The GEO Group and its worldwide subsidiaries adhere to the highest ethical and compliance standards. As a worldwide corporation, The GEO Group represents government clients around the globe and cares for offenders, detainees, and residents in safe and secure facilities across four continents. Throughout its diversified organization, The GEO Group has implemented policies and procedures that reflect high ethical standards. The GEO Group's corporate code of ethics delineates the overarching principles that guide the organization in its day to day operations and interactions with key constituency groups.
Obeying the law, both in letter and in spirit, is the foundation on which GEO's ethical standards are built. Our Code of Conduct strives to promote the following objectives:
Specific sections of GEO’s Code of Business Conduct and Ethics articulate the company’s policies and guidelines with respect to compliance with antibribery and anti-corruption laws, government contracting, health and safety, conflicts of interest, accurate record-keeping, confidentiality, improper gifts, political contributions, anti-discrimination and anti-sexual harassment, reporting illegal and unethical behavior, and senior leadership roles and responsibilities for meeting disclosure and accounting requirements set by the U.S. Securities
and Exchange Commission.
These standards and policies are communicated widely throughout our organization and reinforced through rigorous and ongoing training. All new GEO employees are provided with a copy of GEO’s Code of Business Conduct and Ethics, along with the GEO Employee Handbook, and are required to sign an acknowledgement form.
The GEO Group has a number of policies, practices, and procedures which directly address Bribery and Corruption programs, Whistleblower programs and practices, among other governance areas. These distinct and comprehensive policies and practices include, but are not limited to:
Additionally, with respect to our Whistleblower program, GEO has a dedicated hotline managed by an independent, third-party provider, which is available 24/7 and which is advertised throughout the organization. These and other policies, practices, and procedures as well as the overall area of Governance is overseen by GEO’s Senior Vice President and General Counsel, which provides for managerial responsibility and accountability at the highest level of GEO’s management structure.
Under applicable laws, as a government contractor, and as established by GEO’s Code of Business Conduct and Ethics, GEO requires a thorough investigation of all acts and allegations of staff misconduct.
The Office of Professional Responsibility (OPR), at the direction of GEO’s General Counsel, is responsible for investigating all acts and allegations of serious staff misconduct. OPR reviews more than 1,700 matters reported annually through the employee hotline or other reporting mechanisms and investigates all matters of serious staff misconduct.
OPR routinely reviews and makes necessary updates to its process to ensure matters of serious staff misconduct continue to be promptly and effectively handled.
To ensure GEO can identify and address potential ethical violations efficiently, we provide employees and third parties with a dedicated confidential and anonymous toll-free hotline. The EthicsPoint hotline, managed by an independent, third-party provider, is available 24/7 and in local languages, such as Spanish. The hotline is proactively advertised throughout the organization. If a report is made involving directors or executive officers, then the Audit and Finance Committee of GEO’s Board of Directors will investigate it. If a report is made involving any other person, then it will be handled by OPR.
After all appropriate steps necessary to investigate the allegation are taken, and it has been determined that there was a violation of the Code of Business Conduct and Ethics, the Audit and Finance Committee and OPR will report such determination to the Board of Directors or applicable regional or divisional vice president, respectively. It is then the Board of Directors’ or applicable regional or
divisional vice president’s responsibility to take such preventative or disciplinary action as deemed appropriate.
This policy and other policies, practices, and procedures, as well as the overall area of Corporate Governance, is overseen by GEO’s Senior Vice President and General Counsel, which provides for managerial responsibility and accountability at the highest level of GEO’s management structure.
GEO’s Whistleblower Program includes a strict nonretaliation policy. Sections 16 and 17 of GEO’s Code of Business Conduct and Ethics specifically discuss protections provided for employees who report
suspected illegal or unethical behavior, or other violations of the Code.
It is GEO’s policy to comply with the requirements of all applicable anti-bribery laws, including the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, and similar local laws in jurisdictions where we operate.
It is GEO’s policy to require our agents, consultants, and business partners to comply with those same laws and practices. Certain activities related to government officials – such as providing gifts, political contributions, entertainment, travel-related benefits or facilitating payments – can violate domestic and foreign antibribery laws. Bribery of non-governmental officials is also illegal in many countries and violates GEO's Code of Business Conduct and Ethics.
Our Anti-Bribery Policy prohibits all forms of bribery, including domestic bribery. It requires assessments of all business partners, internal approvals, books, and record entries, and it imposes records retention
requirements in key risk areas related to government officials and business partners. The Anti-Bribery Policy also requires audits to help ensure compliance, as well as appropriate due diligence of companies
targeted for acquisition or as potential joint venture partners, particularly where the target companies have government contracts or other significant governmental interaction.
To reinforce our ongoing commitment to ethics and anti-corruption, GEO adheres to the American Correctional Association’s industry-specific Code of Ethics, including its anti-corruption standards. All
GEO field staff receive a minimum of 40 hours of training per year, including training regarding our Code of Business Conduct and Ethics, Global Human Rights Policy, and Gifts Policy, among others.