We are committed to building an ethical business culture throughout the entire Coca-Cola system. To ensure we conduct our business with honesty and integrity, our starting point is to comply with all anti-corruption laws of every country in which we operate.
Our Code of Business Conduct
Our Company’s Code of Business Conduct serves as the foundation of our approach to ethics and compliance. It clearly states our expectations of accountability with regard to ethical conduct in all areas of our business. All of our Company and majority-owned subsidiary associates are required to read, understand and adhere to the Code’s precepts, both in the workplace and in the larger community. Launched in 1978, our Code of Business Conduct is currently available online in 22 languages, as well as offline in an additional 10 Indian languages/dialects.
Our Company's anti-corruption compliance program is dedicated to ensuring that business throughout the Coca-Cola system is conducted in a fair, ethical and legal manner. This means avoiding corruption in any form, including bribery. Our Code of Business Conduct and Anti-Bribery Policy give guidance on operating with honesty and integrity. They clarify our expectations that anti-corruption laws are adhered to every country in which we operate.
Ethics Codes and Principles for Non-Employee Directors and Suppliers
We have also published a Code of Business Conduct for Non-Employee Directors, which comes from the same principles and values as the Company’s Code of Business Conduct for employees. Our Supplier Code of Business Conduct and Supplier Guiding Principles set baseline expectations for how our suppliers conduct their business.
Ethical Conduct Administration
The Code of Business Conduct is administered by our Ethics & Compliance Committee. This cross-functional senior management team oversees all our ethics and compliance programs and determines Code violations and discipline. Our Ethics & Compliance Office has operational responsibility for education, consultation, monitoring and assessment related to the Code of Business Conduct and compliance issues. Associates worldwide receive a variety of ethics and compliance training courses administered by the Ethics & Compliance Office. We regularly monitor and audit our business to ensure compliance with the Code and the law. We also maintain a consistent set of best-in-class standards around the world that govern how we investigate and handle Code issues. In 2008, we revised the Code to further improve its effectiveness, and in 2012 we updated the Code to improve its effectiveness and incorporate requirements under the UK Bribery Act.
Ethical Conduct Training
To ensure an ongoing commitment to and understanding of our Code of Business Conduct, we offer online training to all associates with Company-provided computers, covering topics related to ethics and compliance, including our Anti-Bribery Policy. All newly hired associates receive the training upon hire and all others receive the training at least once every three years. In 2015, more than 32,000 employees (management and non-management) certified their compliance with the Code of Business Conduct and the Company's anti-bribery requirements. In 2016, we modified this training program to reflect our updated Anti-Bribery Policy, which was revised in June 2016.
In addition to a number of optional training courses on various topics, associates are requested to participate in ethics training on an annual basis, resulting in a minimum of 60 minutes of required ethics training per associate per year.
EthicsLine is a global online and telephone information and reporting service that is available to all of our associates, bottling partners, suppliers, and consumers so they may ask questions about ethics and compliance issues. It is available 24 hours a day, seven days a week, with translators available, as a means for individuals to report potential violations.
Building Ethical Business Practices in High-Risk Areas
We are committed to building an ethical business culture throughout the Coca-Cola system, particularly focusing on the business we conduct in countries and territories where there may be a higher risk of unethical behaviors. For example, in 2014 we conducted anti-bribery risk assessments in Vietnam, Cambodia and Myanmar.
Additionally, we have developed a number of programs to address anti-corruption issues around the world.
In Vietnam, in 2015 we refined the format for our ethics training program. Employees with access to the internet participate in an online training module; those who don’t are provided in-person classroom training. One hundred percent of employees in Vietnam and Cambodia completed the training in 2015, which enables them to confidentially communicate their concerns and report any requests they have received for facilitation payments. We are working to expand this training program over time across Vietnam, Cambodia and Myanmar.
Following our successful implementation of a robust due diligence process at our new plant in Myanmar, we were named by the U.S. State Department as the sole company to satisfy its requirements for responsible reporting and transparency by multinational corporations. Establishing an ethical business culture is a continuous process requiring regular training, engagement and systematic due diligence.
We provided our drivers with anti-bribery training, and we also launched a certification process for our Code of Business Conduct and Workplace Rights. This certification requires employees to take a nine-question survey, which provides verification of compliance with our policies and a means for workers to confidentially report any concerns they may have.
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