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ADP expects the highest possible ethical conduct from its Principal Executive Officer and Senior Financial Officers. Your full compliance with this Code and with ADP’s Code of Business Conduct & Ethics and ADP’s Anti-Bribery Policy is mandatory.
You are expected (i) to foster a culture of transparency, integrity and honesty, and (ii) to ensure that everyone in your organization also fully complies with this Code.
In accordance with the rules of the U.S. Securities and Exchange Commission, any change to, or waiver of, this Code must be immediately publicly disclosed.
A. Conflicts of Interest
You must avoid any personal activity, investment or association that could appear to interfere with good judgment concerning ADP’s best interests. You may not exploit your position or relationship with ADP for personal gain. You should avoid even the appearance of such a conflict. For example, there is a likely conflict of interest if you:
There are other situations in which a conflict of interest may arise. If you have concerns about any situation, follow the steps outlined in the Section on “Reporting Violations.”
As an ADP principal executive officer or senior financial officer, it is imperative that you avoid any investment, interest or association that interferes, might interfere, or might appear to interfere, with your independent exercise of judgment in ADP’s best interests.
Engaging in any conduct that represents a conflict of interest is strictly prohibited.
B. Accurate Periodic Reports
As a public company, it is critical that ADP’s filings with the U.S. Securities and Exchange Commission and other regulators are timely, accurate, complete, fair and understandable, and prepared in accordance with U.S. Generally Accepted Accounting Principles and other financial statement requirements. Please exercise the highest standard of care in preparing such reports in accordance with the following guidelines:
If you fail to comply with this Code, with ADP’s Code of Business Conduct & Ethics, with ADP’s Anti-Bribery Policy and/or with any applicable laws, you will be subject to disciplinary measures, up to and including immediate discharge from ADP.
D. Reporting Violations
Your conduct can reinforce an ethical atmosphere and positively influence the conduct of fellow associates. If you are aware of or suspect misconduct, including a violation of any applicable law, you must report it to the appropriate level of management.
You may also contact ADP Global Ethics, your local Human Resources team, the Legal Department or the Audit Committee of the Board of Directors (anonymously, if you wish, where allowed by local law):
|Direct phone:||1-973-974-7377 (Accessible from all locations)|
|Third-Party Helpline Provider, EthicsPoint, a NAVEX company:|
|Website:||www.adp.ethicspoint.com (for web reports)|
|Toll-Free:||A list of toll-free numbers by country with the applicable country code can be found on the Associate Portal at https://myadp.adpcorp.com/ by following the links for Our Company / Policies & Guidelines / Ethics, Legal Compliance / Reporting Ethical Violations or on ADP’s website at https://www.adp.com/about-adp/corporate-social-responsibility/ethics/reporting-an-ethical-concern.aspx|
|Email:||send an email to email@example.com|
|Mail:||send a detailed note, with relevant documents, to ADP, Mail Stop #325E, One ADP Boulevard, Roseland, New Jersey 07068; or|
Any reports that involve the Chief Executive Officer, the President, the Chief Financial Officer, the Chief Operating Officer, the Chief Administrative Officer or the Chief Legal Officer of Automatic Data Processing, Inc. will be immediately communicated to the Chairman of the Board of Directors and the Chairman of the Audit Committee.
Your reports, calls, detailed notes, emails and/or other messages will be dealt with confidentially, unless it is necessary to share such information in order to address the matter appropriately. Regardless, you have the commitment of ADP and of the Audit Committee of ADP’s Board of Directors that if you made a report in good faith, you will be protected from retaliation. ADP has a strict anti-retaliation policy. Any person who retaliates against or threatens to retaliate against another for raising a concern or allegation regarding actual or potential misconduct will be subject to disciplinary action, up to and including termination.
Nothing in this Code or any ADP policy or agreement prohibits you from providing information to the U.S. Securities and Exchange Commission or any government agency in a manner contemplated by law or regulation.
If you are uncomfortable with your answer to any of the above, you should not take the contemplated actions without first discussing them with your local management. If you are still uncomfortable, please follow the steps outlined above in the Section on “Reporting Violations.” All associates, and managers in particular, are responsible for creating an environment that both facilitates open discussion of issues and makes it easy and comfortable to raise concerns without a fear of reprisal.
Any associate who ignores or violates any of ADP’s ethical standards, and any manager who penalizes a subordinate for trying to follow these ethical standards, will be subject to progressive discipline, including immediate dismissal. However, it is not the threat of discipline that should govern your actions. ADP expects you to share its belief that a dedicated commitment to ethical behavior is the right thing to do, is good business, and is the surest way for ADP to remain one of the world’s most ethical and highly successful companies.
Automatic Data Processing, Inc.
One ADP Boulevard
Roseland, New Jersey 07068-1728
The ADP Legal Department is responsible for the interpretation and administration of this policy.
Any printed versions of this document should be used for immediate reference only.
Please refer to the latest electronically approved version.
Revised April 6, 2022