The AT&T Issue Brief Library

Our issue briefs provide a summary of key topics. Download all issue briefs for a comprehensive overview, or use our issue brief builder to generate a customized PDF download with your selected topics. 

Good Corporate Governance

Materiality Assessment Topics: Bribery/corruption

Issue Summary

Good corporate governance is a necessary foundation for ethical and responsible business practices and is directly related to business success.

Our Position

Living up to the highest standards of honesty, integrity and respect is the most important commitment we can make—to our customers, our shareholders and each other.

Data Highlights

2017 Key Performance Indicators
  • Employee training completion on the Code of Business Conduct in 2017: 99% of employees 

Our Action

Code of Business Conduct

The AT&T Code of Business Conduct (COBC) puts our values into action across the globe. More than just a set of rules, the COBC lays out the guidelines and expectations for how we do business and how we interact with customers, suppliers, owners, and each other. We hold ourselves to the highest standards. This means always doing the right thing and operating with integrity, transparency, and honesty. The COBC is available as a PDF and as an interactive form on

The COBC covers a wide range of topics related to ethics and compliance, including diversity and nondiscrimination, conflicts of interest, customer and employee data privacy, and our commitment to the environment. In addition, we maintain an easy-to-use website that provides access to specific policies and more detailed guidance around key topics covered in the COBC. Each employee—from our part-time employees to our CEO—is responsible for reviewing the COBC annually and understanding its provisions.

In the U.S., manager appraisals include a component that reflects the employee’s commitment to the COBC and all other applicable company policies, including completion of all mandatory compliance training. In 2017, approximately 99% of employees completed the annual COBC training.

Resources for Employees Who Seek Guidance or Wish to Raise a COBC Concern

Employees can raise questions and concerns or make a report to their supervisor, another manager, Human Resources, the Chief Compliance Office, Asset Protection or the Legal Department.

If reporting to their supervisor or one of the other resources above is uncomfortable, employees may make confidential and anonymous reports of suspected or actual violations of the COBC or other company policies through a telephone hotline or online reporting mechanisms.

AT&T believes that an employee who seeks advice, raises a concern or reports misconduct is doing the right thing, and we do not tolerate retaliation against such a person. Allegations of retaliation are investigated, and appropriate action is taken.

We also have a separate Code of Ethics that applies to all employees and our Board of Directors (Board). The Code of Ethics emphasizes honest and ethical behavior, avoiding conflicts of interest, and the fairness and accuracy of our SEC filings and related financial statements. In addition, our Principles of Conduct for Suppliers covers numerous topics, including ethics, for suppliers. For more information, see our Engaging Our Supply Chain issue brief.   

Corporate Compliance Program

The AT&T Corporate Compliance Program (Program) is a risk-based program designed around the guidance provided in the Federal Sentencing Guidelines for Organizations (Guidelines). The 2 overarching elements of the Guidelines are:


  • Exercise due diligence to prevent and detect criminal conduct; and
  • Otherwise promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.


Our Program focuses on areas including anti-bribery/anti-corruption, antitrust and competition, third-party oversight, data protection, and environmental health and safety. Our Program goes beyond the requirement to detect criminal conduct, and we monitor all employee misconduct and wrongdoing reported through Human Resources and Asset Protection channels. We expect employees to follow the law as well as our own internal policies, which may hold employees to a higher standard than required by law.

Ethics and Compliance Resources, Including Training and Awareness

We offer many resources for employees who have questions about laws, regulations and policies affecting our business. In addition to the COBC and policy website, below are some examples of other resources available to employees that promote an environment of ethics and compliance: 


  • Employees can contact the “Ask Compliance” helpline by telephone or email to ask questions or raise concerns about compliance policies or ethical issues. 
  • In 2017, we rebranded our compliance training to Ethics@Work and launched the Ethics@Work toolkit. We expanded in-person training sessions to include all mid-level managers and above. This enhanced learning experience included gaming features, risk-based scenarios and interactive discussions with cross-functional employee groups. We continue to use web-based training courses, video training and other types of communications and messaging (e.g., digital signage in elevators, newsletters, newscasts, ethical messaging videos, etc.) to enhance learning for employees and support our culture of ethics and compliance. Many of our compliance courses are accessible via mobile devices.  
  • We establish annual training requirements for areas of compliance that represent significant risks to the company or that support our focus on an ethical culture. In addition to training on the COBC, examples of topics covered in 2017 trainings included anti-bribery/anti-corruption, third-party oversight, data protection, and environmental health and safety, among others.



