ACT WITH
INTEGRITY
THE PEPSICO WAY
PEPSICO GLOBAL CODE OF CONDUCT
INTRODUCTION
3
Our Mission and Vision . . . . . . . . . . . . . . . . . .
4
ACT WITH INTEGRITY
5
Why Do We Have a Code of Conduct? . . . . . . . . .
6
Who is Responsible for Our Code? . . . . . . . . . . .
6
What is My Personal Responsibility? . . . . . . . . . . .
7
How to Act with Integrity . . . . . . . . . . . . . .
7
Lead by Example . . . . . . . . . . . . . . . . . .
8
How Can I Seek Guidance and Report Violations? . . .
9
Speak Up Hotline . . . . . . . . . . . . . . . . . . . . .
10
Investigating Misconduct and Disciplinary Action . . .
11
Retaliation is Prohibited . . . . . . . . . . . . . . . . .
11
IN OUR WORKPLACE
12
Inclusion for Growth . . . . . . . . . . . . . . . . . . .
13
Human Rights . . . . . . . . . . . . . . . . . . . . . . .
14
Anti-Discrimination/Anti-Harassment . . . . . . . . .
15
Environment, Health and Safety . . . . . . . . . . . .
16
Substance Abuse . . . . . . . . . . . . . . . . . . . . .
17
Anti-Violence . . . . . . . . . . . . . . . . . . . . . . .
17
IN OUR MARKETPLACE
18
Our Consumers . . . . . . . . . . . . . . . . . . . . . .
19
Food Safety and Product Quality . . . . . . . . .
19
Responsible Marketing . . . . . . . . . . . . . . .
20
Our Customers . . . . . . . . . . . . . . . . . . . . . .
21
Our Suppliers . . . . . . . . . . . . . . . . . . . . . . .
21
Fair Competition . . . . . . . . . . . . . . . . . . . . .
22
Anti-Bribery . . . . . . . . . . . . . . . . . . . . . . .
23
Identifying Government Officials . . . . . . . . .
24
Business Gifts . . . . . . . . . . . . . . . . . . . . . .
25
Anti-Money Laundering . . . . . . . . . . . . . . . . .
26
International Sanctions and Trade Controls . . . . .
26
IN BUSINESS
27
Maintaining Accurate Business Records . . . . . . . .
28
Records Retention . . . . . . . . . . . . . . . . .
28
Financial Accuracy . . . . . . . . . . . . . . . . .
29
Financial Disclosures and Audits . . . . . . . . .
29
Privacy . . . . . . . . . . . . . . . . . . . . . . . . . .
30
ArtificiaI Intelligence . . . . . . . . . . . . . . . . . . .
31
Proper Use and Protection of Company Resources .
32
Physical Property and Financial Resources . . .
32
Electronic Assets . . . . . . . . . . . . . . . . . .
33
Intellectual Property . . . . . . . . . . . . . . . .
34
Protecting PepsiCo Information . . . . . . . . . .
35
Insider Trading is Prohibited . . . . . . . . . . . .
36
Conflicts of Interest . . . . . . . . . . . . . . . . . . .
37
Communicating with the Public . . . . . . . . . . . .
38
Public Speaking and Press Inquiries . . . . . . .
38
Social Media . . . . . . . . . . . . . . . . . . . .
39
IN OUR WORLD
40
pep+ (PepsiCo Positive) . . . . . . . . . . . . . . . . .
41
The PepsiCo Foundation . . . . . . . . . . . . . . . . .
41
Be a Good Citizen . . . . . . . . . . . . . . . . . . . .
42
Political Activities . . . . . . . . . . . . . . . . . . . .
42
RESOURCES
43
PepsiCo Global Compliance & Ethics Department . .
43
PepsiCo Law Department . . . . . . . . . . . . . . . .
43
Act with Integrity
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PepsiCo Global Code of Conduct
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Introduction
I am pleased to present PepsiCo’s Global Code of
Conduct. Our Code defines how we do business
the right way anchored by our strong ethical
culture: what we call The PepsiCo Way. One of
the key behaviors of The PepsiCo Way is Acting
with Integrity in everything we do. That’s because
integrity is among PepsiCo’s most valuable assets.
It is critical to maintaining our reputation with
our stakeholders, ensuring equal employment
opportunities,
sharpening our competitive
advantage and driving long-term growth.
And while a culture of integrity and ethics takes
years to build, it takes just a moment to lose. So,
that culture cannot be taken for granted. We must
invest in it consistently, day after day, year after
year. That’s why every PepsiCo employee must
follow our Global Code of Conduct. By doing so,
we not only strengthen our ethical culture, we
also build trust with fellow employees, customers,
consumers, investors and communities, helping us
win in every market we serve.
Thank you for your commitment to this critical
effort — a commitment that will help ensure
PepsiCo remains one of the most respected,
ethical and successful companies in the world.
Sincerely,
Ramon Laguarta
Chairman and Chief Executive Officer
ACT WITH INTEGRITY
THE PEPSICO WAY
Act with Integrity
Introduction
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PepsiCo Global Code of Conduct
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Introduction
OUR MISSION AND VISION
At PepsiCo, our mission is simple:
Create More Smiles with Every Sip and Every
Bite
. Every action we take and decision we make must be in service to this
ambition as we strive to achieve our vision
To Be the Global Leader in Convenient
Foods and Beverages by Winning with pep+ (PepsiCo Positive)
.
We will get there by working together, as One PepsiCo, united by a set of
behaviors that define our culture.
FASTER
by winning in the marketplace, being more consumer-centric and
accelerating investment for topline growth.
STRONGER
by transforming our capabilities, cost and culture by operating as One
PepsiCo, leveraging technology, winning locally and globally enabled.
BETTER
by continuing to integrate our purpose agenda into our business strategy
and doing even more for the planet and people.
The PepsiCo Way drives our employees and our business to become Faster,
Stronger and Better to advance us toward our mission and vision.
WE CALL THIS
THE PEPSICO WAY
.
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PepsiCo Global Code of Conduct
Act with Integrity
Introduction
ACT WITH INTEGRITY
Why Do We Have a Code of Conduct? . . . . . . . . .
6
Who is Responsible for Our Code? . . . . . . . . . . .
6
What is My Personal Responsibility? . . . . . . . . . . .
7
How to Act with Integrity . . . . . . . . . . . . . .
7
Lead by Example . . . . . . . . . . . . . . . . . .
8
How Can I Seek Guidance and Report Violations? . . .
9
Speak Up Hotline . . . . . . . . . . . . . . . . . . . . .
10
Investigating Misconduct and Disciplinary Action . . .
11
Retaliation is Prohibited . . . . . . . . . . . . . . . . .
11
ACT WITH
INTEGRITY
THE PEPSICO WAY
At PepsiCo, we believe that Acting with
Integrity is not only the right thing to
do; it’s the right thing to do to make our
business Stronger.
Our Global Code of Conduct is the
foundation of our commitment to ethical
excellence and provides the policies and
guidelines that define how we do business
the Right Way – The PepsiCo Way.
PepsiCo Global Code of Conduct
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WHO IS RESPONSIBLE FOR OUR CODE?
Whatever your role is at PepsiCo, the principles of our Code should be at the core of every business
decision you make. Our Code applies to everyone in our company, everywhere, from our offices, plants
and warehouses to the boardroom, including:
• All PepsiCo employees, including employees of PepsiCo’s consolidated subsidiaries.
• Members of the PepsiCo Board of Directors when they act in their capacity as directors.
Our company’s Board of Directors is responsible for adopting our Code. PepsiCo’s
Global Compliance & Ethics Department is accountable for promoting,
monitoring and enforcing it.
Any waiver of our Code requires the prior written approval of the Global
Chief Compliance & Ethics Officer or, in certain circumstances, the Board
of Directors or a committee thereof. Waivers will be promptly disclosed
as required by applicable law.
RESPECT
IN THE WORKPLACE
TRUST
IN THE MARKETPLACE
FAIRNESS
IN OUR BUSINESS RELATIONSHIPS
HONESTY
IN BUSINESS CONDUCT
PURPOSE
IN OUR WORLD
WHY DO WE HAVE A
CODE OF CONDUCT?
PepsiCo’s Global Code of Conduct provides a road
map of the policies, standards and procedures
that govern how we do business around the world.
By following our Code and always Acting with
Integrity, you play an integral role in supporting
our culture of ethical excellence.
Our Code outlines the company’s commitment to
ethical practices in all aspects of our business:
This Code of
Conduct does not
constitute a contract or
guarantee of employment
for any period of time
or create any specific
employment rights.
