Evolving Together
A Journey of Ethics, Quality, and Trust
A Message from Team Speak Up!
Dear USP Colleagues:
At the heart of USP lies a steadfast commitment to ethics, quality, and trust — principles that guide our actions and shape our organizational culture. A dedicated Speak Up strategy is a cornerstone of this commitment, empowering every voice and reinforcing our shared responsibility to set the highest standards.
Ethics is the foundation of everything we do: guiding our decisions, defining what’s right, and prompting us to act with honesty, fairness, and responsibility. When we Speak Up — whether to raise a concern or share an idea — we’re reinforcing a culture of integrity that protects us all and helps us thrive collectively and as individuals. We are committed to delivering excellence in our work, every day.
Quality isn’t just about the standards and solutions we develop — it’s about how we work together, solve problems, and continuously improve. When we Speak Up about what’s working and what could be better, we help raise the bar for ourselves and for each other.
Trust is something we earn — through consistent actions, ethical choices, and a focus on quality. When we Speak Up, we build trust with our colleagues, our leaders, and our customers and stakeholders. It creates a workplace where people feel safe, respected, and empowered to do their best work.
We know that growth doesn’t happen overnight. It’s a journey of learning, adapting, and improving — together. Speaking up is a key part of that journey. It’s how we stay aligned with our values, respond to new challenges, and keep moving forward as one team. We look forward to continuing on in this journey together — with you!
Elizabeth O’Keefe
Laura Jane Stephens Senior Director, Global Compliance Senior Employee Relations Manager
What USP Employees Are Saying
People Manager, India
1. How has the Speak Up culture at USP evolved during your time here, and what impact has this had on you personally or on the organization as a whole?
Over the past 6.5 years with USP, I have seen a significant evolution in the organization’s approach to fostering a “Speak Up culture.” While USP has always maintained a relatively transparent environment compared to many other organizations, in the past, the ability to express concerns or feedback varied across departments and lacked a structured platform.
Today, USP has established a more formal and organization-wide mechanism that encourages employees to voice their thoughts and concerns without fear of retaliation. This institutionalized approach to ethical communication marks a major milestone for the organization. Personally, it has made me feel more empowered and confident in sharing feedback openly, knowing that it will be received constructively. At a broader level, it has strengthened trust and accountability across teams, contributing to a healthier and more inclusive workplace culture.
2. What challenges, if any, do you think exist when it comes to speaking up at USP?
While USP has made significant strides in fostering a Speak Up culture, I believe challenges still exist in terms of individual communication styles. Not everyone feels equally comfortable expressing concerns;
some individuals are naturally more vocal, while others may need additional encouragement or reassurance to speak up.
There is still an opportunity to further reinforce the message that open communication is not only welcomed but also free from any form of retaliation. Continued emphasis on psychological safety, along with more visible leadership support and regular reinforcement of this culture, can help bridge the gap and make speaking up a truly inclusive experience for everyone.
3. What advice would you give to a new employee about navigating and contributing to the Speak Up culture at USP?
I’ve learned that contributing to the Speak Up culture means more than just raising issues, it’s about doing so with honesty, intent, and responsibility. I would encourage new employees to be genuine and solution-oriented when they speak up. Think about how your feedback can drive positive change, not just highlight problems.
Also, understand that this platform is a privilege — use it wisely, respectfully, and always with a mindset of building trust, not eroding it. When we speak up with integrity and a collaborative spirit, we not only help create a healthier work environment but also contribute to USP’s strong ethical foundation.
Defining Speak Up Culture
Why Speak Up?
Speak Up plays a vital role in USP’s Corporate Compliance Framework, which is designed to align with the U.S. Federal Sentencing Guidelines and is continuously refined to meet evolving expectations from the U.S. Department of Justice. This framework is not only about promoting ethical behavior — it is a strategic tool for identifying, managing, and mitigating risk across the organization.
At the heart of our program is the commitment to maintaining robust and effective lines of communication. These channels are essential for enabling employees and stakeholders to report concerns, ask questions, and seek guidance without fear of retaliation, thereby helping USP proactively detect and address potential issues before they escalate — our internal accountability and early warning system. It empowers us to surface risks in real time, respond swiftly, and reinforce a culture of transparency and integrity. By encouraging open dialogue, we strengthen our ability to embed trust and awareness into every level of the organization, ensuring that our compliance efforts are not only reactive but also preventive.
