Our Company's long-standing commitment to doing business with integrity means avoiding corruption in any form, including bribery, and complying with the anti-corruption laws of every country in which we operate.

For the Coca-Cola Company and our entire system, the Code of Business Conduct and Anti-Bribery Policy provide guidance on how to conduct business in a fair, ethical and legal manner. Our anti-corruption compliance program encompasses numerous reporting, monitoring and certification controls, as well as an education component comprising both web-based and in-person training.

Global Anti-Bribery Policy

Our global Anti-Bribery Policy—most recently revised in June 2016—establishes the limitations we must adhere to when interacting with officials of various governments around the world. The policy provides information about anti-bribery laws in order to avoid inadvertent violations. In order to protect our Company’s reputation, it is vital that we not only understand and appreciate the importance of this policy, but comply with it in our daily work. In 2016, we modified our ethical conduct training program to reflect the updated Anti-Bribery Policy,

Anti-Bribery Efforts

We conduct periodic anti-bribery assessments and audits of our business to raise overall awareness, detect potential misconduct and monitor compliance with anti-corruption laws and policy. We annually review practices at high risk operational units for compliance with our Anti-Bribery Policy. We periodically engage independent third parties to perform assurance procedures to ensure our anti-bribery compliance program elements are functioning properly and to identify best practices that we can implement broadly. We continue to leverage opportunities to share learnings and successful practices across our system.

Additionally, we have a global due diligence program to screen vendors and potential vendors deemed to be high risk and to obtain their agreement to abide by our Anti-Bribery Policy. We refreshed our training in 2012 and continue to direct resources to training and support in order to assist local management in avoiding corruption.

In Myanmar, for example, it is not uncommon for the traffic police and other government employees to request facilitation payments (small payments to low-level officials to speed routine interactions or approvals) from commercial drivers. The company whose operation we acquired was not immune to this practice. We determined that on a certain date following our acquisition, with training preceding, we would end this practice of facilitating payments altogether. We reviewed local processes and implemented necessary mitigation practices, including training programs, the development of local-language cards that drivers can provide to authorities that state our policy prohibiting such payments, and reviews to ensure that our vehicles are appropriately maintained, roadworthy and licensed.

We continue our efforts to root out corruption in partnership with governments whenever possible. In December 2013, The Coca-Cola Company was the first company to sign a Memorandum of Understanding (MOU) with the Anti-Corruption Unit of the Cambodian government. As of September 2016, 22 companies and one trade association had signed MOUs. The hope is that this opportunity to publicly show commitment to ethical business practices will gain momentum. Our commitment helps us build trust with our stakeholders in Cambodia, and provides clear direction to our workforce in the country. As a result, The Coca-Cola Company was named the Best Group Trader by the General Department of Customs and Excise of Cambodia.

Global Corruption Risk Mapping

Using our enterprise risk management system and data from Transparency International, we annually build a model to map risks of corruption and bribery. We review internal factors, including capital expenditures and past audit results, as well as relevant external factors. With input from senior management and corporate audit teams, we are able to determine where to focus our anti-corruption efforts. Understanding both the culture and the level of risk in these markets helps us prevent and root out unethical conduct while being sensitive to and respectful of local cultures.

In 2015, we reviewed all of our operations through this process for risks related to corruption and continued to refine the risk criteria in the model.

Global Anti-Corruption Partnerships

As a signatory to the United Nations Global Compact, we are actively engaged with other companies and nongovernmental organizations in the fight against corruption. In December 2007, we became a signatory to the World Economic Forum Partnering Against Corruption Initiative (PACI), making The Coca-Cola Company the first food and beverage company to join approximately 140 other multinational companies in the private sector fight against corruption.

The PACI's mission is to develop multi-industry principles and practices that will result in a competitive, level playing field, based on integrity, fairness and ethical conduct. The PACI requires CEO commitment to zero tolerance for bribery and a commitment to implement a practical and effective anti-corruption program within their company.

Anti-Corruption Toolkit

Coca-Cola’s anti-corruption program extends across our system. Our comprehensive program includes rigorous reporting, monitoring, certification, and education components. In order to help our bottling partners meet our expectations of doing business ethically and fairly, we have developed an Anti-Corruption Toolkit.

Our aim with this toolkit is to foster complete Coca-Cola system alignment about our global commitment to anti-corruption. In 2014, the English language version of this comprehensive toolkit was made available to our bottlers. The toolkit provides due-diligence processes for selecting, training and embedding ethical business practices within bottling partners’ operations. It covers 24 diverse scenarios that a bottler might encounter and ways to handle those scenarios. It also includes compilations of applicable laws, including The Foreign Corrupt Practices Act, and recommendations for educating and supporting all employees in anti-corruption behavior.