PepsiCo Global Code of Conduct
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RESPECT AND FOLLOW PEPSICO’S
CODE OF CONDUCT
ALWAYS DO WHAT IS RIGHT
LEAD BY EXAMPLE AND
EMPOWER OTHERS TO DELIVER
BEHAVE IN A TRANSPARENT
AND AUTHENTIC WAY
BE ACCOUNTABLE FOR YOUR ACTIONS
WHAT IS MY PERSONAL
RESPONSIBILITY?
ACT WITH INTEGRITY
AND FOLLOW OUR CODE
Our reputation for acting ethically and
responsibly is built one decision at a time,
every day, by each of us. Our Code, together
with our company policies, gives you the
information needed to perform your job
ethically. It is your responsibility to Act as
Owners and understand and comply with
the policies that apply to the work you do
and the decisions you make.
As a global business, PepsiCo is also
committed to complying with the laws of the
countries where we operate. Global laws and
regulations are complex; following our Code
and policies will help ensure your compliance
with applicable local laws.
To access all policies referenced in our Code,
please visit the Policies page on
HOW TO ACT WITH INTEGRITY
At PepsiCo, we pride ourselves on our ability to Focus and Get Things Done Fast, but you must never allow the
pursuit of ambitious business goals to cause you to lose sight of the ethical aspects of decision-making. Part of
Acting with Integrity means doing the right thing even when no one is looking. It is easy to be tempted by seemingly
small ethical shortcuts that others would be unlikely to notice. Acting with Integrity is not only about following the
rules; it is being guided by your own moral principles.
DON’T FALL
PREY TO ETHICAL
SHORTCUTS.
PepsiCo Global Code of Conduct
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LEAD BY EXAMPLE
While all employees must always Act with Integrity, each manager
and leader of PepsiCo has the increased responsibility to lead by example and
empower others to deliver by reinforcing the principles of our Code throughout all
levels of our workforce.
If you are a leader or manager, you are expected to serve as a positive role model
and inspire others to embrace our Code by:
• Rewarding integrity.
• Encouraging ethical decision-making.
• Creating an open work environment where team members feel comfortable
to Voice Opinions Fearlessly.
• Preventing retaliation against those who speak up.
• Seeking help in resolving and escalating issues when they arise.
What should I do if my manager asks me
to perform a task that I believe might
violate our Code or a law?
Raise your concerns openly and honestly with your manager. If you are
not satisfied with your manager’s response, or if you feel uncomfortable
speaking to your manager, raise the issue through any other resource listed
under “How Can I Seek Guidance and Report Violations?” You should never
knowingly violate our Code, a policy or a law, even if a manager directs you to
do so or because you failed to ask for guidance.
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Global Compliance & Ethics or the PepsiCo
Law Department:
For issues involving actual
or potential Code or legal violations, you
should contact Global Compliance & Ethics or
the Law Department. Some examples of these issues
include:
• Financial accounting or auditing irregularities
or misrepresentations.
• Fraud, theft, bribery or other corrupt business
practices.
• Antitrust or Insider Trading violations.
• Violations of PepsiCo’s Human Rights Policy.
• Illegal discrimination or harassment.
• Material conflicts of interest.
• Misuse of confidential information, IT systems or
other company assets.
• Criminal or other illegal activity.
See our Global Code of Conduct
Escalation Policy.
HOW DO I KNOW
WHEN I SHOULD SEEK
GUIDANCE?
If something does not feel right, then it
might not be the right thing to do.
Ask yourself:
HOW CAN I SEEK GUIDANCE AND REPORT VIOLATIONS?
It is your responsibility to ask questions, raise concerns and Voice Opinions Fearlessly when compliance
issues arise. Our Code cannot describe every possible situation that you might encounter in your daily
work. If you cannot find an answer in our Code, or if you have questions on how to interpret our Code, seek
guidance. Likewise, if you are aware of something that may be a violation of our Code, our policies or the
law, you must speak up and report it so it can be addressed. You have several channels to seek guidance or
make a report:
Your immediate manager, next level manager
or Human Resources manager:
In most cases,
your immediate manager should be your first
point of contact. You should immediately contact
your manager to report issues that require
urgent attention, such as workplace violence,
employee health and safety, and food quality or
safety issues.
Your manager is also an excellent resource for
guidance or concerns related to many company
and job-specific policies and processes, work
responsibilities, co-worker issues, discipline
disputes, compensation, promotion opportunities,
and issues related to the work environment.
If you are
unsure about the
answers to any of
these questions, you
should ask for help
in making the right
decision.
You can
contact Global
Compliance &
Ethics by emailing
PepsiCoComplianceandEthics@
pepsico.com
, or you can
consult with your
local PepsiCo Law
Department.
You can
contact Global
Compliance &
Ethics by emailing
PepsiCoComplianceandEthics@
pepsico.com
, or you can
consult with your
local PepsiCo Law
Department.
Am I sure this course of
action is legal? Is it consistent
with our Code and policies?
Am I Acting as an Owner
to ensure the action or
result does not reflect
poorly on me or PepsiCo?
How would I feel if it was
reported on the front page
of the newspaper?
Will it hurt PepsiCo’s
reputation or cause our
company to lose credibility?
Am I Acting
with
Integrity, being
truthful and honest?
Am I putting other
people at risk?
PepsiCo Global Code of Conduct
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Speak Up calls are answered
by an independent third party
with expertise in handling hotline
calls. An Interview Specialist
will ask you questions and send
a report to Global Compliance &
Ethics for a confidential review.
The report will be promptly
investigated and, if warranted,
remedial action will be taken.
WHAT
HAPPENS
WHEN I
CONTACT
THE SPEAK
UP LINE?
Speak Up Hotline:
In addition to the resources listed
above, you can ask questions, raise concerns or
make reports of suspected compliance violations
by contacting Speak Up, PepsiCo’s ethics hotline.
Speak Up is a 24-hour, toll-free ethics hotline
available to all PepsiCo employees, consumers,
suppliers and other third parties to report
suspected violations of our Code.
Any information you provide to assist PepsiCo in
investigating your report will be kept confidential,
except as needed to conduct a full, fair investigation
or as otherwise required by applicable law. You may
choose to remain anonymous, however, identifying
yourself helps with the investigation of your concerns.
See our Global Speak Up Policy.
The Speak Up Hotline
is available anywhere in
the world
By web at
www.PepsiCoSpeakUp.EthicsPoint.com
By phone using a special toll-free telephone
number based on the country from which
you are calling. In the United States call
1-866-729-4888. For a list of international
country phone numbers, see our Speak Up
section at
By scanning the QR code for a
mobile optimized experience.
PepsiCo Global Code of Conduct
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RETALIATION
IS PROHIBITED
PepsiCo is committed to protecting
the rights of those individuals or
organizations who Voice Opinions
Fearlessly and report issues either
through one of the reporting
means described in our Code or
to government authorities. Our
company will not retaliate or
permit retaliation against a person
or organization who in good faith:
• Reports and/or assists another
person or organization to report
an actual or suspected violation
of our Code, our policies or the
law.
• Raises a question or seeks advice
about a particular business
practice, decision or action.
• Cooperates or participates
in an internal or government
investigation of an actual or
suspected violation.
See our Global Non-Retaliation
Policy.
INVESTIGATING MISCONDUCT
AND DISCIPLINARY ACTION
All reported instances of alleged Code violations will be reviewed by appropriate professionals designated
by Global Compliance & Ethics. The investigator(s) will:
Act objectively in determining
facts through interviews or a
review of documents.
Contact employees who may
have knowledge about the
alleged incident(s).
Recommend corrective actions
and/or disciplinary measures,
where appropriate.
If asked, you must cooperate fully with any inquiry or investigation.
As an employee of PepsiCo, you must follow our Code and comply with our policies and the law while
conducting business on behalf of the company. If you violate our Code, our policies or the law,
it may result in:
Disciplinary action, ranging from additional training
and coaching to employment consequences,
including termination of employment.
Civil and/or criminal penalties imposed
by a governmental agency or a court.
PepsiCo Global Code of Conduct
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ACT WITH INTEGRITY IN OUR WORKPLACE
Inclusion for Growth . . . . . . . . . . . . . . . . . . .
13
Human Rights . . . . . . . . . . . . . . . . . . . . . . .
14
Anti-Discrimination/Anti-Harassment . . . . . . . . .
15
Environment, Health and Safety . . . . . . . . . . . .
16
Substance Abuse . . . . . . . . . . . . . . . . . . . . .
17
Anti-Violence . . . . . . . . . . . . . . . . . . . . . . .