Effective lines of communication
Written policies and procedures (i.e., Code of Ethics)
Compliance program: leadership and oversight
Education and training
Enforcing standards: consequences and incentives
Risk assessment, auditing, and monitoring
Responding to detected offenses and developing corrective action
Defining Speak Up Culture
Inquiring about legal, compliance, policy, or business ethics
Raising a concern over an action that is perceived to have violated a law or an organizational policy
Encouraging healthy dialogue between staff and leadership to facilitate new and innovative ways of thinking and challenge the status quo
While not every idea may be implemented, all contributions deserve to be heard, and every individual should be treated with respect
What to Report
While we may not anticipate encountering unethical behavior at work, it is everyone’s responsibility to report it if we do. Speaking up is essential to maintaining our organizational integrity and values.
Some situations where you may learn about or witness inappropriate conduct include:
Violation of law or regulation
Misuse of company resources, funds, or property
Abuse of accounting, financial policies, and requirements (including expense reporting and timecard completion)
Bribery or kickbacks of any kind
Filing false claims with a government agency or violating government contract requirements Theft, fraud, or other criminal activities
Disclosure of proprietary or confidential information
Harassment, intimidation, or other inappropriate workplace behaviors
Conflicts of interest with any business, individual, or organization
Other violations of USP’s Code of Ethics or related standard operating procedures (SOPs) and policies
Speak Up Culture in the News
Titan sub whistleblower: US officials ‘botched chance to investigate’
A former director of Oceangate believes the disaster in which five people were killed could have been avoided if his safety warnings had been investigated.
The Times
Culture wars and scandals drag down corporate reputations
MSN.com
Tech company Astronomer launches investigation into ‘kiss cam’ moment at Coldplay concert
abcnews.com
Whistleblower accuses JPMorgan Chase of violating cash reserve rules meant to protect the financial system
International consortium of investigative journalists
Meta whistleblower alleges company worked with China on censorship
BBC
Recognizing Progress: The Journey of USP’s Speak Up Culture
“Comfort in speaking up is an important driver of a culture of integrity and leads to better business performance.”
—Gartner, Inc.
A study conducted by Gartner in 2023/24 found:
▶ 55% of employees at other organizations reported witnessing misconduct that they did not report as many people believed the majority of the policy violations they witness are “harmless.”
▶ Reporting of concerns is typically done through the manager as the reporting channel.
Trust in leadership as well as in each other and in the process of how concerns are handled and responded to is the key to the success of USP’s Speak Up culture. By extension, this sense of trust contributes to the success of individuals and of the organization in how we achieve our mission.
USP maintains that Speak Up is an ongoing journey, but we have reason to celebrate our gains over the last year, with the understanding that the journey must continue.
Favorability ratings (the percentage of respondents selecting agree or strongly agree) according to the Employee Voice Survey:
83%
+6 from FY24
Respondents who have a positive view on the overall state of USP’s Speak Up culture
82%
unchanged from FY24
“I view my manager as a role model for trust and integrity.“
80%
+1 from FY24
“I am confident that if I report an inappropriate business practice or an ethical issue it will be addressed in a fair manner.”
79%
unchanged from FY24
“I can report unethical behavior or practices without fear of retaliation.”
Data from Employee Voice Survey Results collected in the final wave of FY25
By the Numbers
What USP Employees Are Saying Program Manager, US
1. How has the Speak Up culture at USP evolved during your time here, and what impact has this had on you personally or on the organization as a whole?
I believe Speak Up culture has taken some time to be fully trusted internally, due to previous challenges with lingering instances of subtle retaliation or lack of response. I had a negative experience around 2021 with speaking up and being shut down in a somewhat humiliating way, an instance that an observer reporting through his reporting structure that ended up going nowhere.
