We take violations of our Code, policies, and the law seriously and work quickly to uncover them through internal, external, and government investigations and audits.
The investigation process empowers FIS to address wrongdoing, minimize potential damage, and demonstrate our Company’s commitment to working with integrity.
Cooperate fully.
Whether you are an FIS colleague, contractor, or director, you are expected to:
- Cooperate with any required investigation, audit, review, examination, or test.
- Recognize that refusal to cooperate may lead to disciplinary action – even termination.
- Immediately notify your manager if you have been asked to participate in a government investigation or inquiry.
If misconduct is occurring …
We need to know:
- Who was involved
- What happened
- When it happened
- Where it occurred
- How we can prevent it in the future
An investigation or audit helps us gather those facts and get to the bottom of the situation.
Be honest and accurate.
To ensure effective and transparent investigations, you must:
- Never make false or misleading statements related to:
- - Audits or reviews of our financial statements
- - Internal or external audits of our Company
- - Activities of auditors or investigators
- - Documents we file with the SEC or other local or regional agencies
- - Reported concerns, including reports to the Ethics Helpline
- Give complete information – never omit details that are relevant to an auditor or investigator.
- Refrain from pressuring others to give incomplete, false, or misleading statements.
Additional Resources Available:
If misconduct is occurring …
We need to know:
- - Who was involved
- - What happened
- - When it happened
- - Where it occurred
- - How we can prevent it in the future
An investigation or audit helps us gather those facts and get to the bottom of the situation.
Keep in mind …
Unless you are specifically authorized to do so, do not directly interact with regulatory agencies on FIS matters.
Instead, direct all regulatory agency requests to the Ethics Office.
Centralized and coordinated management of interactions with regulatory agencies is critical to ensuring timely and accurate disclosure of sensitive information.
Our Core Values In Action
Q: What if I did not report any concern but am asked to cooperate in an internal investigation? Must I participate?
A: Yes. At times, we may need to reach out to additional potential witnesses or parties to an incident in order to gather necessary information. As an FIS colleague, we ask that you cooperate in all internal investigations, so that we may carry out our commitment to working with integrity.
