GPM is committed to maintaining the highest ethical standards, fostering a culture of integrity, and ensuring a respectful, safe, and equitable environment for all stakeholders, including staff, credential holders, partners, and representatives. This policy outlines the procedures for reporting ethical violations, protecting whistleblowers, addressing conflicts of interest, and preventing harassment or discrimination.
Violations of the GPM Code of Ethics and Professional Conduct include, but are not limited to:
Based on the severity of the violation, the following actions may be taken:
A conflict of interest arises when personal, financial, or professional interests interfere with the best interests of GPM. Examples include:
GPM prohibits any form of harassment, discrimination, or bullying, including but not limited to:
This policy will be reviewed annually to ensure compliance with evolving ethical and professional standards. Updates will be communicated to all affected stakeholders.
By engaging with GPM—whether as staff, a credential holder, or a representative—individuals acknowledge and agree to comply with this policy.
At GPM, we strive to provide high-quality products and services. If you are not fully satisfied with your purchase, please review our refund and cancellation policy below.
You may request a refund for eligible products within seven (7) days of purchase by contacting us at
The following items are non-refundable:
Monthly subscriptions for GPM Ambassadorships can be canceled at any time. To cancel:
Cancelled subscriptions will remain active until the end of the current billing cycle, and then no further charges will be made.
If your product has not yet been downloaded, you may cancel your order by contacting us immediately at
For refund requests, cancellations, or any related questions, contact us at:
GPM
41502 Orianna Lane
Novi, MI 48385 USA
Email:
Updated March 10, 2025
Entities other than GPM and authorized users may not use any form of the GPM logo ("logo") except to identify GPM products or services. Any use that falls outside of these specifications is strictly prohibited.
The logo consists of a stylized globe in blue, symbolizing global reach and sustainability. At the bottom of the globe, there is a green leaf, representing environmental responsibility and regenerative practices. On the right-hand side of the globe, two curved orange circular lines add a dynamic element, suggesting movement, innovation, or cyclical sustainability principles. The letters "GPM" appear in a stylized blue font, integrated seamlessly into the design. The color palette of blue, green, and orange conveys sustainability, stability, and energy.
Third parties are explicitly prohibited from using any form of the logo in products, product packaging, or other situations that do not relate to GPM products or services.
This includes, but is not limited to, the following:
Non-GPM materials may not mimic any GPM advertising, product packaging, or website design without prior written permission from GPM.
Third parties may only use a form of the logo without prior written permission under the following circumstances:
In an area of a website, advertising, or marketing collateral exclusively dedicated to the promotion of GPM.
GPM reserves the right, in its sole discretion, to terminate or modify permission to display the logo. GPM may request that third parties modify or delete any use of the logo that, in GPM’s sole judgment, does not comply with this policy or might otherwise impair GPM's rights in the logo. GPM further reserves the right to object to unfair uses or misuses of its logo, trademarks, or other violations of applicable law.
Updated March 9, 2025
This policy defines the appropriate use of GPM’s intellectual property (IP), including copyrighted materials, logos, non-registered trademarks, and USPTO-registered trademarks. The intent is to safeguard GPM’s brand integrity and ensure clear, consistent communication in alignment with its values.
GPM retains full rights to its published works, including but not limited to:
Third-party use of the GPM logo is governed by the GPM Logo Use Policy.
For permissions, licensing, or policy questions: Email:
Updated March 9, 2025
Please read GPM’s Acceptable Use Policy ("AUP") carefully before accessing any site operated by GPM or its affiliates.
All site contents are copyright © 2009–2025 GPM and/or its affiliates. All rights reserved.
No portion of our sites may be reproduced, distributed, or transmitted in any form without prior written permission from GPM.
By accessing and using this website, you agree to comply with our AUP. GPM reserves the right to update these terms at any time. Violations may result in legal action, suspension of access, or other remedies.
You are granted a limited, non-exclusive license to use materials from this site for non-commercial purposes within your organization or, if you are a GPM Accredited Training Partner, within your customer’s organizations. All copyright and proprietary notices must be retained in copies. No other rights are granted.