2. What challenges, if any, do you think exist when it comes to speaking up at USP?
I feel as though there has been great improvement over the past few years and have even been pleasantly surprised by being approached for information about things I may have witnessed when investigations were underway. I have found the discussion I’ve had with my Human Resources Business Partner and Employee Relations (ER) to have been very measured and unbiased, and have had colleagues note that Employee Relations and Ethics have taken remarks made during interviews or discussions to dig deeper into things that had not already risen as complaints in order to try to prevent further issues.
3. What advice would you give to a new employee about navigating and contributing to the Speak Up culture at USP?
I have long trusted the handling of ethics issues at USP, but appreciate the additional work being done for more of the underlying disrespect and more subtle issues that exist in employee relations, both at the peer and leadership levels.
Investigations by the Numbers
This section explains how concerns are handled, which teams manage them, and how they are resolved. It also summarizes the number of cases reported to the Audit Committee of the USP Board of Trustees, which oversees USP’s financial reporting, internal controls, and audit processes to ensure accuracy, integrity, and compliance with legal and regulatory requirements.
For matters to be reported to the Audit Committee on a quarterly basis, the following criteria must be met:
▶ Allegations involving employees in the position of Vice President or higher
▶ Fraud or violations of law or regulations with actual or potentially significant legal, reputational, or financial consequences
▶ Questionable or improper accounting procedures
▶ Improper billing on government contracts or subcontracts
▶ Failure to comply with the Code of Ethics, Employee Handbook, or approved rules of volunteer leadership groups that have actual or potentially significant legal, reputational, or financial consequences
USP’s reporting and investigation process involves multiple teams — including Legal — not just Compliance or Global People & Culture. A structured triage system directs each report to the most appropriate team, ensuring thorough review and resolution.
The Investigations Process
REPORT
Received via a reporting channel and logged into USP’s internal tracking system.
TRIAGE & ASSESSMENT
The report is triaged for legal risk and potential conflicts, then assigned to the appropriate team for investigation.
INVESTIGATION
The investigation takes place.
REVIEW
Findings are reviewed for a fair and consistent outcome, and a root cause analysis is conducted to identify improvement opportunities.
CLOSURE
Case concludes and appropriate communications and actions are taken.
Issue Categories by Team
All incoming reports are evaluated by Global Compliance & Ethics, Global People & Culture/Employee Relations, or Global Legal Affairs to determine the scope of a case and who will investigate.
Conflicts are reviewed via protocols designed to mitigate risk and then assigned to the appropriate team. This assignment matrix does not include all possible issue categories but rather informs on a high level which group is responsible for which types of issues.
Claims of retaliation will typically be investigated by the department that reviewed the underlying claim; otherwise, retaliation claims will be handled by Global Compliance & Ethics in partnership with Legal, unless determined otherwise. Concerns regarding workplace violence and other security issues are handled by Global Security.
▶ Performance/conduct ▶ Discrimination ▶ Harassment
Timekeeping (non-donor funded) EMPLOYEE RELATIONS
Failure to grant appropriate accommodation or leave
▶ Bribery/corruption ▶ Conflicts of interest
▶ Finance-related (invoicing, expensing) ▶ Fraud ▶ Kickbacks
All reports are treated with the greatest confidentiality possible; information will only be shared with stakeholders on an as-needed basis. ▶ Export control and illegal boycott
Government contracting
Insider trading
Misuse of confidential information (leaks)
Protection of USP assets
Scientific integrity
Other serious policy violations
Any allegations or investigations by a government agency
ER Investigation Overview, FY25
Corrective Actions after ER Investigations
19 outcomes from FY25 investigation findings
To ensure transparency into all concerns that come through USP’s reporting channels and to demonstrate the effectiveness of our Speak Up culture work, the data below relates to the investigations handled by USP’s Employee Relations team, including matters that were not reported to the Audit Committee.
37%
Developmental actions/ non-corrective actions (coaching, mentoring, training, etc.)
