Environmental, Social & Governance

Business Ethics

At NCR, we run the store, restaurant and self-service banking for our customers—so they have more time to focus on what’s important to them. Our board of directors, executive officers, managers, employees and other NCR representatives are committed to maintaining the highest standards of business ethics and integrity as outlined in the company's Code of Conduct. Complying with these core values and principles is at the heart of everything we do.


Business ethics oversight

NCR’s Ethics and Compliance Office oversees our adherence to our Shared Values, Code of Conduct, and policies. The key pillars of our Compliance program include:

  • Board of Directors’ Committee on Directors and Governance, which gives guidance and direction on the company’s Ethics & Compliance Program
  • Chief Ethics & Compliance Officer, who leads our robust business ethics, bribery and corruption and whistleblower programs
  • Ethics & Compliance Committee, led by our Chief Ethics & Compliance Officer and comprised of leaders from our Global Security, Information Security, Human Resources, Employee Relations, Diversity, Equity, and Inclusion, Internal Audit, Law and Risk departments.

Our Ethics & Compliance Officer oversees investigations of reported violations of NCR’s shared values, Code of Conduct and policies and reports on those activities to NCR’s board of directors. Our Chief Ethics & Compliance Officer reports quarterly to the Chairperson of the Board of Directors’ Committee on Directors and Governance, who evaluates the performance of our Chief Ethics & Compliance Officer and the Compliance Program annually.

Ethical reporting

NCR employees are always encouraged to speak up and report any concerns of wrongdoing through the multiple independent avenues NCR provides to report ethical concerns. Employees can report concerns to their management teams, local human resources or legal departments, or directly to the company-wide Ethics & Compliance Office. Employees can also make anonymous reports via the NCR Alertline, available 24/7 and in over 150 local languages, or send an email to the Ethics & Compliance mailbox.

NCR’s Alertline is operated by an independent third party, Navex Global, Inc. Navex is unaffiliated with NCR. All anonymous reports made to the Alertline are made in strict confidence.

Reported concerns are shared only with those required to help answer questions or investigate matters, ensuring the prompt enforcement of NCR’s reporting standards. If appropriate, the Ethics & Compliance Office will determine disciplinary action. Further, any employee who reports a potential violation in good faith is not the subject of a retaliatory termination or other adverse employment action.

Training courses

Everyone at NCR is required to annually take our Code of Conduct training, available in 17 languages. Since 2008, NCR has achieved 100% timely completion of its Code of Conduct training.

Other training courses are assigned based on our employees’ responsibilities, considering specific risks.

  • Members of our Payments business are required to annually take anti-money laundering training. In 2022, we achieved 99% timely completion of the course.
  • NCR personnel in our public sector business are required to annually take Corporate/Personal Integrity Program (C/PIP) training. In 2022, we achieved 100% timely completion of the course.

To date, 81% of our managers have completed Civil Treatment training globally.


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Types of Report as Percentage of Reports

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Consequences for violating NCR’s Code of Conduct range from warnings to termination, depending on the severity of the violation. NCR has a zero tolerance for retaliation against good faith reports, regardless of whether allegations are ultimately substantiated.

Culture of integrity

NCR's shared values form the foundation of our business relationships with each other, our customers, partners and suppliers, and are used to direct our behavior and guide our decisions as we drive to achieve our business objectives.

The NCR Code of Conduct sets the standards designed to uphold our values and foster integrity in our relationships with one another and our valued stakeholders. The Code applies to all NCR associates, including senior management (including our principal executive officer, our principal financial officer and our principal accounting officer), directors, independent contractors and agents. Our Ethics & Compliance program is responsible for managing the company’s adherence to the Code of Conduct, while our Chief Ethics & Compliance Officer oversees investigations pertaining to fraud, conflicts of interest, violations of laws and other similar matters, and reports on those activities to the Board.

Our Code of Conduct sets standards to uphold our values and ethics and embed integrity into our relationships with one another and our valued stakeholders. This Code is reviewed by the Committee of Directors and Governance at least annually.


NCR has a zero-tolerance policy for bribery and corruption and requires all directors, officers, employees and all third-party NCR representatives to adhere to the highest legal and ethical standards of business conduct. With oversight by the Ethics & Compliance Office, all NCR associates and representatives are expected to comply with applicable anti-corruption laws, including the US Foreign Corrupt Practices Act and the UK Bribery Act.

NCR also has clear guidelines articulating the company’s efforts to keep accurate records that fairly reflect the transactions and disposition of assets of the company and its internal monitoring system to detect corruption.

Employee ethics training

All NCR employees undergo Code of Conduct training during the onboarding process, and we require all employees to complete an annual recertification training on NCR’s Code of Conduct. This yearly training reviews, among other topics, NCR’s human rights, anti-corruption and business conduct policies. At the end of the training, each employee must certify that they will comply with the NCR Code of Conduct. The Code of Conduct training is revised annually to reflect any changes to compliance issues or any potential compliance risks.

In 2019, NCR introduced additional training to individuals in its organization, such as supply chain managers, sourcing and compliance personnel who may require more in-depth knowledge about recognizing and addressing modern slavery and anti-money laundering laws.

Political involvement

NCR supports employee participation in the political process, for example, voting in elections or making personal contributions to support candidates or parties of their choice. Employees may express their views on government, legislation and other matters of local and national interest. However, these activities must be undertaken on an employee’s own time and at his or her own expense. 

No employee will be compensated or reimbursed for personal political contributions or be given or denied employment or promotion due to making, or failing to make, a political contribution.

Political involvement activities that are prohibited or require authorization include:

  • Committing company funds or other assets to political candidates, parties, or other political activities, including public policy initiatives or referendums, without the prior approval of the Vice President, Global Government Affairs
  • Providing or promising money or anything of value to a government official to obtain or retain business
  • Allowing use of company facilities or equipment for political activities without the prior approval of the Senior Director, Global Government Affairs