You must comply with all applicable laws, including U.S. export controls and local laws. GPM products are commercial and subject to restrictions under DFARS 252.227-7015 and FAR 52.227-19.
All trademarks, logos, and service marks on this site are the property of GPM or their respective owners. Use without prior written consent is prohibited. Refer also to our Logo Use Policy.
All site content is provided “as is” without warranties of any kind. GPM disclaims all warranties, including fitness for a particular purpose. We are not liable for any damages resulting from your use of this site or its content.
Some GPM products or services may not be available in your region. Contact your local GPM representative for information.
We may provide links to third-party sites for convenience. GPM is not responsible for the content or accuracy of third-party sites.
Unauthorized access to restricted areas is prohibited. You may not use this site for illegal activities, fraudulent purposes, or to abuse GPM’s services or data.
Your GPM account is personal and must be kept secure. Notify us immediately of any unauthorized use or access. Failure to do so may result in liability for unauthorized activities associated with your account.
You may not reproduce copyrighted materials without prior written permission.
If you believe your copyright has been infringed, contact our Designated Agent with the required information under the Digital Millennium Copyright Act (DMCA).
Designated Agent:
GPM – Legal Department
41502 Orianna Lane
Novi, MI 48385 USA
Email:
Updated: March 9, 2025
At GPM, protecting your privacy is a top priority. This Privacy Policy explains how we collect, use, share, and safeguard your personal information when you visit our websites, use our services, or interact with us. By using our services, you agree to the terms of this Privacy Policy.
We collect information in various ways, including:
Types of information we collect:
We use your information for:
We use cookies to:
You can control cookies through your browser settings. Disabling cookies may limit your experience on our site.
We share information with:
We do not sell your personal data to third parties.
We retain your information for as long as necessary to:
Once no longer needed, we securely delete or anonymize your data.
Depending on your location, you may have the following rights:
GDPR Users: EU residents can exercise these rights under GDPR.
CCPA Users: California residents have additional rights under the CCPA, including the right to opt out of data sales (though we do not sell data).
To exercise any of these rights, contact us at
We use administrative, technical, and physical safeguards to protect your data. While no system is 100% secure, we continuously improve our security practices to reduce risks.
We operate globally, so your data may be transferred and stored outside your home country. We ensure appropriate safeguards for cross-border transfers, including Standard Contractual Clauses where applicable.
Our services are intended for users 13 years and older. We do not knowingly collect data from children under 13. If we discover such data, we will delete it promptly.
We may update this Privacy Policy periodically. Changes will be posted here with an updated effective date. Significant changes will be communicated directly.
For any questions, concerns, or to exercise your privacy rights, reach out to:
GPM
41502 Orianna Lane
Novi, MI 48385 USA
Email:
Updated March 10, 2025
As a business and an employer, it is necessary for GPM Ltd. D.B.A. GPM Global and its subsidiaries and affiliates (collectively, “GPM” or the “Company”) to collect, store, and process personal data about our employees, contingent workers, customers, suppliers, and other third parties with whom we engage to provide products or services on our behalf.
With the introduction of the European General Data Protection Regulation (“GDPR”) on May 25, 2018 and other applicable laws governing data protection, we are subject to enhanced requirements regarding how we collect, use, and store personal data.
The purpose of this policy is to help all of us comply with our legal obligations and enable individuals about whom we hold personal data to have confidence in us. This policy applies to all GPM employees, contingent workers and third parties processing data on behalf of GPM. Unless specified, this policy applies in all countries in which GPM operates and/or conducts business.
“Data Controller” or “Personally Identifiable Information Controller (PII Controller)” means the entity that determines the purpose and means of Processing Personal Data.
“Data Processor” or “Personally Identifiable Information Processor (PII Processor)” means the entity that Processes Personal Data on behalf of the Controller.
“Data Protection Laws” means all applicable data protection and data privacy laws and regulations, including but not limited to the EU General Data Protection Regulation (GDPR), UK General Data Protection Regulation (UK GDPR), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and the California Consumer Privacy Act (CCPA).
