of EH&S performance, and we strive, where feasible, to surpass compliance requirements.
  2. We recognize prevention of health and safety risks, and pollution prevention, as two of our paramount corporate objectives, and apply best prevention practices through our system of Continuous Process Improvement.
  3. We strive to identify and minimize adverse EH&S impacts and risks from our business operations by considering opportunities for EH&S protection in the design and planning stages of all facility, process, and product developments and modification, and by establishing specific EH&S improvement objectives.
  4. We work to conserve raw materials and natural resources, including energy and water, recognizing that this is essential to the sustained profitability of our business, as well as to the sustainability of natural ecosystems.
  5. We distribute responsibility for EH&S protection throughout our value chain. We diligently partner with our customers, suppliers and contractors to optimize EH&S protection and performance in our products, operations, and facilities.
  6. We actively foster open communication to internal and external stakeholders regarding our EH&S performance, recognizing that this dialogue is essential to continuous improvement of our EH&S protection practices, and to build an environment of trust within the communities in which we operate.
  7. We work to develop within each individual employee a sense of personal responsibility for EH&S protection. We support this responsibility with appropriate education, training, financial, and other resources, and by holding each business unit director, managing director, and individual employee accountable for adhering to the principles stated in this Policy.
  8. We pursue minimization of solid and hazardous waste in all of our business decisions and operations. To achieve this, recyclables and reusability of all waste, including product packaging, are key considerations.
  9. We continuously seek to improve our management of EH&S risks and impacts, and to enhance our EH&S performance. Continuous improvement is pursued by periodic management reviews of, and internal audits for conformance to, this policy statement and the EH&S management system.


Q. What types of policies, rules or procedures does Western Digital maintain relative to health and safety programs?

A. Western Digital maintains health and safety polices, rules and/or procedures which address occupational safety, emergency preparedness, occupational injury or illness, industrial hygiene, physical work, machine guarding and living conditions where applicable. The substance of these programs is delivered to employees utilizing various formats including in-person training, web-based training, face-to-face communications, postings and bulletins. All programs are communicated in various languages appropriate to the employee population of each of our facilities to insure that all employees have a clear understanding of the programs.

Q. Do Western Digital’s facilities receive periodic audits of health and safety practices in order to assess conformance with regulatory and other requirements?

A. Yes. Western Digital conducts both internal and external audits to evaluate its compliance with applicable health and safety laws and regulations.

Q. Does Western Digital have a program to manage occupational injuries and illness, including treatment of reported cases, investigations, record keeping, and returning workers to work as soon as they are physically able?

A. Yes. Western Digital has personnel assigned to focus on these tasks as part of their daily responsibilities.

Q. Does Western Digital have a program or procedures in place to monitor and evaluate worker exposure to chemical, physical, or biological agents?

A. Yes. Key Western Digital locations have a staff of E, H & S personnel who are chartered with monitoring the work environment and making recommendations to management. If the expertise is not available in-house, Western Digital will utilize the services of outside professionals to provide testing and recommendations to assure a healthy workplace.

Q. Does Western Digital have a program of insurance to compensate for the medical costs of work-related injuries or illnesses?

A. Yes. Western Digital has different programs in place which are tailored to meet the specific needs of employees at our various facilities throughout the world.

Q. Does Western Digital have procedures in place for safeguarding of workers from potentially hazardous machinery, including barriers, interlocks and periodic inspections?

A. Yes. Western Digital has a full complement of employee health and safety policies, procedures and programs customized for each of our facilities. These programs include but are not limited to electrical safety, lockout/tag out, cutting/welding, and contractor safety.

Q. Does Western Digital provide protective equipment to workers exposed to potential hazards?

A. Yes. Western Digital has formal programs and provides all necessary protective equipment to workers exposed to potential hazards. Our programs include but are not limited to chemical hygiene, hearing conservation, respirator protection and ergonomics.

Q. Does Western Digital have emergency medical supplies placed in convenient locations at the facility for immediate use?

A. Yes. Western Digital maintains basic first aid supplies at all of its facilities. In addition, certain of our locations are staffed with medical personal should the need for more sophisticated medical services arise.

Q. Does Western Digital place contractual requirements on its suppliers to be in compliance with health and safety laws, regulations and codes of conduct?

A. Yes. Whenever possible, Western Digital executes contracts with its suppliers which require, among other things, that the suppliers comply with all relevant and applicable health and safety laws and regulations.

Business Continuity Planning

Q. Has Western Digital identified and assessed potential emergency situations such as process failures, accidents, storms, floods, or other events that pose a threat to humans or the environment?

A. Yes. Western Digital regularly evaluates its risks associated with non-controllable events, has developed comprehensive Business Continuity Plans (BCP) for all key locations, and updates these plans annually.

Q. Has Western Digital developed and implemented an emergency preparedness and response program to minimize the impact of an emergency?

A. Yes. In addition to its site-specific BCP’s, Western Digital has local Emergency Response Teams (ERT) who are trained as first responders in the case of a site-specific event.

Q. What emergency programs or systems does Western Digital have in place to prepare for an unforeseen event?

A. Western Digital maintains a variety of site-specific programs and systems to respond to any particular event. The programs include but are not limited to evacuation procedures and routes, qualification and training of first responders, emergency response drills and guidelines for external communications and reporting. Systems include but are not limited to fire alarm systems, gas monitoring systems emergency lighting, use of protective equipment and clean up and decontamination.

Q. Does Western Digital have firefighting aids in place for immediate use at its Facilities?

A. Yes. All Western Digital buildings have fully-operational sprinkler systems with the exception of our Navanakorn facility and maintain a full compliment of fire hoses, fire extinguishers and trained personnel should the need arise to deploy this equipment.

Q. Does Western Digital have programs or policies in place to promote cooperation with local authorities, including fire and police, in order to manage emergencies and assure public safety?

A. Yes. Western Digital has dedicated site supervisors at all key locations whose responsibility is to interface with local emergency authorities. In addition, all sites are staffed with security personnel who are trained with respect to receiving and reporting with local emergency agencies.