17
ACT WITH
INTEGRITY
IN OUR WORKPLACE
You are expected to support PepsiCo’s
commitment to ensuring equal
employment opportunity, maintaining
a workplace culture of inclusion and
respecting the dignity and human
rights of all people.
You must do your part to create a
work environment where everyone
feels valued and respected for
their contributions and is free from
intimidation and harassment.
PepsiCo Global Code of Conduct
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INCLUSION FOR GROWTH
At PepsiCo, our global workforce has always been a competitive
advantage. Our teams bring a range of experiences, thoughts, and ideas
that fuel innovation, enable us to deliver better and more relevant products, and
help us understand the variety of consumer’s wants and needs in communities in
every market.
Our Inclusion for Growth strategy is structured around three pillars:
People, Business and Community.
PEOPLE PILLAR
Continuing to attract and retain top talent, providing associates with the
opportunities to succeed, and ensuring a culture of inclusion where excellence
and contribution drive success.
BUSINESS PILLAR
Building a global workforce and supplier ecosystem that strengthens our ability
to compete by leveraging diverse perspectives for innovation, gaining deeper
consumer insights in markets around the world and delivering excellence in all
areas.
COMMUNITY PILLAR
Deepening our impact by focusing on meaningful partnerships that drive business
growth and opportunity, strengthen brand trust and our license to operate by
strengthening relationships with suppliers, customers, consumers and local
organizations.
Our company has a deep history of building an inclusive and respectful workplace
culture. PepsiCo has always been a company that thrives on bringing together the
best talent, empowering people to grow, and delivering innovative products that
meet the needs of our consumers. This legacy inspires the way we work today.
See our
Inclusion for Growth Overview
PepsiCo Global Code of Conduct
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HUMAN RIGHTS
PepsiCo recognizes the importance of maintaining
and promoting fundamental human rights in our
operations and supply chain, and we are committed
to respecting the rights of workers throughout our
business and supply chain. Our Code and business
policies work together to support the principles
contained in the International Bill of Human
Rights and the International Labor Organization
Declaration on Fundamental Principles and Rights
at Work.
You are expected to support our commitment to
operate programs and policies that:
• Promote a workplace free of discrimination and
harassment.
• Prohibit child labor, forced labor and human
trafficking.
• Provide fair and equitable wages, benefits and
other conditions of employment in accordance
with local laws.
• Provide humane and safe working conditions,
including safe housing conditions, where
applicable.
• Respect employees’ right to freedom of
association and collective bargaining.
You must Act as Owners to help ensure that our
suppliers and business partners uphold these
principles as well. Our Global Human Rights Policy,
Global Supplier Code of Conduct, and Human
Rights Due Diligence Program are some of the
tools we use to communicate our expectations
and help address potential human rights risks
throughout our operations and supply chain.
If you suspect a human rights abuse within our
direct operations or in our relationships with our
suppliers, speak up and report it.
See our Global Human Rights Policy and
Global Supplier Code of Conduct.
PepsiCo Global Code of Conduct
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ANTI-DISCRIMINATION/ANTI-HARASSMENT
Each of us should have the opportunity to reach our full potential and contribute to PepsiCo’s success.
You must never discriminate or treat employees or job applicants unfairly in matters that involve
recruiting, hiring, training, promoting, compensation, or any other term or condition of employment.
You are expected to make employment decisions regarding employees and applicants based on job-
related factors, without regard to race, color, age, sex or gender, sexual orientation, gender identity,
gender expression, transgender status, religion, creed, national origin, ethnicity, citizenship, ancestry,
disability, genetic information, military or veteran status, pregnancy, marital or familial status, or any
other protected category under applicable law. Basing employment decisions on any of these personal
characteristics is against our policies and is illegal under the laws of many countries.
Our Code prohibits harassment of any kind in the workplace or any other offensive or disrespectful
conduct. PepsiCo also complies with all country and local laws prohibiting harassment. You must never
engage in workplace harassment, which includes unwelcome verbal, visual, physical or other conduct
of any kind that causes others to feel uncomfortable or creates an intimidating, offensive or hostile
work environment.
While the legal definition of harassment may
vary by jurisdiction, we consider the following
non-exhaustive list to be unacceptable behavior:
• Sexual harassment.
• Offensive language, jokes or degrading
comments.
• Racial, ethnic, gender or religious slurs.
• Intimidating or threatening behavior.
Remember that harassment, sexual or otherwise,
is determined by your actions and how they
impact others, regardless of your intentions. If you
or someone else is the subject of discrimination
or harassment, speak up and report it.
See our Global Equal Employment Opportunity
Policy and Global Anti-Harassment Policy.
What is sexual harassment?
Sexual harassment may consist of verbal,
visual or physical conduct of a sexual nature
that is unwelcome and that a reasonable
person would find offensive. It can take many
forms, such as:
• Sexual advances, requests for sexual favors
or unwelcome demands for dates.
• Sexually oriented jokes, pictures, texts or
email messages.
• Explicit or degrading comments
about appearance.
• Display of sexually suggestive
pictures or pornography.
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ENVIRONMENT, HEALTH AND SAFETY
PepsiCo is committed to safeguarding the environment, health and safety (EHS) of our employees, visitors,
contractors, consumers and communities in which we operate. You are responsible for following all EHS
policies, procedures, and regulations, whether at our facilities, in the marketplace or on the roadways.
You should always speak fearlessly and raise a concern when:
EHS is everyone’s responsibility—you are expected to Act as Owners and have the courage to care for
yourself, your colleagues and our communities by insisting that work be performed safely and with minimal
impact on the environment, no matter what your job is.
See our Environmental, Health and Safety Policy.
A TASK YOU CONSIDER UNSAFE OR HARMFUL
TO THE ENVIRONMENT IS ASSIGNED TO YOU
A JOB YOU THINK YOU ARE NOT PROPERLY
TRAINED TO PERFORM AND THAT MAY HARM
YOU OR OTHERS OR THE ENVIRONMENT IS
ASSIGNED TO YOU
SOMEONE IS PERFORMING A TASK THAT YOU
BELIEVE IS UNSAFE OR HARMFUL TO THE
ENVIRONMENT OR THAT THE PERSON IS NOT
PROPERLY TRAINED TO PERFORM
A VEHICLE OR PIECE OF EQUIPMENT IS NOT
OPERATING PROPERLY AND MAY BE UNSAFE
AN UNSAFE CONDITION OR A POTENTIAL
DANGER TO YOURSELF, OTHERS OR THE
ENVIRONMENT COMES TO YOUR ATTENTION
YOU ARE AWARE OF INACCURATE OR
MISLEADING INFORMATION BEING PROVIDED
TO ANY REGULATORY AUTHORITIES.
PREVIOUSLY REPORTED UNSAFE OR
ENVIRONMENTALLY HARMFUL CONDITIONS,
TASKS, OR ISSUES HAVE NOT BEEN
ADEQUATELY ADDRESSED.
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What is considered substance
abuse and prohibited under
our Code?
• Working under the influence of alcohol
or drugs on or off PepsiCo premises,
including remotely on video conference
platforms (e. g. , Zoom, Microsoft Teams).
• Possessing, selling, using, transferring
or distributing illegal drugs or controlled
substances while working or on the
premises.
• Working while impaired by a lawful drug,
prescription medication or over-the-
counter drug.
SUBSTANCE ABUSE
If you work under the influence of drugs or alcohol,
you pose an unacceptable safety risk to yourself
and others. Drugs may include illegal drugs,
controlled or certain legal substances or misused
prescription medication. You are expected to
perform your job duties free from the influence of
any substance that could impair job performance.
If you have a drug or alcohol problem, you are
encouraged to seek assistance. Contact your
Human Resources manager to learn of applicable
assistance programs in your region or to find
specific policies.
ANTI-VIOLENCE
PepsiCo has a zero-tolerance policy for workplace
violence. You are prohibited from engaging in
any act that could cause another individual to
feel threatened or unsafe. This includes verbal
assaults, threats, or any expressions of hostility,
intimidation, aggression or hazing.
Our company prohibits the possession of weapons
in the workplace. This prohibition extends to
company parking lots as well as our facilities, to
the full extent permitted by local law.
Our zero-tolerance policy for workplace violence
applies to behavior of all of our employees
as well as third parties, including visitors, on
company premises, as well as to the behavior of
our employees, customers, vendors, suppliers
and temporary personnel engaged in PepsiCo
business anywhere in the world outside of our
premises. Workplace violence also includes any
violent act by a third party against a PepsiCo
employee who is conducting business on behalf
of PepsiCo.
You have an obligation to speak up and report
unusual or concerning behavior, threats or
potential violence immediately to location
management.
See our Global Workplace Violence Policy.