“Data Subject” or “Personally Identifiable Information Principal (PII Principal)” means the identified or identifiable person or household to whom Personal Data relates.
“Data User” is a term used to describe any employee, consultant, independent contractor, intern, temporary worker or third party acting on GPM’s behalf (including data processors) whose work involves processing personal data for GPM.
“Personal Data” shall have the meaning ascribed to “personally identifiable information,” “personal information,” “personal data” or equivalent terms as such terms are defined under Data Protection Laws.
“Personal Data Incident” shall have the meaning assigned by Data Protection Laws to the terms “security incident,” “security breach” or “personal data breach” and shall include any situation in which Vendor becomes aware that Personal Data has been or is likely to have been accessed, disclosed, altered, lost, destroyed or used by unauthorized persons, in an unauthorized manner.
“Processing” means any operation or set of operations that is performed on Personal Data, whether or not by automatic means, such as collection, recording, organization structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Processing also includes transferring or disclosing personal data to third parties.
“Special Category Data” or “Special Category Personal Information” is a subset of personal data and refers to information about an individual’s race or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data (eye color, hair color, height, weight), medical history, or criminal convictions and offenses or related security measures.
Depending on the circumstances, GPM may act as a data controller or a data processor. As a data controller, GPM is responsible for establishing practices and policies in line with Data Protection Laws. It is equally important that GPM be able to demonstrate compliance with these laws. The Company does this by:
Any personal data that the Company processes or that is processed on GPM’s behalf must:
GPM processes sensitive information on behalf of colleagues across various business systems and limited special category data in Workday. Appropriate controls are in place and outlined in the Special Category Data, Benefits and Payroll DPIAs and the Access Control Standard for Sensitive and Special Category Data available on the GPM Compliance site.
The Company may only process personal data if permitted to do so under Data Protection Laws. The following are the grounds GPM relies upon to process personal data:
Where processing is necessary:
In addition to these grounds, GPM may also process personal data where the data subject has given consent to the processing for one or more specified purposes, provided that the consent is freely given, specific, informed and an unambiguous indication of the data subject’s wishes. Where GPM uses consent as the grounds for the processing, a data subject has the right to withdraw consent at any time and for any reason.
GPM may, on occasion, also need to process special categories of personal data for customers, employees or contingent workers (e.g., where required by safe employment practices). When GPM processes or uses a third party to process on its behalf special categories of personal data, GPM will ensure, where applicable, that the following conditions are satisfied:
GPM maintains a central record of the types of personal data the Company collects and why that data is collected. GPM will only process personal data for the specific purpose(s) set forth
in the central record or for any other purpose(s) specifically permitted Data Protection Laws.
GPM will notify data subjects of those purposes when data is first collected or, where not possible, as soon as possible thereafter.
GPM will only process personal data to the extent required for the purposes provided to the data subject. This means that GPM may not ask for, or record in its systems, more personal data than is needed. The Company has appropriate technical and organizational measures in place to ensure that personal data that is no longer needed is erased or destroyed.
The Company also employs reasonable measures to ensure that any personal data held is accurate and kept up to date. GPM aims to check the accuracy of any personal data at the point of collection and at regular intervals afterwards. The Company will take all reasonable steps to erase, destroy or amend inaccurate or out-of-date data without undue delay and, in any event, within one month of a data subject’s request (or for up to three months where there are specific reasons why one month is not possible).
Paper records that contain personal data must be shredded and disposed of securely when there is no longer a need to retain them. Paper records containing personal data may not be disposed of in any other manner.
When deleting electronic personal data, all possible steps should be taken to put the data in question beyond use. Where it is impossible to delete personal data altogether, reasonable steps must be taken to ensure the data is deleted to the fullest extent possible.
IT is responsible for destroying or erasing electronic equipment that contains personal data (e.g. laptops, desktops, company-owned mobile devices, and work data on BYOD devices).
When the Company processes personal data, it takes reasonable measures to ensure data remains secure and is protected against unauthorized or unlawful processing, accidental loss, destruction or damage.