10%
Transition People Manager role to Individual Contributor role
21% Terminations
Reporting Sources
11%
Warnings (verbal, written, first and final)
16%
Other (examples):
• Anonymous hotline — Reporter was unresponsive to follow-up requests for information
• Investigation findings were unfounded — no credible evidence, no outcome results
• Transferred to POSH (prevention of sexual harassment) committee
5% Alignment of expectations/performance improvement plan (PIP)
Performance/Conduct Case Categories
Issues Investigated and Reported to the Audit Committee, FY25
and FY24
USP’s Business Conduct Policy (which represents the greatest number of investigated issues at USP) encompasses conduct that is considered offensive including those that are insulting, intimidating, threatening, degrading, defamatory, disparaging, disrespectful, or discourteous. As a majority of concerns fall under this category, it is reasonable to conclude that most compliance concerns relate to our people and how we interact and engage with one another. Regardless of the issues that are raised during the year, USP relies on root cause analysis to determine the reason these violations occur and uses that information to inform its risk-based programming such as policy development, training, and other types of engagements with Global Compliance & Ethics, Global People & Culture/Employee Relations, and Global Legal Affairs.
Investigation Issues Outcomes,
A report is deemed unsubstantiated when it cannot be proven with sufficient confidence.
A report is deemed unfounded when it can be clearly demonstrated that no policy violation has occurred.
Substantiated/ Founded
A report is considered substantiated when some or all the allegations raised can be proven with reasonable certainty.
A report is considered founded when it can be clearly demonstrated that a policy violation has occurred.
Inconclusive
A report is considered inconclusive when there is not a reasonable basis to conclude that an incident occurred and is not otherwise substantiated or unfounded. This typically occurs when there is not enough information available to determine a finding.
Compliance and ER Outcomes
As USP’s Speak Up culture evolves, the initial surge in reported matters reflects growing awareness and trust in the process. Over time, it is expected that the volume of reports will level out as employees better understand what qualifies as a reportable issue and as concerns are addressed.
As the culture continues to mature, reported issues may become more complex. With increased awareness of ethical and compliance standards, employees are more likely to identify and report nuanced or layered concerns.
While the number of cases appeared lower in FY25, many investigations were significantly more complex than previous years. Several involved multiple parties, numerous witness interviews, third-party involvement, or higher organizational risk, requiring more time and resources.
As detailed in the report summaries, the nature of issues reported to Compliance and ER not only broadened in scope but also deepened in complexity.
Concerns and questions raised through our reporting channels are not just issues to resolve, they are opportunities for reflection and growth. Each investigation provides firsthand insight into emerging risks and highlights policies or practices that may be ineffective or non-existent. By addressing these findings, we strengthen our organizational norms, ensure compliance, and foster a culture of accountability and improvement.
What USP Employees Are Saying
Function Manager, US
Apart from any outcome that may occur from the act of speaking up, there is a powerful sense of support that comes from speaking up and being heard. I think promoting Speak Up culture at USP has been a powerful tool in changing the way I feel about my choice to communicate and the safety I feel in communicating difficult topics to management.
Investigation Outcomes
What Happens in an Investigation?
The following scenarios are anonymized retellings of actual investigations conducted by USP over the past year.
While the core theme in each scenario has been retained to convey key takeaways and important lessons learned, many of the details have been changed to protect the identities of those involved.
As you read through these scenarios, keep in mind that USP has checks and balances in place to ensure that investigations aren’t siloed and that the process receives the appropriate amount of oversight from Legal, as well as the Audit Committee of the Board of Trustees, which receives a quarterly report of all Compliance and ER-related investigations. This ensures that USP is managing legal risk as well as adhering to our own policies and procedures for conducting internal investigations.
Nepo No-Go
What happened? During the request for quotation selection process for a donor-funded project, a member of the procurement team noted a potential conflict of interest involving one of the participating suppliers. The supplier’s company name included a surname matching that of a USP staff member associated with the process. Further review confirmed that the business was owned by the employee’s parent. In line with standard protocol, the matter was referred to the Compliance team for a comprehensive assessment.
What was the outcome? Following a thorough review conducted by the Compliance team, it was established that the employee had knowingly included a supplier owned by their parent in the request for quotation process. This action was found to be inconsistent with USP’s Code of Ethics and Conflicts of Interest policy, which restricts employees from engaging in procurement activities that may result in personal or familial benefit. The procurement in question was valued at $75,000 in donor funding. Had the conflict not been identified, USP could have been exposed to significant contractual and legal risk. During the course of the investigation, the employee’s lack of transparency with Compliance staff was also noted and found to be in breach of organizational expectations related to cooperation in internal inquiries. In accordance with USP’s disciplinary procedures, the employee was terminated.