PepsiCo Global Code of Conduct
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Introduction
In Our Workplace
In Our Marketplace
In Business
In Our World
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In Our Workplace
ACT WITH INTEGRITY IN OUR MARKETPLACE
Our Consumers . . . . . . . . . . . . . . . . . . . . . .
19
Food Safety and Product Quality . . . . . . . . .
19
Responsible Marketing . . . . . . . . . . . . . . .
20
Our Customers . . . . . . . . . . . . . . . . . . . . . .
21
Our Suppliers . . . . . . . . . . . . . . . . . . . . . . .
21
Fair Competition . . . . . . . . . . . . . . . . . . . . .
22
Anti-Bribery . . . . . . . . . . . . . . . . . . . . . . .
23
Identifying Government Officials . . . . . . . . .
24
Business Gifts . . . . . . . . . . . . . . . . . . . . . .
25
Anti-Money Laundering . . . . . . . . . . . . . . . . .
26
International Sanctions and Trade Controls . . . . .
26
ACT WITH
INTEGRITY
IN OUR MARKETPLACE
Fostering trust with our partners is
integral to making PepsiCo a Faster,
Stronger and Better company. This
includes our consumers who purchase
our products, our customers who sell
our products, our competitors and our
suppliers.
You must treat our partners with fairness,
honesty and respect, while complying
with all applicable laws wherever we do
business.
PepsiCo Global Code of Conduct
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Introduction
In Our Workplace
In Business
In Our World
Resources
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In Our Marketplace
OUR CONSUMERS
PepsiCo products are enjoyed by consumers
more than one billion times a day in more than
200 countries and territories around the world.
Our consumers’ trust in our company and our
products is key to achieving our vision
To Be the
Global Leader in Convenient Foods and Beverages
by Winning with pep+ (PepsiCo Positive)
No matter what work you do, each employee
touches the consumer in some way. You must
Be Consumer Centric and always Act with
Integrity to deliver the highest standard of
product quality and market our products
responsibly.
FOOD SAFETY AND
PRODUCT QUALITY
Key to PepsiCo’s mission to
Create More
Smiles with Every Sip and Every Bite
is our
commitment to producing high-quality products
across all our brands. Our consumers have the
confidence to make our products part of their
lives, sharing them with the people closest
to them.
We maintain consumer trust by researching,
developing and manufacturing products that
we are truly proud of in an ethical manner.
We assure quality throughout the supply
chain from the purchase of ingredients
until the finished product reaches
our consumer.
If you are involved in any aspect of developing,
producing, handling or storing our products,
you must:
If you see or suspect anything that could
compromise product safety or quality, speak up
and report it immediately.
See our Global Food Safety Policy.
KNOW THE FOOD SAFETY AND
PRODUCT QUALITY STANDARDS,
POLICIES AND PROCEDURES
THAT APPLY TO THE PRODUCTS
PRODUCED AT YOUR LOCATION
FOLLOW GOOD MANUFACTURING
PRACTICES AND TESTING
PROTOCOLS
COMPLY WITH ALL APPLICABLE
FOOD SAFETY LAWS AND
REGULATIONS
PepsiCo Global Code of Conduct
19
Introduction
In Our Workplace
In Our Marketplace
In Business
In Our World
Resources
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In Our Marketplace
RESPONSIBLE MARKETING
As a trusted global foods and beverages
company, we have an important
responsibility to market our products
accurately and transparently to all
consumers. You are expected to always
represent our products truthfully,
responsibly, and in adherence to all
relevant laws and regulations in the
countries where we operate.
Be sure to follow all local review and
approval processes for consumer-facing
content. You must take particular care in
developing advertisements and evaluating
programming that carries messages to
children under 13 years of age.
See our Policy on Responsible
Advertising to Children.
If your work involves marketing, you must never:
OVERSTATE OR
MISREPRESENT THE
QUALITIES OF OUR
PRODUCTS OR PACKAGING
USE MISLEADING OR
UNTRUTHFUL STATEMENTS IN
ADVERTISING OR ON LABELS
MAKE CLAIMS, INCLUDING
CLAIMS ABOUT HEALTH
EFFECTS, SUSTAINABILITY,
OUR PRODUCTS OR PRODUCT
INGREDIENTS, WITHOUT
ADEQUATE SUBSTANTIATION
AND PROPER LEGAL
CLEARANCE
PepsiCo Global Code of Conduct
20
Introduction
In Our Workplace
In Our Marketplace
In Business
In Our World
Resources
Act with Integrity
In Our Marketplace
OUR CUSTOMERS
Our partnership with our customers is essential
to getting our products into the hands of our
consumers. Accordingly, you must treat our
customers ethically, fairly, and earn their business
on the basis of our superior products, customer
service and competitive prices, and never engage
in unfair or deceptive trade practices.
Our contracts with customers must always reflect
the importance and value we place on their
business. Customer sales and trade spending
agreements should be in writing and conform to
our policies and local laws. For more information,
see page 29: Financial Accuracy.
OUR SUPPLIERS
We hold our suppliers to the same standards of
integrity to which we hold ourselves. Therefore,
all suppliers are expected to comply with our
Global Supplier Code of Conduct as a condition of
doing business with us. Our suppliers include any
third party vendor, consultant, contractor, service
provider, or supplier of raw materials, ingredients
or packaging components.
If you are responsible for selecting a supplier, you
should Act as an Owner and base your decision
on merit, quality of service and reputation. When
selecting and retaining suppliers, you must adhere
to policy guidelines and ethical business practices.
You must:
• Follow our applicable bidding, negotiating
and contracting processes.
• Perform, if applicable, appropriate due
diligence under PepsiCo’s Third Party Due
Diligence Program (TPDD). See page 24.
• Help ensure the supplier adheres to our
Global Supplier Code of Conduct.
• Avoid potential or actual conflicts of interest
with suppliers, and never offer unlawful
incentives, such as “kickbacks. ”
See our Global Supplier Code of Conduct and
our Global Conflicts of Interest Policy.
What is a “Kickback”?
A kickback is a form of corruption that
involves two parties agreeing that a portion
of sales or profits will be improperly given,
rebated or otherwise returned to one of the
parties (or someone else designated by that
party) in exchange for making the deal.
PepsiCo Global Code of Conduct
21
Introduction
In Our Workplace
In Our Marketplace
In Business
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Resources
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In Our Marketplace
Play by the Rules
You should never take unfair
advantage of our size and scale
when dealing with competitors,
suppliers or customers. While it is
appropriate, in general, to leverage
our scale in the marketplace, it may be unlawful
to make unreasonable demands on our business
partners as to price, terms and conditions.
You should never discuss such topics with a competitor,
even in an informal setting such as a trade show or
customer event.
You must avoid activities that even appear to violate
antitrust or competition laws. For example, all written
communications referring to our business and our
competitors should be appropriate in tone and refrain
from language that could be construed as encouraging
anti-competitive behavior or disparaging third parties.
Violations of antitrust or competition laws may
result in severe legal penalties for our company
and criminal charges for the individuals involved.
Competition laws are complex and vary by country.
For guidance, you should consult your
local Law Department and refer to your
sector, region or country policies. If you
suspect an antitrust violation, speak up
and report it.
See our Global Antitrust and
Fair Competition Policy and Global
Supplier Code of Conduct.
FAIR COMPETITION
PepsiCo competes fairly. We are committed
to outperforming our competitors legally
and ethically. You should only comment
on competitors’ products or services in
an accurate and truthful manner, use only
legitimate means of obtaining competitive
information, and always comply with antitrust
and competition laws.
You must never enter into any agreements
or arrangements between PepsiCo and
competitors (whether formal or informal,
written or verbal) related to the following
topics:
SETTING PRICES OR
OTHER TERMS OF SALE
COORDINATING BIDS
OR ALLOCATING
CUSTOMERS,
SALES TERRITORIES
OR PRODUCT LINES
ENGAGING IN
ANY OTHER
ACTIVITY THAT
VIOLATES APPLICABLE LAW
PepsiCo Global Code of Conduct
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Introduction
In Our Workplace
In Our Marketplace
In Business
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In Our Marketplace
What is a “Facilitating Payment”?
A facilitating payment is a payment made to a
government official to expedite non-discretionary
actions or services, such as providing police protection
or mail service, processing visa, permit or licensing
applications, or providing utilities like phone service,
water and power. These payments are prohibited at
PepsiCo even if allowed under local law.
ANTI-BRIBERY
PepsiCo prohibits any form of corruption in our business
dealings. By conducting business responsibly, you help to
reinforce our reputation for Acting with Integrity and fair
dealing. You are responsible for understanding how to
identify and avoid all forms of corruption, as outlined in
our Code and Global Anti-Bribery Compliance Policy.
