Based on the outcome of Avnet’s sustainability materiality study1 in 2020, ethics and compliance within our corporate governance was identified as a key focus area for Avnet’s ESG strategy. Ethics and compliance are the foundation upon which our governance work is built. Avnet's Ethics & Compliance Program is designed to prevent, detect and respond to instances of legal and compliance risk and misconduct, and to promote an ethical culture at Avnet. It is also intended to ensure we are acting with integrity for our employees, customers, suppliers, and shareholders, communities, and company – and doing business the right way.
Visit Avnet’s Ethics & Compliance Program for more information.
Strategic Roadmap
The chief ethics and compliance officer evaluated Avnet’s Ethics and Compliance Program in FY21 and initially focused on refreshing it in three key areas:
- Training
- Communications and awareness
- Code of Conduct Advisors

During FY21, the Ethics and Compliance Office also developed a strategic roadmap for the FY22-24 program with the following strategic objectives in mind:
- Sustain the progress already made in creating an effective program.
- Enhance existing tools, training and processes to strengthen the program.
- Adapt the program as appropriate due to business changes, regional differences and legal/regulatory developments.
- Operationalize responsibility and accountability for compliance oversight and monitoring.
- Regionalize the program through localization of policies and awareness materials and customization of initiatives based on regional issues and dynamics.
- Measure effectiveness of the program and its component parts to identify opportunities for improvement.
In support of Avnet’s commitment to Ethics and Compliance, we have provided a status on our FY21 goals and modified our FY22 goals to support our FY22-24 strategic roadmap.
Ethics & Compliance Goals: FY21 – FY22
Topic | Goals | FY21 Performance | FY22 Goals |
---|---|---|---|
Increased employee awareness | Incorporate two “moments of ethics” at Executive Leadership Team meetings, and four at senior-level quarterly meetings | MET GOAL Completed two “moments of ethics” at Global Town Halls, and several “moments” in other senior level meetings |
|
Training | 96% of all identified employees complete E&C training | DID NOT MEET
|
Refresh of the E&C training program and roadmap, with a focus on managers/“tone at the middle” |
Job descriptions and onboarding | Strengthen language in job descriptions and onboarding | MET GOAL Language added to external job postings and onboarding materials in the APAC and Americas |
Add language to external job postings in the Europe, Middle East, and Africa (EMEA) region |
Code of Conduct | N/A | N/A |
|
Most Ethical Company status | Maintain most ethical company status |
DID NOT MEET |
N/A |
1Our ESG materiality assessment and analysis was designed to identify the most relevant, or material, issues from an ESG perspective, which is a broader standard than that used in our financial disclosures. The use of “material” or “salient” when referring to ESG topics or risks throughout our ESG reporting is intended to flag the most important issues from our ESG assessment and does not speak to the materiality of those issues to Avnet.