Takeaway/lessons learned: This scenario underscores the critical importance of diligence in identifying conflicts of interest within the procurement process. The proactive observation by the procurement team allowed USP to mitigate significant ethical, financial, and contractual risks associated with the donor-funded initiative. Adherence to USP’s Code of Ethics and Conflicts of Interest policy remains foundational in upholding the organization’s credibility and independence as a global standardssetting body. Additionally, transparency and cooperation during internal investigations are crucial for timely and effective resolution. To support organizational integrity, USP continues to prioritize regular training and reinforcement of ethical standards and conflict of interest protocols to ensure all staff understand their responsibilities and uphold the values of the institution.
Collusion and Consequences
What happened? The owner of a third-party agent affiliated with USP raised concerns about the conduct of a USP employee, along with several additional team members. The report alleged there was documentation to demonstrate the gifting of a trip to a four-star resort for the employee and family members that was approved and paid for with company funds by their co-owner without their knowledge. The Reporter alleged that this and other instances of questionable behavior were an indication that the implicated employees were engaging in collusive activities with the co-owner to undermine the company and direct sales to another company.
What was the outcome? Following a formal compliance investigation, it was confirmed that a luxury vacation was provided to the employee and several family members — including their spouse, children, and parents — raising questions about the appropriateness of the gift. The investigation further concluded that the conduct of the employees involved did not align with USP’s Code of Ethics, which emphasizes ethical behavior in all thirdparty interactions and the importance of avoiding both actual and perceived conflicts of interest. As a result, the employees are no longer employed at USP.
Takeaway/lessons learned: USP maintains a clear expectation — and contractual requirement — that all third-party agents and suppliers operate in accordance with the USP Code of Ethics. This framework is designed to promote integrity and ethical behavior across all business relationships. In the event of any concerns, third parties are responsible for promptly reporting potential ethical issues to USP and are expected to cooperate fully with internal investigations to support transparency and accountability.
Likewise, USP employees who regularly engage with external agents and stakeholders are held to high standards of conduct. Employees are expected to uphold professionalism in all interactions and avoid circumstances that could lead to actual or perceived conflicts of interest or breaches of policy and legal obligations. These principles ensure that relationships with third parties remain grounded in trust, ethical responsibility, and regulatory compliance.
The Duty Behind the Report
What happened? The Compliance team received an anonymous report from an employee alleging that several of their co-workers were creating a toxic work environment within the division by engaging in malicious gossip and discriminatory behavior. Due to the complexity and severity of the claims, Compliance staff partnered with Employee Relations to conduct a joint investigation.
What was the outcome? The anonymous individual who submitted the report expressed a willingness to support the investigation. Much of the initial report was hearsay and, without additional context, it was impossible to thoroughly investigate the specific claims. Despite repeated outreach efforts by the investigators to gather further context and clarify the allegations, the Reporter did not respond to follow-up inquiries. As a result, the investigation could not be fully pursued and was formally closed without further action.
Takeaway/lessons learned: Although the initial Reporter did not respond to follow-up inquiries, USP’s investigative team conducted meaningful discussions with division leadership to gain a deeper understanding of the reported concerns. These conversations provided valuable insight into the probable root causes and helped inform a comprehensive list of recommendations, which was subsequently shared with the business to support continuous improvement. While the investigation could not proceed as originally envisioned, USP leveraged the opportunity to explore broader systemic issues within the division. Such inquiries play a pivotal role in shaping initiatives — including training, policy development, and other cultural enhancement efforts — designed to strengthen the organization’s overall work environment.
It is also important to note that while Reporters have the right to remain anonymous, this right comes with the responsibility to fully cooperate with the investigation. Failure to do so constitutes a policy violation that could lead to corrective actions, up to and including termination of employment. This serves as a reminder of the importance of collaboration and transparency in maintaining the integrity of our investigative processes.
What USP Employees Are Saying Legal Team Member, US
1. How has the Speak Up culture at USP evolved during your time here, and what impact has this had on you personally or on the organization as a whole?
