While not every employee will be (or needs to be) an expert in accounting or finance, each IBMer needs to understand the financial and compliance implications of their responsibilities and that they are required to ask questions or raise concerns to their managers, IBM’s legal counsel, or IBM’s senior management, if necessary. updates to the ibm business conduct guidelines The Business Conduct Guidelines are regularly reviewed to determine they reflect the current issues and situations that could arise in our business or have occurred for others in our industry or across industries.