GPM does this by:
In assessing the appropriate level of security, GPM considers the risks associated with the processing, in particular the risks of accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to the personal data that is processed.
Where GPM engages third parties to process personal data on its behalf, such parties do so based on written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organizational measures to ensure data security. Personal data may not be shared with anyone outside of GPM or authorized third parties.
Desks and cupboards are kept locked if they hold personal data or confidential information of any kind. Data users ensure that individual monitors/screens do not show personal data or confidential information to passers-by and that they log off from or lock their computers/tablets when left unattended.
A Personal Data Incident can happen in many ways, including:
Colleagues who become aware of or have any reason to suspect that a Personal Data Incident has occurred or is about to occur must immediately contact their immediate report or email
In the event of an actual or imminent Personal Data Incident, GPM takes quick action to minimize the impact of the incident and report the incident if required by law. In most cases, the response will involve:
GPM utilizes multiple server locations to store and back up personal data. For server locations utilized by third parties with whom GPM engages to process personal data on behalf of colleagues and customers, consult the relevant data protection impact assessments for colleague personal data and the external sub-processor page and product privacy notices for customer personal data. These documents are all located either internally on the Compliance page or externally on the Legal & Compliance site under the Data Privacy icons. For a current list of corporate data server locations, colleagues may also reach out directly to IT.
Under the GDPR, GPM may transfer personal data to countries outside the European Economic Area (“EEA”) where there is an adequate level of protection in that country or where GPM has put appropriate measures in place to ensure data protection.
Companies within the GPM group (i.e., all corporate entities and subsidiaries) must enter into the Intra-Group Data Transfer Agreement in order to ensure appropriate safeguards for the transfer of personal data outside the EEA, but within the GPM group.
Companies outside of the GPM group who process personal data for or on behalf of GPM, for which GPM acts as a data controller or data processor, must enter into a data processing agreement with GPM to ensure appropriate safeguards for the transfer of personal data outside the EEA. That agreement contains language to ensure the third party has appropriate technical and organizational measures in place to comply with the GDPR and to ensure the protection of data subject rights.
Instances where GPM transfers personal data to a country outside the EEA may include:
For each transfer of data outside the EEA, GPM will rely upon the Standard Contractual Clauses as defined by the European Commission (2001/497/EC, 2004/915/EC and 2010/87/EU).1 Note that a data transfer agreement is also required if transferring personal data outside of the United States.
GPM is required to provide information to data subjects about the processing of their personal data. This information is contained in the Company’s Web Privacy Statement which is publicly available at www.greenprojectmanagement.org and the Employee Privacy Statement, which is available on the GPM intranet. Such statements provide information about:
NOTE: 1 As of December 27, 2022, these transfers will be effected using the new standard contractual clauses as outlined in the Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council.
If GPM receives personal data about a data subject from a third party, the Company will also provide the data subject with information on:
Data Protection Laws require GPM to consider data protection during the development stages of a new product offering. In order to satisfy this obligation, GPM must take steps to ensure
data protection is part of the design process and personal data collection is minimized to the
extent possible.
In some circumstances (namely, when processing would result in a high risk to an individual’s rights and freedoms), GPM may be required to undertake a formal data protection impact assessment (DPIA) in relation to the processing of personal data. Such an assessment involves documenting the purposes for which the activity is carried out, how GPM will comply with data protection laws, and how the Company will mitigate potential risks to individuals’ privacy. If you believe a data protection impact assessment may be needed, contact the Compliance Director at
If GPM processes personal data, under Data Protection Laws, the data subject may have the right to:
notwithstanding an objection if the Company’s legitimate interests outweigh those of the data subject, or if GPM needs to do so for the establishment or defense of a legal claim;
GPM will assess the data subject’s rights under applicable data privacy legislation on a case-by-case basis in determining how to fulfill a data subject access request. In general, GPM will use a data subject’s rights under the EU GDPR as a baseline for fulfilling requests and applying rights available under applicable data privacy legislation to the extent those are more favorable towards the data subject. If a data subject exercises these rights and GPM has disclosed the personal data in question to a third party, the Company will do its best to ensure that the third party also complies with the wishes of the data subject.