No matter where in the world you work, there is an
anti-bribery law that applies to you. You should never
offer, directly or indirectly through a third party,
anything of value to improperly obtain or retain
business, influence business decisions or secure an
unfair business advantage.
Anything of value includes not only cash, but also
gifts, hospitality (travel, meals and entertainment),
donations and sponsorships, or anything else that
could be valuable to a recipient. You also may not
make facilitating payments to government officials.
Subject to several narrowly tailored exemptions
identified in the Global Anti-Bribery Compliance
Policy, you must obtain pre-approval before
providing any expenses involving government
officials (gifts, travel, entertainment, hospitality,
etc. ). Upon obtaining pre-approval, all such
payments and other value made to government
officials, both directly and indirectly through
a third party, must be accurately and
transparently recorded in our books and records.
You should contact your local Compliance & Ethics officer or
your local Law Department if you have questions or are unsure
of the appropriate course of action. You must promptly report
any suspected bribery, demands for a bribe, or the actual
payment of a bribe made under coercion directly to your local
Law Department or Global Compliance & Ethics officer, or
through the Speak Up line.
See our Global Anti-Bribery Compliance Policy (ABAC Policy)
and access the ABAC Policy Pre-Approval Form for Government
Gifts, Meals, T&E, Sponsorships and Donations
here
PepsiCo Global Code of Conduct
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Introduction
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In Our Marketplace
In Business
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In Our Marketplace
A GOVERNMENT OR ONE OF ITS
DEPARTMENTS OR AGENCIES; FOR EXAMPLE:
• Government ministers and their staff.
• Civil servants, including police, customs officials
and office clerks.
• Building and other safety inspectors.
• Members of the military.
• Regulatory agency employees, including
environmental, tax and licensing.
A PUBLIC INTERNATIONAL ORGANIZATION;
FOR EXAMPLE:
• World Health Organization.
• World Bank.
• World Customs Organization.
• International Labor Organization.
• International charities, such as UNICEF.
A GOVERNMENT-CONTROLLED OR
STATE-OWNED ENTITY; FOR EXAMPLE:
• A state-run university, laboratory or hospital.
• A state-run television station.
• State-controlled commercial enterprises such
as airlines, defense contractors.
• Public utilities (electric, oil, gas).
A POLITICAL PARTY OFFICIAL OR
POLITICAL CANDIDATE; FOR EXAMPLE:
• Elected officials at any level of government
(national, state, local).
• Mayors, commissioners, municipal board
members.
• Even candidates who have never held
political office.
MEMBERS OF ROYAL FAMILIES
SPOUSES OR IMMEDIATE FAMILY
MEMBERS OF ANY OF THE ABOVE
IDENTIFYING GOVERNMENT OFFICIALS
Government officials include any officer, employee or person acting on behalf of:
THIRD PARTY
DUE DILIGENCE
PepsiCo has a risk-based, third party anti-
corruption due diligence program known as
the TPDD program. TPDD applies to certain
third party relationships and third parties that
interact with government officials on behalf
of PepsiCo, that will be providing services
in, are located in, or are headquartered in all
countries in Latin America Foods and most
countries in EMEA, Other International Foods
and International Beverages Franchise.
If a third party is in-scope for TPDD, you will
be asked at the point of vendor or customer
set-up for supporting documentation
demonstrating successful completion of TPDD.
To understand your obligations under TPDD,
consult the Overview of TPDD Process and
TPDD In-Scope Matrix available on the Global
Compliance & Ethics portal.
You may commence the TPDD process by
completing a
TPDD Profile Form
PepsiCo Global Code of Conduct
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In Business
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In Our Marketplace
You should be aware that giving or offering even a simple gift or meal to a
government official can be illegal. As described above, you must obtain prior
written approval from your local Compliance & Ethics Officer or local Law
Department using our Pre-Approval form available
here
before giving or offering
any gift to a government official, even if the government official works for a
PepsiCo customer or supplier.
See our Global Business Gifts Policy and Global Anti-Bribery Compliance Policy.
GIFTS TO
GOVERNMENT
OFFICIALS.
BUSINESS GIFTS
Business gifts include
anything
of value given
on behalf of a company or received by an
employee from a company’s business partner to
build goodwill or further business relationships,
without expecting anything else in return.
Exchanging business gifts with customers or
suppliers requires careful consideration by you
and your manager to avoid any real or perceived
attempt to inappropriately influence business
decisions or gain an unfair advantage.
Before any gift is exchanged, you must ensure it is not intended to influence a specific business decision,
without risk of reputational harm, and permitted under our policies and the giver’s/receiver’s policies.
In addition, you must comply with the following requirements:
Additional restrictions apply depending on whether the gift giver or recipient is a supplier, potential
supplier, customer, bottler, or other business partner. Please refer to our Global Business Gifts Policy for
specific requirements.
You cannot give or receive a gift if you
work in a Procurement role or in any
other function or business that prohibits
the exchange of business gifts.
If you
give
a gift, it must be a good use
of PepsiCo resources and approved by
your manager.
You may give or receive a gift only if it
is professionally appropriate (no cash or
gift cards) and given infrequently.
If you
receive
a gift that violates this
policy, you must
return
the gift unless
it would be impractical or offensive.
You should also notify the gift-giver of
PepsiCo’s business gift restrictions.
In order to avoid the perception of
improper influence, no gifts of any value
should be given or received during or
close to contracts bids or renewals.
PepsiCo Global Code of Conduct
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Introduction
In Our Workplace
In Our Marketplace
In Business
In Our World
Resources
Act with Integrity
In Our Marketplace
ANTI-MONEY LAUNDERING
You must guard against illegal customer or supplier financial transactions for the purposes of money
laundering. Money laundering is the process by which persons or groups try to conceal the proceeds of
illegal activities or try to make the sources of their illegal funds look legitimate. Act as an Owner and
be alert for “red flags,” such as requests from a potential customer or supplier to make
payments in cash or from a nonbusiness account, or other unusual payment terms.
INTERNATIONAL SANCTIONS
AND TRADE CONTROLS
As a global company, PepsiCo is subject to numerous international trade laws. If you
are involved in the transfer of goods or services across national borders on behalf of our
company or our customers, you must comply with all applicable laws and company policies
regarding international trade restrictions, regardless of where you are located. If U. S. law
conflicts with a local trade law, U. S. law may apply. Always consult with the Law Department
for proper guidance on this subject.
OUR BUSINESS TRANSACTIONS ARE SUBJECT TO VARIOUS
GLOBAL TRADE CONTROLS AND SANCTIONS, INCLUDING:
Government-imposed export controls, trade restrictions, trade embargoes,
legal economic sanctions and boycotts.
Anti-boycott laws that prohibit companies from participating in or cooperating with an
international boycott that is not approved or sanctioned by the U. S. government.
Sanctions by different governments around the world that restrict activities with certain
countries, entities or individuals. PepsiCo mitigates sanctions risk through a comprehensive
global screening process that aims to deter PepsiCo’s engagement with sanctioned entities
at any point in its supply chain.
PepsiCo Global Code of Conduct
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ACT WITH
INTEGRITY
IN BUSINESS
Our Code requires you to be honest
in all business activities, always
putting the company’s interests first.
You must be accountable in financial
record-keeping and Act as Owners to
safeguard company assets.
You should only speak on behalf of
PepsiCo if you are authorized to do so
and always follow our policies when
representing our company.
ACT WITH INTEGRITY IN BUSINESS
Maintaining Accurate Business Records . . . . . . . .
28
Records Retention . . . . . . . . . . . . . . . . .
28
Financial Accuracy . . . . . . . . . . . . . . . . .
29
Financial Disclosures and Audits . . . . . . . . .
29
Privacy . . . . . . . . . . . . . . . . . . . . . . . . . .
30
ArtificiaI Intelligence . . . . . . . . . . . . . . . . . . .
31
Proper Use and Protection of Company Resources .
32
Physical Property and Financial Resources . . .
32
Electronic Assets . . . . . . . . . . . . . . . . . .
33
Intellectual Property . . . . . . . . . . . . . . . .
34
Protecting PepsiCo Information . . . . . . . . . .
35
Insider Trading is Prohibited . . . . . . . . . . . .
36
Conflicts of Interest . . . . . . . . . . . . . . . . . . .
37
Communicating with the Public . . . . . . . . . . . .
38
Public Speaking and Press Inquiries . . . . . . .
38
Social Media . . . . . . . . . . . . . . . . . . . .