When I first joined USP, I do not recall Speak Up culture being discussed. However, roughly five years later Speak Up culture has become a highly visible part of USP’s lexicon/culture. While there is always room for growth, the integration of Speak Up into USP’s culture demonstrates USP’s commitment to the principle.
2. What challenges, if any, do you think exist when it comes to speaking up at USP?
Because of confidentiality considerations, it is not always transparent to USP employees that there is value in USP’s Speak Up culture and staff can use it to help resolve issues/conflicts. Everyone at USP, and especially managers, has a responsibility to encourage staff to speak up when warranted, including when they may not be directly involved in the issue at hand. Speak Up culture can be challenging to navigate when issues arise between supervisors and supervisees. Regular conversations about Speak Up culture may help with this.
3. What advice would you give to a new employee about navigating and contributing to the Speak Up culture at USP?
I would advise the employee to be mindful of USP’s Speak Up culture and to be sure to ask questions where the employee is unsure how to implement it. USP has resources to help employees navigate various scenarios.
I Thought It Was Someone Else’s Job...
What happened? An employee raised a workplace concern with an Ethics Liaison who, recognizing the seriousness of the issue, advised the employee to report it to Employee Relations (ER). Although the individual was no longer employed at USP, they subsequently engaged in a detailed discussion with ER regarding a series of uncomfortable interactions with a colleague. The former employee (Reporter) described these interactions as sexual harassment by the Subject toward the Reporter, occurring both during work hours and on personal time.
What was the outcome? The ER manager conducted interviews with several team members and colleagues (both current and former employees), who provided accounts that significantly differed from the Reporter’s version of events. A recurring theme in their feedback was that it was the Reporter who persistently engaged in unwelcome interactions with multiple coworkers, regardless of whether any interest was shown. After a thorough review, the investigation concluded that the reported workplace concerns of sexual harassment by the individual (Subject) named in the report were not substantiated.
Takeaway/lessons learned: A key takeaway from this case is that employees/ colleagues missed several opportunities to coach, mentor, and guide a colleague regarding USP’s Code of Ethics and Core Values. Despite holding positions of seniority over the Reporter, these employees did not intervene when the Reporter repeatedly made inappropriate comments or disclosed overly personal information. The colleagues’ responses as to why they did not stop the Reporter included: “They’re just young, they’ll learn somewhere else.”; “They’ll figure it out.”; “I thought they could tell by my face that I didn’t like what they said.”
These employees’ failure to Speak Up and address the behavior represents a lapse in leadership and accountability and did a disservice to the Reporter, the employees who endured the harassment by the Reporter, and the Subject named in the investigation.
The Power of a Voice
What happened? Two individuals from separate divisions brought concerns to ER regarding the team environment within a third division. These employees independently observed actions and interactions involving the team’s People Manager that they felt could negatively impact team morale and psychological safety. They shared that, in their view, team members may be hesitant to voice feedback or raise issues due to apprehension around potential consequences/retaliatory behaviors.
What was the outcome? Following a formal review conducted by Employee Relations, the Legal Team, and HR Leadership, it was determined that the conduct of the People Manager had a broader negative impact beyond their direct team. The investigation concluded that their behavior disrupted collaboration and workplace dynamics across multiple levels of the organization. Based on these findings and, in alignment with USP’s Code of Ethics, the decision was made to terminate the individual’s employment.
Takeaway/lessons learned: This case highlights the importance of maintaining open channels for reporting concerns across all levels and divisions within the organization. Employees who speak up, particularly on behalf of colleagues who may feel hesitant to do so, play a vital role in upholding a respectful and inclusive work environment.
A culture that consistently recognizes and addresses inappropriate use of authority is essential to sustaining psychological safety and mutual respect. When employees feel empowered to raise concerns without fear of retaliation, it reinforces a workplace rooted in trust, accountability, and collaboration. The principle of “see something, say something” remains a cornerstone of ethical engagement. Encouraging proactive accountability supports our shared commitment to the organization’s Code of Ethics and Core Values.