Data subjects who wish to request information about the personal data GPM holds about them may do so by submitting a Data Subject Access Request (DSAR). If colleagues receive a request directly (whether verbally or in writing), immediately forward details of the request to
GPM provides its employees and contingent workers with access to training about data protection responsibilities. This training occurs at onboarding and at regular intervals thereafter.
Contact information for relevant data supervisory authorities varies by location.
If you have questions about GPM’s Privacy Information Management System, please contact:
GPM
Attention: Compliance Director
41592 Orianna Ln
Novi MI 48375 USA
Email:
Those subject to the Code must avoid any situation in which they have, or appear to have, an interest that conflicts with the best interests of GPM. Conflicts of interest can arise in situations where the colleague or a member of the colleague's immediate family have an interest or relationship (financial, employment, or otherwise) that may have an adverse effect on GPM or may unduly influence the colleague's exercise of independent judgment due to considerations of personal gain or benefit.
While it is impossible to list every situation in which an actual or apparent conflict of interest may exist, GPM considers the following activities to be conflicts of interest. As such, colleagues are prohibited from engaging in these activities without receiving prior written approval from the President or their designee:
The exchange of gifts and entertainment can create improper influence (or the appearance of improper influence) and must be in accordance with this policy.
Gifts and entertainment means anything of value, e.g. loans, favorable terms on a product or service, prizes, use of another company's vehicles, tickets, gift certificates, use of vacation facilities, stocks, other securities or participation in stock offerings. Entertainment is considered a gift, subject to these guidelines, when the giver or representative from the giving organization will not accompany you to the event. Gifts and entertainment between GPM colleagues and others fall into three categories:
Some gifts and entertainment are sufficiently modest that they do not require prior approval. Think through the intent (e.g., Is it normal courtesy or to build a business relationship versus influencing the recipient's objectivity in making a business decision?), materiality, frequency and transparency (e.g., Would you be embarrassed if your manager, colleagues or anyone else outside GPM became aware?). The following are usually acceptable without prior approval:
Other types of gifts and entertainment are never permissible. They are:
For anything that does not fit into the other categories, the gift or entertainment may or may not be permissible. You must get approval from your manager or Strategic Leadership Team member as appropriate for the following:
Any entertainment valued at more than $500 USD (or gifts over $250 USD) must be approved by the GPM President.
In some departments or regions, more restrictive guidelines or rules on gifts and entertainment may apply. Colleagues must be careful not to accept gifts or entertainment that do not comply with these guidelines or rules.
It is acceptable to receive a gift that exceeds a designated monetary limit if it would be insulting to decline, but the gift must be reported to management who will decide whether it:
You must immediately return any gift of cash or a cash equivalent such as a bank check, money order, or negotiable instrument.
The nature of GPM's business requires colleagues and third parties with whom we do business to interact regularly with government officials and private sector customers. Applicable anti-corruption laws (e.g., the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, the US Foreign Corrupt Practices Act (FCPA), the International Travel Act, the UK Bribery Act, and Canada's Corruption of Foreign Public Officials Act (COFPA)) establish certain rules and restrictions on those interactions in all countries where GPM does business.
GPM prohibits paying, offering to pay, promising to pay or authorizing the payment of money or anything of value, directly or indirectly, to any government official or private sector customer in order to secure an improper business advantage. GPM also strictly prohibits any colleague from soliciting or accepting a bribe from any individual or entity as a GPM colleague. International law prohibits all of the above-anti-bribery laws that are not just restricted to offers of improper payment to government officials. Additionally, requests for improper payments are often accompanied by illegal activities such as tax evasion, money laundering or anti-competitive behavior, including, but not limited to, price-fixing, fraud, and bid-rigging. GPM strictly prohibits colleagues from knowingly facilitating or assisting government officials or private sector clients in violating the law.