39
PepsiCo Global Code of Conduct
27
Introduction
In Our Workplace
In Our Marketplace
In Our World
Resources
Act with Integrity
In Business
MAINTAINING ACCURATE BUSINESS RECORDS
RECORDS RETENTION
A company the size of PepsiCo generates a large volume of business records each day. You are
responsible for ensuring that the records in your custody or control are maintained, retained, and
destroyed in compliance with all legal and regulatory record keeping requirements. To manage
your business records properly, you should:
• Comply with our records management policies and retention schedules for all business
records, paper, or electronic.
• Keep records only as long as necessary for a legitimate business purpose or legally required.
Follow the retention periods specified in the retention schedule, if applicable, or as required by
law for your sector, country or function.
• If you receive a Legal Hold or Tax Audit notice, follow all retention instructions on the notice
regardless of the retention schedule or applicable law.
Destruction of documents subject to a Legal Hold or Tax Audit notice, even inadvertently, could
expose our company and you to civil and criminal liability. You should consult the Law Department
if you have specific questions about documents referred to in a Legal Hold or Tax Audit notice.
PepsiCo’s records management requirements apply to all employees as well as anyone
we do business with, including suppliers, contractors or any third party.
If applicable, see the U. S. Records Management Policy and the North America Records Retention Schedule.
Otherwise, consult your local Law Department for other sector, country or function rules.
You are responsible for all business records you interact with in your daily work. Business records include any
document or communication in paper or electronic form that are maintained in the course of business, such as
emails, project plans, purchase orders or contracts. Employees who manage more highly regulated records, such
as personnel files, market research, tax documents, or information in filings with government agencies, have an
increased obligation to understand and adhere to all records management requirements.
WHICH BUSINESS
RECORDS APPLY
TO YOU?
PepsiCo Global Code of Conduct
28
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In Our Marketplace
In Business
In Our World
Resources
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In Business
FINANCIAL ACCURACY
PepsiCo is trusted as a company that does business with integrity. This is
reflected in our commitment to accurate reporting in our company’s books
and records. You are expected to Act as an Owner and be accountable for the
accuracy and honesty of the business records, contracts and agreements that
you handle in the normal course of business.
You should never falsify, omit, misstate, alter or conceal any information, or
otherwise misrepresent the facts on a company record or encourage or allow
anyone else to do so. All of your transactions, no matter what the dollar
amount, must be properly authorized, executed and recorded.
If you notice an inaccuracy in a company record, or a failure to follow our
internal control processes, speak up and report it immediately.
See our Global Anti-Trade Loading Compliance Policy.
FINANCIAL DISCLOSURES AND AUDITS
Our investors and the general public rely on our company to Act with
Integrity, and the law obligates us to report accurately on our business,
our earnings and our financial condition.
If it is part of your responsibility, you must make full, fair, accurate,
timely and understandable disclosures in our public communications,
regulatory disclosures, and reports submitted to the U. S. Securities
and Exchange Commission and other governmental agencies. In
addition, if it is part of your responsibility to provide information for
such communications, disclosures or reports, you must ensure that
the information you provide is accurate and complete.
It is also your responsibility to make open and full disclosure to and
cooperate fully with auditors and/or investigators in connection
with any corporate or external audit or review of the company’s
books and records.
See our Global Disclosure Policy.
DO NOT COMMIT FRAUD
Accurate financial reporting means
you should never:
Misstate financial information in our
company’s books and records.
Accelerate or defer costs in
violation of generally accepted
accounting principles.
“Trade load,” “channel stuff,”
or otherwise inflate or deflate
quarterly or annual sales by pulling
forward or delaying shipments
or intentionally selling larger
quantities than the customer needs.
Sign any side letter or any other
document that modifies or
interprets an existing customer
agreement without the prior
review and approval of the Law
Department.
Alter manufacturing numbers to
meet productivity goals.
Present false medical information to
obtain disability benefits.
Falsely report time worked to earn
more pay or to avoid discipline for
being late or absent from work.
PepsiCo Global Code of Conduct
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Introduction
In Our Workplace
In Our Marketplace
In Business
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Resources
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In Business
PRIVACY
If you have access to personal data in the course of
performing your job, you must comply with PepsiCo’s Global
Privacy Policy. This policy sets out a globally applicable
standard for PepsiCo’s approach to data privacy. The policy
incorporates ten Privacy Principles, which are intended
to establish good data privacy practices, demonstrate
compliance with data privacy laws and regulations and
outline PepsiCo’s commitments to handling and using the
data it collects, generates, and holds.
Managing personal data responsibly allows us to maintain
trust with our business partners, customers, consumers
and employees, and to comply with our legal obligations.
Whether we are designing new products, enhancing
services, or managing a third party, we must all Act as
Owners by keeping privacy considerations at the forefront.
In cases where we design, develop, deploy, or use systems
involving the use of biometric data (e. g. , fingerprints, facial
recognition), we must do so by adhering to our Global
Biometrics Privacy Policy. This policy ensures that the
collection and use of such data is done so in accordance
with applicable laws.
PepsiCo remains committed to enhancing, transforming,
and upholding privacy compliance to protect the privacy
and security of the personal data entrusted to us.
Examples of personal data PepsiCo collects include: names,
identification numbers, email addresses, individual phone
numbers, photos, IP addresses, device ID, or location data.
For more information on how PepsiCo uses and protects
personal data, please visit our Global Privacy Portal or
contact
mailto:PepsiCoPrivacy@pepsico.com
PepsiCo Global Code of Conduct
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Introduction
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In Our Marketplace
In Business
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Act with Integrity
In Business
ARTIFICIAL INTELLIGENCE
PepsiCo is embracing Artificial Intelligence
(AI) to transform how we develop products,
streamline operations, and engage with our
customers, consumers and associates. While AI
offers exciting opportunities to augment human
capabilities and drive innovation, each of us has a
shared responsibility to Act with Integrity and to
foster a culture that ensures the use of AI within
PepsiCo is aligned to our core values and upholds
the principles described in PepsiCo’s Global
Responsible AI Policy.
Before using any AI technology, every associate
is expected to learn about its capabilities and
limitations. Only approved, vetted AI tools should
be used, that are implemented according to
established guidelines.
It is essential to verify any AI-generated outcomes
independently and not rely solely on automated
results. This way, you play your part in preventing
harmful or unfair outcomes, and that decisions
made with AI are robust.
Transparency and accountability are fundamental
to our responsible AI practices. Associates must
use AI in a manner that is clear and open, ensuring
that its role in decision-making processes is
understood and subject to examination. If you have
questions, are ever uncertain about the use of
an AI tool or encounter potential issues, contact
SPA-ResponsibleAI@pepsico.com
.
Our Responsible AI Policy further outlines the
principles and protocols to be followed when using
AI to ensure that AI capabilities are deployed in
a manner that is fair, reliable, secure, safe and
compliant.
If you see or suspect a violation of our policy, speak
up and report it immediately. Reporting concerns
helps us address risks proactively and maintain the
integrity of our technology implementations.
For more information on Responsible AI, please
visit our Responsible AI Portal.
PepsiCo Global Code of Conduct
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PROPER USE AND PROTECTION
OF COMPANY RESOURCES
PepsiCo relies on you to Act as an Owner and use company resources honestly and efficiently to
better serve our customers, operate profitably, and create value for our shareholders and other
stakeholders. Company resources encompass a wide array of assets, from the tangible ones you can
touch – physical property, financial resources and electronic assets – to the intangible resources that
are critical to our long-term success – intellectual property and confidential information.
PHYSICAL PROPERTY AND FINANCIAL RESOURCES
You are responsible for the proper use of the PepsiCo property and resources you are provided
with to do your job, from tools and equipment to company funds. You must avoid misusing
company resources in all forms, including taking product or supplies for personal use, charging
personal expenses on company credit cards, using company vehicles for unauthorized personal
transportation needs, or using or reselling scrap or other company property without permission.
As discussed above, you must never divert assets through embezzlement or fraud.
The obligation to Act as Owners and protect company funds is particularly important if you
have spending authority, approve Travel and Entertainment expenses, or manage budgets and
accounts. Before expending company funds, you must always:
• Ensure the funds are properly used for their established purpose.
• Obtain required approval before incurring an expense.
• Accurately record all expenditures.
• Verify that expenses submitted for reimbursement are business-related,
properly documented and comply with our policies.
See our Global SpendWise Policies.
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PUTTING INFORMATION
SECURITY INTO PRACTICE
To safeguard our information systems, you
should take care with any property that has
been issued to you and never:
Allow others to access your
electronic devices or user
identification credentials.
Use unsecure online accounts,
including social media accounts.
Instead, be sure to maximize
password security and set up
two-factor authentication,
where available.