Final Thoughts from the Executive Team
To all USP Colleagues,
As we reflect on the past five years, we are proud of the remarkable strides all of us at USP have made on our Speak Up journey. Thanks to your commitment to openness and transparency, Speak Up has evolved into a cornerstone of our organizational culture. Together, we’ve cultivated an environment where every voice is valued, concerns are heard and addressed with urgency and integrity, and accountability is embraced at every level.
Today, Speak Up stands stronger than ever. Participation has grown, trust has deepened, and the positive impact on our workplace is undeniable, as evidenced in the Employee Voice survey results and in our daily conversations with staff. We’ve seen firsthand how empowering individuals to speak up can foster innovation, strengthen collaboration, and reinforce our shared values.
For this five-year cycle, our mission remains clear: to continue building on this momentum. Integrity, respect, and accountability must remain at the heart of everything we do. By staying true to these principles, we ensure that our organization remains a safe, inclusive, and empowering space for all.
Let us reaffirm our dedication to these values and continue to support one another in upholding the high standards we’ve set. The future is bright, and together, we will reach even greater heights.
Thank you to all USP staff for being the driving force behind our thriving Speak Up culture!
The USP Executive Team
What USP Employees Are Saying
People Manager, India
1. How has the Speak Up culture at USP evolved during your time here, and what impact has this had on you personally or on the organization as a whole?
Over the past year, I have seen a positive evolution in USP’s Speak Up culture. There has been a noticeable shift toward encouraging open dialogue and employees are more empowered to voice concerns and share ideas. Personally, it has created the importance of building safe spaces for my team to express themselves without fear of judgment. I have seen this firsthand — one team member who was initially hesitant to speak in our weekly team connects has grown to actively share her views and raise process concerns professionally with functional managers. This progress has reinforced the importance of coaching and building trust, and it had a positive impact on our overall team’s collaboration and confidence.
2. What challenges, if any, do you think exist when it comes to speaking up at USP?
While the culture has improved, challenges remain, particularly around how and where feedback is raised. For example, an associate once voiced dissatisfaction about recognition and compensation openly in our shared workspace, which created discomfort among others nearby. While their intent
to speak up was valid, we later had a 1:1 discussion about the importance of using the right channels for sensitive topics. This helped reinforce that Speak Up culture is about open communication, but also about doing so in a respectful and constructive manner.
3. What advice would you give to a new employee about navigating and contributing to the Speak Up culture at USP?
I would advise new employees to view speaking up as both a right and a responsibility. Ask questions, seek clarity, and raise concerns respectfully through the right channels. One should not hesitate to use 1:1s or speak with manager if something feels unclear or unfair. At the same time, know that leaders here are supportive. Speaking up respectfully and constructively not only helps resolve issues but also strengthens the overall team environment.
What USP Employees Are Saying Manager, US
1. How has the Speak Up culture at USP evolved during your time here, and what impact has this had on you personally or on the organization as a whole?
Since joining USP, I’ve seen the Speak Up culture evolve with greater transparency and open communication. The organization’s decision to share the Trust & Integrity Report — which details the reporting and investigation process and informs employees about the types of issues reported, investigated, and addressed — supports our mission to enhance transparency, build trust, and uphold organizational integrity. Ensuring consistency in messaging throughout the organization has also been key to reinforcing these values and encouraging a unified approach to ethical conduct.
In my role as an Ethics Liaison, I’ve seen how providing guidance and support helps reinforce this culture and empowers employees to speak up confidently. Similarly, the Employee Voice Survey has been instrumental in capturing employee perspectives.
2. What challenges, if any, do you think exist when it comes to speaking up at USP?
Although USP has done well in ensuring that everyone is aware of our zeroretaliation policy and that all feel encouraged to speak up, the willingness to do so ultimately depends on the
individual. A potential challenge for some — new or junior employees — would be the natural hesitation to speak up due to the fear of potential retaliation or the unwillingness to disrupt a harmonious work environment. Additionally, there can also be the uncertainty about the right channels to use, but the company has done well to clearly communicate the proper reporting channels.