GPM is legally responsible for any corrupt actions by third parties contracted to represent GPM or otherwise perform services on its behalf. As such, GPM must understand the qualifications and associations of its third-party partners to ensure that it only does business with reputable third parties who act with integrity and deliver quality products and services. Prior to contracting with a third party for goods or services, appropriate due diligence must be conducted.
GPM's Due Diligence Questionnaire must be completed prior to contracting and vetted with the Compliance Director if any of the following apply:
Additionally, contracts to retain third parties must contain a contractual commitment to comply with all laws and regulations including, but not limited to, anti-corruption laws such as the US FCPA, the International Travel Act, the UK Bribery Act and Canada's COFPA.
While the following risk factors do not automatically disqualify a third party from working with GPM, you should carefully consider whether to establish a relationship with a third party that exhibits one or more of the following characteristics as these may be indicative of corrupt behavior:
GPM values its reputation for ethical behavior and recognizes that engaging in bribery or other corrupt behavior would undermine customer and colleague trust. No GPM colleague or third party will ever suffer adverse consequences for refusing to pay a bribe or for refusing to engage in otherwise corrupt behavior, even if GPM loses business as the result of such refusal.
For direct and indirect suppliers, additional due diligence requirements may exist. Depending on the type of service or product the third party will provide, due diligence may be required to ascertain whether the third party has adequate information security controls and data privacy protections or to ensure the third party complies with relevant government regulations. An assessment may also be required to determine whether the new third-party service or product is needed as GPM works where possible to leverage existing business relationships.
GPM is committed to conducting business in compliance with laws governing competition. Violation of these laws may result in civil and criminal liability not just for the Company but also for the individuals involved.
Engaging in any of the following activities is strictly prohibited:
GPM colleagues who arrange, approve or effect any export or import of products, services, or information must coordinate with Global Trade Compliance to ensure that the transaction is compliant with all applicable legal requirements, and that all documentation and record-keeping requirements have been satisfied.
GPM must comply with laws that prevent US companies from being used to implement foreign policies of other nations that run counter to US policy. As a result, GPM is prohibited from refusing or agreeing to refuse to do business with or in a boycotted country, with any business organized under the laws of a boycotted country, with any national or resident of a boycotted country, or with any person who has dealt with a boycotted person or country, when refusal is due to an unsanctioned foreign boycott.
US regulations require that the mere receipt of a boycott request be reported in a timely manner. GPM must report a request even if the Company does not comply with the requested action or the request is withdrawn. If you receive a boycott-related request, immediately contact the Legal Department.
GPM colleagues must commit to protecting the confidentiality of the Company's proprietary information as well as confidential information received from third parties. Confidential information is not to be disclosed unless there is a business need to do so and the party who will receive the confidential information has signed an appropriate nondisclosure agreement. All confidential information disclosed under an appropriate nondisclosure agreement must be clearly labeled as "confidential" at the time of disclosure.
GPM confidential information is any information that GPM does not wish to have displayed publicly or that the Company has determined has economic value to GPM. Examples include:
Colleagues should be careful to protect confidential information in meetings that include individuals outside of GPM, correspondence (including email), telephone calls and at restaurants, trade shows and in other circumstances where third parties could overhear or obtain confidential information.
GPM maintains an adequate and uniform system of accounting, reporting, and auditing controls in order to protect GPM's assets and ensure the accuracy and reliability of its financial records. GPM's financial reports must reflect a full, fair, accurate, timely and comprehensible disclosure of GPM's financial position and results.
As a result, all colleagues are responsible for keeping accurate accounts, books, ledgers, journals, and records. In addition, colleagues must:
As a business and an employer, it is necessary for GPM to process personal data about colleagues, contingent workers, customers, suppliers and other third parties with whom we engage to provide products or services on our behalf. With the introduction of the European General Data Protection Regulation (GDPR) and other applicable laws governing data protection, GPM is subject to enhanced requirements for processing personal data.