Leave laptops or other mobile
devices unattended while traveling
or in an exposed location where
they can be stolen.
Download unauthorized or
unlicensed software or apps
on PepsiCo devices.
Disable, defeat or circumvent
any security controls.
ELECTRONIC ASSETS
Our information technology systems constitute a
critical component of our business operations and
are provided for authorized business purposes.
Your use of these systems must comply with our
Information Security Policy and the Acceptable
Use Policy. Incidental personal use of PepsiCo
devices and systems, including phone, email and
the internet, is permissible, so long as such usage
does not:
• Extend beyond what is reasonable
and occasional.
• Interfere with your work performance
or that of others.
• Involve illegal, sexually explicit, political,
discriminatory or otherwise inappropriate
material.
• Relate to outside business interests.
• Introduce malicious malware into PepsiCo’s
information resources through external devices
or downloading unauthorized material.
• Violate our Code or any company policy.
You should not have an expectation of privacy
regarding the use of PepsiCo information
resources. Any information you create, share or
download onto company systems belongs to the
company. PepsiCo reserves the right to monitor,
record, disclose, audit and delete without prior
notice the nature and content of an employee’s
activity using our company’s email, phone,
voicemail, internet and other systems, to the
extent permitted by local law.
You must ensure that all third parties you engage
or work with that have access to any PepsiCo
information, systems or other information services
also adhere to PepsiCo’s Information Security
Policy and acknowledge their responsibility to
uphold applicable PepsiCo security requirements.
If you suspect a security-related incident, or
become aware of any situation in which data may
have been compromised, including, but not limited
to, the loss or theft of a laptop or handheld device or
malware infection, immediately report the situation
to Information Security via your local Service Desk
or via email at
PepsiCoSecurity@pepsico.com
See our Global Information Security Policy
and Global Acceptable Use Policy.
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INTELLECTUAL PROPERTY
PepsiCo’s intellectual property is an invaluable
asset built over years of hard work and must
be protected at all times. Intellectual property
includes our trademarks, brands, domain names,
social media accounts, package designs, logos,
copyrights, inventions, patents and trade secrets.
You should never allow a third party to use, or
allow others to use, our trademarks or other
intellectual property without proper authorization
and a license agreement that has been approved
by the Law Department. Our trademarks should
never be used in a degrading, defamatory or
otherwise offensive manner.
Our intellectual property also includes employees’
work product. As a company employee, any work
you create, in whole or in part, in connection with
your duties, and/or using company time, resources
or information, belongs to PepsiCo. For example,
inventions, ideas, discoveries, improvements,
artwork, processes, designs, software, or any
other materials you may help to create or author
in connection with your work for our company
belongs to PepsiCo to the extent permitted by law.
Domain names and social media accounts that
include PepsiCo trademarks or other intellectual
property must always be registered in the name of
the appropriate PepsiCo entity through authorized
IT contacts and never in the name of an individual
employee or external consultant or agency. You
should promptly disclose any invention or creative
work related to our business, so that it may receive
the same protection as other intellectual property
of our company.
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Even within our company and among your
coworkers, you should only share information
in accordance with the data classification
guidance and on a need-to-know basis.
You are also responsible for safeguarding
electronic information in your possession,
including when outside of the PepsiCo system
when using non-PepsiCo laptops, mobile
devices and/or a remote network connection.
See our Global Trade Secret Policy
and Data Classification Standard.
You should Act as an Owner and understand the
information you work with and its associated
classification. PepsiCo classifies its information
into four categories: PEPSICO RESTRICTED,
PEPSICO CONFIDENTIAL, PEPSICO INTERNAL
AND PEPSICO PUBLIC. Classifications are based
on the level of sensitivity and risk to PepsiCo if
improperly disclosed or altered. Each category
has a defined set of controls required to ensure
the protection of the information, such as user
authentication and data encryption.
You must always take reasonable and necessary
precautions to protect information relating
to PepsiCo, its customers, suppliers, business
partners, and other third parties that is
confidential, competitively sensitive and/or
proprietary. You must assume that company
information should be protected unless you
have clear indication that PepsiCo has publicly
released the information and/or that the
information is classified as PEPSICO PUBLIC.
You should not disclose any PEPSICO
RESTRICTED, PEPSICO CONFIDENTIAL, OR
PEPSICO INTERNAL information to anyone
outside PepsiCo, even to members of your own
family, unless the disclosure is:
• Properly authorized.
• In connection with a clearly defined,
legitimate business need.
• Subject to a written confidentiality agreement
approved by the Law Department.
PROTECTING PEPSICO INFORMATION
YOUR RIGHTS
AS AN EMPLOYEE
Please note that this confidentiality
obligation does not restrict you from
raising concerns about potential Code
or legal violations within the company
or with a government agency, either
during or after your employment.
Specifically, you are not restricted from
filing a complaint with, communicating
with, providing information to, or
participating in an investigation or
proceeding before a government
agency.
What are examples of PEPSICO
RESTRICTED and PEPSICO
CONFIDENTIAL information?
Examples of PEPSICO
RESTRICTED information
includes, but is not limited
to, formulas, merger and
acquisition information,
corporate business plans
and strategy, financial
performance data,
forecasts, significant
restructurings or
management changes, and
personal health data.
Examples of PEPSICO
CONFIDENTIAL information
includes, but is not limited
to, information related to
payroll, supplier contracts,
pricing and other terms of
customer agreements, sales,
manufacturing processes,
research, pre-release
product or marketing
information, and reports of
potential legal violations.
See our Data Classification
Standard for more detail.
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INSIDER TRADING IS PROHIBITED
In the course of performing your job, you may learn
of certain confidential information that qualifies as
“material non-public information” about PepsiCo,
one of its customers, suppliers or business
partners or another third party.
Information is considered to be “material non-
public information” when it has not been widely
disseminated to the public and is information that
a reasonable investor would consider important in
making a decision to buy, sell or hold a particular
security, such as earnings, forecasts, business
plans and strategies, significant restructurings,
potential significant mergers, acquisitions,
divestitures, refranchisings or joint ventures, sales
information, research, significant new product
development, acquisition or loss of a significant
contract, significant management changes, a
change in auditor or the withdrawals of auditor
reports, significant cybersecurity incidents and
events regarding PepsiCo securities.
You should not transact in PepsiCo securities
(such as Common Stock, debt securities,
stock options or restricted stock units) or the
securities of another company involved with
PepsiCo, or advise anyone else to do so, while
you have material non-public information about
PepsiCo or that company. This includes all
transactions in PepsiCo securities: purchasing,
selling, gifting or donating PepsiCo securities,
exercising options, selling restricted stock units,
and increasing or decreasing your investment in
PepsiCo securities through your 401(k).
This prohibition against insider trading also
applies to your family members or anyone else
living in your household and any entities over
whose transactions in PepsiCo securities you
have influence or control. Anyone who trades
on material non-public information or tips such
information to another is subject to severe
punishment, which could include significant fines
and imprisonment under applicable laws.
In addition, you are not permitted to:
Engage in activities that are
designed to hedge or offset any
decrease in the market value of
PepsiCo stock (including purchasing
financial instruments such as
prepaid variable forward contracts,
collars, exchange funds or equity
swaps, or engaging in short sales).
Pledge PepsiCo stock or stock
options as collateral for a loan
or otherwise.
Hold PepsiCo securities in a
margin account.
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CONFLICTS OF INTEREST
You should avoid a conflict, or an appearance of a conflict, between your personal interests and our
company’s interest. You must Act with Integrity to recognize and avoid conflicts of interest that can
interfere with your ability to make objective business decisions, especially when personal relationships,
outside employment or investments are involved. Conflicts of interest may arise when you:
• Engage in activities that compete, or appear to compete, with our company’s interests.
• Let your business decisions be, or appear to be, influenced by personal or family interests, romantic
relationships or friendships.
• Use a company business opportunity, property, information or resource for personal benefit or the benefit
of others.
• Hire, supervise or have a direct or indirect line of reporting to a family member, romantic partner or close
friend, or have the ability to influence that person’s employment opportunities or compensation.
• Have outside activities or employment that negatively affects your job performance or interferes with
your PepsiCo responsibilities.
• Have an ownership interest in a current or potential supplier, customer or competitor or have a family
member who does. In general, it will not pose a conflict of interest if you or a family member owns a
nominal stock ownership interest (generally, less than a 1% equity interest).
• Work for, provide services to, or receive any other personal benefit from a current or potential supplier,
customer, or competitor or have a family member who does.
HAVING A CONFLICT OF INTEREST IS TYPICALLY
NOT A CODE VIOLATION, BUT FAILING TO DISCLOSE IS.