Around the world, we follow ethical business practices in our dealings with public officials, other companies and private citizens. We do not seek to illegally or unethically influence them, directly or indirectly, through the payment of illegal bribes, kickbacks, or any other unethical payment or inducement. Such activity would erode our integrity and, in most cases, violate the law. We strive to avoid even the appearance of improper influence. In particular, we are especially vigilant when dealing with government officials. Our updated Foreign Corrupt Practices Act (FCPA) and Anti-Bribery Compliance Policy can be found with our CSR Policies.  

Human Rights

Our company’s commitment to Human Rights is outlined in our AT&T Human Rights in Communication Policy.

Political Contributions

We comply with all applicable laws concerning political contributions. Lawful political contributions are an important part of the political process. For more information, see our full statement on political contributions and our biannual AT&T Political Engagement Report.

Corporate Governance

Board of Directors Nomination Process

In reviewing Director candidates, the Board and our Corporate Governance and Nominating Committee consider many factors to ensure the Board encompasses a broad range of skills, expertise, industry knowledge, diversity and contacts relevant to our business.

Board Structure & Responsibilities

Our Board of Director Committees and Charters guide decision-making on a variety of issues. Learn more about each Committee and Charter: 



For more details, including a full list of individual Board members, visit our Corporate Governance website

Board Evaluation

Through a formal survey or other appropriate means, the Corporate Governance and Nominating Committee leads the Board through an annual self-evaluation process to determine whether it and its Committees are functioning optimally. 

Executive/Board Compensation

Our Corporate Governance Guidelines cover subjects such as CEO and Director compensation. The Guidelines are published on our website and available in print to any stockholder who requests them. To view the Guidelines, visit our governance documents or our annual proxy statement.

Sustainability Governance

Our commitment to Corporate Social Responsibility (CSR) is embedded in every company level, and oversight rests with the Public Policy and Corporate Reputation Committee of the AT&T Board of Directors. Our CSR Governance Council is led by our Chief Sustainability Officer and comprises senior executives representing business areas linked to CSR topics deemed most material by our stakeholders. Each senior executive member represents her or his entire department, collaborating on a broader range of issues and perspectives.

Below the cross-functional CSR governance council, there are 4 core issue sub-committees: Community, Employee Activation, Environmental and Human Rights. These sub-committees work closely with the CSR Core Working Team and expert business unit functional teams to incorporate and address CSR issues within AT&T.


Corporate Social Responsibility Governance Council

  • Corey Anthony Senior Vice President and Chief Diversity Officer – AT&T Services, Inc.
  • Len Cali Senior Vice President, Global Public Policy – AT&T Services, Inc.
  • Fiona Carter Chief Brand Officer – AT&T Communications, LLC
  • Tony Goncalves Chief Executive Officer – Otter Media Holdings, LLC
  • Michael Hartman Senior Vice President, Assistant General Counsel – AT&T Services, Inc.
  • Susan Johnson Executive Vice President, Global Connection Management & Supply Chain – AT&T Services, Inc.
  • Mo Katibeh Chief Marketing Officer – AT&T Business Solutions, General Counsel – Vrio Corp.
  • Charlene Lake Senior Vice President, Corporate Social Responsibility & Chief Sustainability Officer – AT&T Services, Inc.
  • Scott Mair President, AT&T Operations – AT&T Services, Inc.
  • Larry Solomon Chief Communications Officer – AT&T Services, Inc.
  • Valerie Vargas Senior Vice President, Advertising and Creative Services – AT&T Services, Inc.
  • Mike Viola Senior Vice President, Investor Relations – AT&T Services, Inc.
  • Rick Welday President, Media Sales & Operations – AT&T Advertising and Analytics AT&T Services, Inc.

Updated on: Nov 20, 2018