Personal data is data relating to a living individual who can be identified (directly or indirectly) from that data (or from that data combined with other information in GPM's possession or available to GPM). Personal data can be factual (e.g., name, address, date of birth) or it can be an opinion about the individual and their actions or behavior (e.g., colleague performance assessment). Personal data can also include identification numbers, location data, online identifiers, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social status of an individual.
Processing describes activities performed with respect to personal data such as collecting, recording, organizing, structuring, storing, adapting, altering, retrieving, consulting, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting use, erasing or destroying data. Processing also includes transferring or disclosing personal data to third parties.
If you are responsible for developing new GPM products and service offerings, contact the Legal Department and Information Security to consider what personal data the product or service will process at the outset of development and build in appropriate technical and organizational safeguards regardless of whether the product is on-premise or cloud-based/hosted. Personal data may be processed by the product itself or it may be processed for purposes of providing customer service and support. Not only does GPM comply with its own obligations under existing data privacy laws, but the Company strives to assist its customers in meeting their obligations by designing products and services that make compliance simple.
In addition to GPM's obligations to lawfully process personal data, the Company also has an obligation to ensure that any third parties used to process data on our behalf do so in accordance with our instructions and in compliance with relevant data privacy legislation. Contact Legal if you engage a third party that will process personal data on behalf of GPM. We must ensure (typically through a mutually-agreed upon data processing agreement) that the third party has adequate measures in place to safeguard the personal data we provide to them for processing.
GPM appreciates the value of thoughtful engagement with the public. For that reason, GPM has designated spokespeople who may formally represent the Company in the media, with analysts or on social forums.
Colleagues engaging in personal social media or other online activities are responsible for acting professionally and ethically when referring to GPM or information related to employment with the Company. Colleagues are prohibited from posting discriminatory, harassing or threatening content or divulging non-public, sensitive information about the Company that is financial, legal or operational in nature or that contains customer or other information governed by GPM's data protection policies. Colleagues are expected to act responsibly, respectfully and with due care.
GPM is committed to creating and maintaining a quality working environment in which all individuals are treated with respect and dignity. Everyone has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits discrimination and harassment. GPM strictly adheres to all applicable labor and employment laws in every country in which we operate.
Even minor, unintentional inequities can, if they become a pattern of behavior, have a negative effect on workplace culture. Be mindful of behavior that may constitute discrimination including, but not limited to, the following:
GPM strives to provide an inclusive environment where colleagues feel appreciated for their unique characteristics and are comfortable sharing their ideas and authentic selves. Our diversity and inclusion program is aimed at celebrating, educating, and empowering all colleagues and cultures we represent.
It is GPM's policy and the responsibility of every colleague to maintain a safe workplace free from threats and acts of violence. Colleagues, contractors, and vendors associated with GPM are prohibited from making threats or engaging in aggressive or violent activities. This includes, but is not limited to, bullying behavior that undermines, patronizes, humiliates, intimidates, or demeans the recipient; stalking in person, in writing, by telephone or in electronic format; making threats; or engaging in physical attacks or property damage. The possession of weapons in the workplace while conducting Company business or at any Company-sponsored function is strictly prohibited.
GPM is committed to providing a safe and drug-free work environment for our customers and colleagues. With this goal in mind, the Company explicitly prohibits colleagues and contractors from:
Colleagues are expected to report unsafe working conditions, including any suspicions that a colleague may be impaired in the workplace. Be aware that what looks like impairment may also be due to medical conditions (e.g., diabetes, epilepsy, or a stroke), the use of medications taken as prescribed, psychological factors, and/or fatigue which is why it is important to report your concern and allow the Company to conduct an independent investigation.
GPM is committed to maintaining high-quality standards for our products and services. This is achieved through a culture of continuous improvement and identifying and implementing effective practices and processes to provide products and services that support customer and shareholder objectives.
In support of that effort, GPM has audited annually to International Standard ISO 9001:2015 standards. In addition, cross-functional teams work continuously through efforts such as the D5 development process, assessment and control of the supplier base, manufacturing control processes, and customer feedback loops to ensure GPM can monitor relevant components of Quality and continue to improve the way we do business.