3. What advice would you give to a new employee about navigating and contributing to the Speak Up culture at USP?
At USP, embracing the Speak Up culture involves feeling confident and supported in voicing questions, concerns, or suggestions in a respectful and thoughtful manner. For new employees, it’s important to understand the organization’s values and the available channels for open communication. Employees should familiarize themselves with the Employee Handbook, Code of Ethics, and their department’s SOPs and processes. New employees should see their fresh perspective as a strength. They should not hesitate to share observations or ideas that could lead to improvement but should approach discussions with curiosity and a willingness to learn, while also encouraging others to express their views. As always, feedback should be constructive and should offer potential solutions.
The following resources are available to all staff for fostering and supporting a strong, healthy, and productive Speak Up culture at USP. Should you have any comments, questions, or ideas about Speak Up, this report, or our Compliance & Ethics framework, please reach out to compliance@usp.org
How You Can Support a Strong Speak Up Culture
Review USP’s Code of Ethics, Employee Handbook, and related SOPs & Processes.
Participate in awareness building efforts, such as Global Ethics Day on February 3, 2026.
Take pride in USP’s reputation for ethical business practices.
Interact with your department’s Ethics Liaisons on a regular basis.
Respond to the Employee Voice Survey every week.
Complete all mandatory Compliance & Ethics trainings before the due date.
Support USP’s Equity Equals Excellence strategy and ensure that everyone can express concerns in a safe and confident manner.
Proactively ask questions if you find yourself unsure of which direction to go.
Foster an environment where all feel safe to propose novel ideas: Openly support and encourage innovation within your team.
Talk openly about ethical issues to further the notion that acting ethically is a high priority for USP.
Be an ethical role model for colleagues and “walk the walk” with your peers/direct reports.
What are some other ways YOU can support a strong Speak Up culture?
Reporting Concerns and Additional Resources
If you suspect a violation, it is your duty to report it. Retaliation and intimidation are prohibited. Employees may report concerns about suspected Compliance or Ethics in any of the following ways: Report a concern to your supervisor (or any member of leadership), Global Compliance & Ethics, Global People & Culture/Employee Relations, or Global Legal Affairs
Use the USP Helpline (a confidential, third-party service available 24/7) 1-866-492-3365 | usp.org/ethics
Other Resources and Information:
▶ USP’s Speak Up Connect Page
▶ Your Department’s Ethics Liaison
▶ Fostering Psychological Safety to Increase Belonging and Build Speak Up Culture at USP
▶ What USP Leaders Need to Know — Responding to Reports (complaints, inquiries, etc.)
▶ USP HAS ZERO TOLERATION FOR RETALIATION
USP will not tolerate retaliation against anyone who reports a concern in good faith, nor will we tolerate retaliation against anyone who participates in an investigation. If you believe you have been retaliated against or have witnessed retaliation, report the situation to any resources listed in this report. Reporting “in good faith” means you had reason to believe a violation existed and are sincere in your attempt to provide honest and accurate information, even if there was no violation.
Discussion Guide
About This Guide
This guide is to help you understand the important role that all staff members play with respect to understanding and engaging with our Speak Up process. By reviewing the Trust & Integrity Report together with our colleagues, we aim to create a space for open dialogue, build awareness of how concerns are reported and addressed, and ensure everyone feels empowered to raise issues without fear of adverse action or retaliation.
We encourage you to start a dialogue with your team members, your Ethics Liaison, or your group leadership. Your shared insights and experiences are essential to strengthening our Culture of Integrity and Accountability!
Some questions to consider:
▶ What are the key takeaways from this year’s Trust & Integrity Report?
▶ Were there any surprises or unexpected trends in the data presented?
▶ What does the report reveal about our organizational culture and leadership’s commitment to ethics?
▶ How does this year’s report compare to previous years in terms of scope, depth, and transparency?
Please consider sharing any feedback you have to compliance@usp.org
With a little help from our AI friend...
The Global Compliance Team composed this report with a little help from the USP-licensed, web-based version of Copilot, available to all USP employees. The authors created prompts from various data points and other information available to them, and asked Copilot to assist with the task of writing cohesive and engaging content. This is an example of how employees can use Copilot to complete daily tasks in a more efficient manner that is consistent with the intended (and ethical) use of this tool. For more information, including how to seek out guidance from a USP AI Ambassador, please visit the AI @ USP page on USP Connect.