Anti-Bribery and Anti-Corruption
Discover has zero tolerance for bribery and corruption. These activities are illegal and against our Core Values; bribery and corrupt behavior violate earned trust and put our company at risk.
Our Anti-Bribery and Anti-Corruption (ABAC) Policy establishes principles that govern the conduct of all employees with respect to compliance with the letter and spirit of the Foreign Corrupt Practices Act (FCPA), Bank Bribery Act, Travel Act, United Kingdom Bribery Act (UKBA), and similar local laws and regulations wherever Discover conducts business. The ABAC Policy prohibits both public and private sector bribery in all forms, generally prohibits “facilitation payments," and is intended to promote ethical conduct to prevent bribery and other corrupt practices.
We have a global ABA Compliance Program that is reasonably designed to implement our ABAC-related policies and procedures. Key components of the ABAC Compliance Program include an ABAC Standard that details the Program’s requirements; a dedicated ABAC team within our Compliance Department; periodic assessments of bribery and corruption risks and the effectiveness of internal controls; and risk-based due diligence and ongoing monitoring of relevant business, employee, and third-party activities to prevent, identify, manage, mitigate, and, when necessary, report bribery and corruption risks.
Employees are also required to participate in annual ABAC training. Our policies, procedures, and training provide guidance on several channels for reporting ethical issues promptly, including through anonymous reports to our Integrity Hotline.
Anti-Money Laundering and Sanctions
Our Anti-Money Laundering (AML) Policy defines our risk-based approach to ensuring our products and services are prevented from being used to launder money, finance terrorism, or violate economic sanctions. It is our policy to aid law enforcement through reporting of suspicious activity.
All employees are trained annually on the AML Policy, U.S. and Canadian AML laws, and Discover’s processes, including specifically how to identify and report transactions associated with money laundering, terrorist financing, and human trafficking.
We undertake customer and partner due diligence to understand the risks associated with maintaining certain relationships and take steps to mitigate those risks, including, but not limited to risks associated with partners operating in certain industries and customers or partners located in certain jurisdictions. This further helps us avoid doing business with any sanctioned entities or money launderers.
Our AML annual training helps employees analyze customer and partner geographic location, products, and services, and expected activities to identify unusual transactions outside of that customer’s or partner's expected pattern of
activity, thus reducing exposure to fraud,
identity theft, and financial crimes.
Upholding Human Rights
Wherever we do business, we respect and protect human rights. As outlined in our annual Modern Slavery Act and Transparency Statements, we prohibit any violations relating to, but not limited to, child labor, forced labor, elder abuse, slavery and human trafficking. Our Code of Ethics and Business Conduct includes an obligation to report any suspicion of non‑compliant and/or unethical behavior, either by Discover or by any of our suppliers, third parties or partners.
One way we hold ourselves accountable for upholding human rights is by performing compliance checks on all new employees and contractors and by training employees on underlying principles and policies of the code annually. We remain committed to transparency of our procurement practices and partnerships and communicating enhancements to our policies and due diligence process as they relate to modern slavery.
Discover’s EthicsPoint Hotline:
Discover is committed to an environment where open, honest communications are the expectation, not the exception. We work hard to cultivate a culture where employees feel comfortable in approaching management to report concerns relating to ethical or business conduct matters, including accounting, internal accounting controls, or auditing matters. However, employees can also report any concerns anonymously (where allowed by local law) through our hotline, EthicsPoint, which is managed by a third party. Discover prohibits retaliation against any employee for reporting concerns in good faith, and we promise our employees that their concerns will be heard.
Consumers can file complaints through the Consumer Financial Protection Bureau’s (CFPB) Consumer Complaint Database, which is a collection of complaints about consumer financial products and services that is then sent on to companies for response.