GPM is committed to being an outstanding corporate citizen and to minimizing the impact of our business, products, and services on the environment. GPM accomplishes this through operation of an Environmental Management System (EMS) that is audited annually to International Standard ISO 14001:2015. This ISO standard sets forth the elements of an organizational structure that ensures adherence to applicable environmental standards and regulations as well as monitors and sets goals for continuous improvement.
At GPM, Safety is a high priority. For the well-being of each individual and the organization, all colleagues must be conscious of safety risks and take reasonable steps to mitigate those risks where possible. Maintaining a culture of safety requires a team effort to identify and correct unsafe conditions. Colleagues are encouraged to report hazards and safety concerns to their managers so that GPM can continue to build and maintain a safe and efficient workplace.
GPM is committed to the highest possible standards of ethical, moral and legal business conduct. In conjunction with this commitment, you must report serious concerns of wrongdoing or danger in relation to business activities that could have a large impact on the Company, such as actions that:
GPM will not tolerate harassment or victimization of an individual based on knowledge or suspicion that the individual has reported a concern either through the Ethics Hotline or directly to management, Legal or Human Resources. If you feel that you have been retaliated against for raising a complaint in good faith, you should immediately notify your manager or Human Resources.
Failure to comply with the provisions of this Code of Ethics may result in disciplinary action, up to and including termination.
Thank you for everything you do to ensure we remain a trusted partner to our customers and to one another. If you have questions about the Code of Ethics, please email us at
See also our Digital Sustainability Policy.
At GPM, we understand the immense power and potential of Artificial Intelligence (AI). As we harness this technology to create innovative solutions, we also acknowledge that with great power comes great responsibility.
We pledge to use AI responsibly, ethically, and transparently. We will always prioritize the privacy, security, and well-being of our users, customers, and partners.
We commit to respecting and upholding human rights in all our AI-powered endeavors. We will ensure that our AI systems do not discriminate, marginalize, or harm individuals or groups.
We promise transparency about how, why, and where we use AI. We will hold ourselves accountable for our AI systems' impact and continually seek ways to improve their performance and safety.
We will protect the privacy and security of our users' data. We will use AI only for purposes that our users have explicitly consented to, and we will never share user data without explicit permission.
We will constantly strive to learn more about the ethical implications of AI, and we will continually improve our practices based on these learnings.
We will foster a culture of open dialogue and collaboration around AI ethics. We invite user, employee, and stakeholder feedback to help us shape our responsible AI practices. By making this pledge, we hope to create a future where AI serves humanity responsibly, ethically, and beneficially. We invite you to join us on this journey.
Updated March 12, 2025
At GPM, we are committed to regenerative development—an approach that moves beyond sustainability to actively restore, enhance, and revitalize the natural world. Our goal is not merely to reduce harm, but to create thriving ecosystems, resilient communities, and flourishing living systems.
This policy establishes our dedication to:
We embrace the interdependence of human and natural systems, embedding planetary stewardship into every aspect of our operations, partnerships, and decision making.
GPM commits to climate-positive actions that go beyond carbon neutrality by actively removing more carbon than we emit.
As signatories of the UN Global Compact CEO Water Mandate, GPM is committed to water regeneration—ensuring that our operations and projects contribute to the restoration and protection of global water cycles.
GPM recognizes that true sustainability is not just about reducing harm but actively restoring biodiversity and ecological resilience.
To eliminate waste and regenerate resources, GPM commits to designing closed-loop systems that mimic nature’s cycles.
To ensure that our commitments translate into action, we will establish strong governance and oversight mechanisms.
Regenerative development requires collective action. GPM will lead by example and engage stakeholders at all levels to drive meaningful change.
GPM is not just committing to sustainability—we are committing to a fundamentally new way of thinking and acting. Our role is not to minimize damage but to actively heal, restore, and regenerate.
At GPM, we believe that projects can be life-giving—not neutral, not less harmful, but actively restoring the Earth, rebuilding ecosystems, and revitalizing communities.
This isn’t just our policy.
It’s our ethos.
It’s who we are.
Updated March 12, 2025
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