You must promptly disclose an actual or potential
conflict of interest when hired, when the conflict arises
during your employment, and annually during Code of
Conduct training by accessing
www.disclose.ethicspoint.com
.
See our Global Conflicts of Interest Policy.
TO DETERMINE IF YOU
HAVE A CONFLICT OF
INTEREST THAT SHOULD BE
DISCLOSED, REVIEW THE GLOBAL
CONFLICTS OF INTEREST POLICY
TO SEE IF YOUR SITUATION IS
SPECIFICALLY ADDRESSED.
If it is not, ask yourself these questions:
If the answer
is yes to any
question, you have a
potential conflict of
interest that should
be disclosed.
Do my outside interests influence, or
appear to influence, my ability to make
sound business decisions?
If the situation became
public knowledge, would I
be embarrassed? Would it
embarrass the company?
Do I stand to personally benefit, or appear
to benefit, from my involvement in this
situation? Does a friend or relative of mine
stand to benefit or appear to benefit?
Could my participation in this activity
interfere, or appear to interfere, with
my ability to do my job?
Is the situation causing me to put
my own interests ahead of PepsiCo’s
interests? Does it appear to?
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COMMUNICATING
WITH THE PUBLIC
PUBLIC SPEAKING
AND PRESS INQUIRIES
PepsiCo is committed to providing accurate, clear,
complete and consistent information to the public.
You may not speak on behalf of our company
without prior authorization.
No PepsiCo employee is permitted to agree to
an interview or external speaking engagement,
business or personal, in which our company will
be discussed or referenced, or publish any video
or written content related to PepsiCo, without
the support and approval of a member of the
PepsiCo Communications team. You must also have
authorization, based on a clear business rationale,
from your direct manager and/or the most senior
person on your team.
If you are contacted and asked to discuss
company business with members of the press,
investors or market analysts, do not provide any
information. Instead, you should refer them to
PepsicoMediaRelations@pepsico.com
.
See our Global Media, Public Speaking and
Publication Policy and our Global Disclosure Policy
for additional guidance.
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What are some real-life
examples of social media use
that violate our policies?
UNINTENDED CONSEQUENCES
Posting photos from PepsiCo facilities
that may inadvertently reveal proprietary
information or violate the privacy of
PepsiCo colleagues.
FIFTEEN MINUTES OF FAME
Posting a picture of a private celebrity
or business executive visit to PepsiCo.
OVERSHARING PEPSICO LOVE
Posting information about a PepsiCo product
or campaign before it is officially released.
SPEAK FOR YOURSELF
Unauthorized speaking on behalf of PepsiCo
on social media channels.
SOCIAL MEDIA
We encourage PepsiCo employees to take pride in their relationship with PepsiCo and to connect with
family, friends, colleagues and consumers around the world through social media. While doing so, be mindful
that posting to social media channels can result in unintended consequences that could impact both you
and PepsiCo.
You are expected to understand and comply with our Global Social Media Policy when active on social
platforms for business, or when using social media for personal activities if you’ve identified yourself as a
PepsiCo employee and/or are using company equipment or systems.
Before engaging on social media, know your responsibilities according to our policy, including:
Due to unique U. S. laws, U. S. -based hourly and non-supervisory employees are subject to
a different policy, which can be found on the Policies page on You should
consult your local Law Department or Communications team if you have questions or are
unsure if content is appropriate to post. For questions about Social Media policies, contact
GlobalSocialMedia@pepsico.com
See our Global Social Media Policy for full guidance.
Do not misrepresent yourself
or the company or speak on
behalf of the company.
Never disclose any personal
information about employees,
consumers, visitors or online
followers, or proprietary
or confidential information
about PepsiCo or its business
partners.
Avoid harassing, defamatory
or disparaging content, and be
sensitive to global cultures.
Remember that internet
content can live forever
and it is important that
your online behavior
reflects our values.
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ACT WITH INTEGRITY IN OUR WORLD
pep+ (PepsiCo Positive) . . . . . . . . . . . . . . . . .
41
The PepsiCo Foundation . . . . . . . . . . . . . . . . .
41
Be a Good Citizen . . . . . . . . . . . . . . . . . . . .
42
Political Activities . . . . . . . . . . . . . . . . . . . .
42
ACT WITH
INTEGRITY
IN OUR WORLD
As a principled organization that operates
in every corner of the world, it is a
business imperative to respect, support
and invest in the people and communities
where we live and work.
We strive to use our global scale for
good by building a more sustainable food
system and by creating our products in
a way that benefits our consumers, our
suppliers, our communities and our planet
– part of our mission to
Create more
Smiles with Every Sip and Every Bite
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pep+ (PEPSICO POSITIVE)
At PepsiCo, we believe that there is an opportunity to change how the world
produces, distributes, consumes and disposes of our brands. Through pep+
(PepsiCo Positive), we aim to do just that.
pep+ is a strategic end-to-end transformation with sustainability and human
capital at the center of how the company creates growth and value by
operating within planetary boundaries and inspiring positive change for the
planet and people.
Learn more about
pep+
THE PEPSICO FOUNDATION
PepsiCo strives to nurture the potential of communities around the world
by contributing toward a more sustainable food system. The company’s
philanthropic arm, the PepsiCo Foundation, plays an important role in that by
investing in nutritious food & safe water access and farming and workforce
development. Primarily, the Foundation gives back through strategic grant-
making to nonprofits, supporting employee engagement in local communities
and providing disaster relief.
Over decades of working with local partners, the PepsiCo Foundation has made
local and lasting impacts in the communities we serve around the world.
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BE A GOOD CITIZEN
We Celebrate Success and encourage
you to give back to your communities
by participating in company outreach
efforts, volunteerism and other ways that
are meaningful to you. PepsiCo proudly
partners with nonprofits that share our
commitment to food security, safe water
access, and economic opportunity. To learn
more about our global volunteer program,
visit One Smile at a Time.
We provide employees with company-
sponsored volunteer opportunities in
areas aligned with our pep+ agenda. When
engaging in personal charitable activities,
remember to secure prior approval before
committing any company funds or assets.
Qualifying nonprofit organizations that you
choose to support may be eligible for a
corporate matching gift from the PepsiCo
Foundation. Visit
to learn more, including the terms and
conditions of the matching gift program.
See our Global Donations Policy.
POLITICAL ACTIVITIES
Political and public policy engagement (Political Activity),
including political contributions, are highly regulated and
restrictions and requirements differ globally. It is critical that
you
do not:
• engage in Political Activity on behalf of PepsiCo (directly,
or through third parties, such as consultants or trade
associations) without the direct involvement of PepsiCo’s
Public Policy and Government Affairs Department.
• use PepsiCo funds or resources, receive PepsiCo
reimbursement, or suggest PepsiCo’s support for your
personal Political Activity.
PepsiCo’s political contributions or communications
on issues of public concern are not intended to
influence you to adopt certain ideas or support
certain causes. Your decisions to contribute your
own time or money to any Political Activity are
entirely personal and voluntary.
See our Global Political and
Public Policy Activities Policy.
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PEPSICO GLOBAL COMPLIANCE
& ETHICS DEPARTMENT
For general inquiries, or to report a possible
violation of our Code of Conduct, contact
PepsiCoComplianceandEthics@pepsico.com
• For questions on our training programs,
contact
PepsiCoComplianceTraining@pepsico.com
• For questions concerning
Conflicts of Interest disclosures, contact
PepsiCoComplianceDisclosures@pepsico.com
PEPSICO LAW DEPARTMENT
To report a possible legal violation,
contact
PepsicoLawDept@pepsico.com
SPEAK UP
HOTLINE
• By phone using a special toll-free telephone
number based on the country from which you are
calling. In the United States, call 1-866-729-4888
For a list of international country phone numbers,
see our Speak Up section at
• By web available at
www.PepsiCoSpeakUp.EthicsPoint.com
• By scanning the QR code for a mobile
optimized experience.
To access PepsiCo policies, visit
PepsiCo, Inc.
700 Anderson Hill Road
Purchase, NY 10577
www.pepsico.com
© 2025 PepsiCo, Inc.
Effective date: August 1, 2020
Last revision: June 15, 2025
PepsiCo’s Global Code of Conduct contains many of the valuable
trademarks owned and/or used by PepsiCo and its subsidiaries and
affiliates to distinguish its products and services of outstanding quality.
All trademarks featured herein are the property of their respective owners.
The photos and/or images included in our Code of Conduct may or may
not represent current logos, marks, uniforms or staff and should not be
reproduced in any other media or publication.
ACT WITH
INTEGRITY
RESOURCES
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