ENTER
3
Be Aware
4
Why We Have a Code
5
Who Is Covered Under the Code
6
What You Need to Do
7
How to Make Good Decisions
8
Your Local Ethics Officer
9
Reporting Concerns
11
Protect What Is Ours
12
We Protect Non-Public Information
13
We Safeguard Company Assets
15
We Maintain Accurate Records
16
We Prevent Money Laundering
17
Demonstrate Accountability
18
We Avoid Conflicts of Interest
22
We Are Responsible with Gifts,
Meals and Entertainment
25
We Build Transparent Relationships
Table of Contents
26
Deal Fairly with Others
27
We Compete Fairly
28
We Comply with Trade
Compliance Laws
29
We Do Not Tolerate Bribery
30
We Do Not Trade on
Inside Information
31
We Follow Privacy Laws
32
Care for Our Communities
33
We Respect Human Rights
35
We Show That We Care
38
The Last Drop
39
A Fountain of Information
40
Glossary
41
Resources
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
TABLE OF CONTENTS
Question or Concern? Log on to EthicsLine @
www.KOethics.com
2
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
BE
AWARE
EVERYTHING WE DO REFLECTS OUR BRANDS,
AND OUR CODE SHOWS US THE WAY.
Why We Have a Code
Who Is Covered Under the Code
What You Need to Do
How to Make Good Decisions
Your Local Ethics Officer
Reporting Concerns
Care for
Our Communities
A Fountain
of Information
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
BE AWARE
Question or Concern? Log on to EthicsLine @
www.KOethics.com
3
Deal Fairly
with Others
A Fountain
of Information
Demonstrate
Accountability
Care for
Our Communities
Table of
Contents
Be
Aware
Protect What
Is Ours
Why We Have a Code
Policy Modifications and Waivers
We realize that the Code will not cover every possible circumstance, especially
when issues arise with contracts or local laws. So our Company may modify the
Code, as necessary. Any waivers of the Code, however, must be approved by
the Board of Directors or the Board’s designees. In the extremely rare situation
that a waiver is approved, we will quickly and properly disclose it where
required by law.
What makes Coca-Cola one of the most admired brands in the world? It is not
just our products. It is also how we do our work and the integrity of our actions.
Ingrained in our culture, integrity inspires our work and strengthens our
reputation as a Company that does extraordinary things and always does what
is right. Integrity is the essential ingredient to our success.
Sometime, you might face a situation where the right thing to do is not obvious.
That is where our Code of Business Conduct can help. It is always here as your
guide to preserving our reputation and living our values. While the Code cannot
answer every question, it can show you where to go for guidance when the
answer is not clear.
How Can the Code Help You?
The Code enables you to...
»
»
Conduct yourself honestly and ethically.
»
»
Uphold our values and protect our reputation.
»
»
Understand what Coca-Cola expects from you.
»
»
Make good decisions every day.
»
»
Comply with the laws, regulations and standards
that apply to our Company.
»
»
Understand where to go for assistance or
guidance if you have questions.
Administering the Code
The Ethics & Compliance Committee is responsible for administering the
Code in an independent, objective and consistent manner. The Committee
is made up of a group of senior Company leaders who enforce the Code, and
it is overseen by our Chief Financial Officer, General Counsel and the Audit
Committee of the Board of Directors.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
BE AWARE
Question or Concern? Log on to EthicsLine @
www.KOethics.com
4
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
Who Is Covered Under the Code
It does not matter where you work or what you do for the Company
–
you have
a responsibility to use good judgment and follow our Code. That includes every
full-time or part-time employee at every level of the Company, all the way up to
the executive suite. The Code also applies to controlled subsidiaries and entities
in which the Company either owns a majority interest or manages operations
(all of the above are referred to throughout this Code as “the Company”). All
employees, and any others subject to the Code, must acknowledge that they
have read and agree to uphold the Code.
Anyone who works on the Company’s behalf (including suppliers, consultants
and other business partners) must share our commitment to integrity by
following the principles of our Code when providing goods and services to the
Company or acting on our behalf. Suppliers, as a condition of working with us,
must comply with our Supplier Code of Business Conduct and our Supplier
Guiding Principles.
Uphold the Law
Laws and regulations can vary widely from country to country. Because our
Company is incorporated in the United States, our employees around the world
often are subject to U.S. law in addition to the laws of the country where they work.
Because we operate in over 200 countries, knowing which laws to follow can be
complicated, so be sure you know the laws and regulations related to your job in
the country (or countries) where you do business. Sometimes local customs or
practices can conflict with our Code or the law. In cases like these, follow the law
and our Code. Contact local legal counsel for guidance.
Your Rights as an Employee
While we expect you to follow our Code, we also recognize your rights as a
Company employee. For example, you have the right to speak publicly about
matters of public concern or to participate in certain activities related to the
terms and conditions of your employment (including discussions about wages,
hours, working conditions, health hazards and safety issues). Nothing in this
Code or in any Company policy is intended to limit or interfere with your rights
under the law.
1
When a Code Violation Occurs
When one of our employees fails to follow our Code or applicable laws, ignores
someone else’s failure to follow the Code or pressures someone else to violate
the Code, a violation has occurred. This can harm the Company’s reputation
and our bottom line.
We take all potential Code violations seriously. Code violations may lead to
disciplinary action that matches the nature and circumstances of the violation,
up to and including suspension without pay, loss of merit increases or annual
incentives, and termination of employment. If an act violates the law, it could
result in fines or criminal prosecution. Code violations are also documented in
your employee record.
The Company has other policies and processes governing performance,
conduct and behavior. Policy violations that are not Code violations will
be handled under the appropriate policy or procedure.
1
The Coca-Cola Company remains committed to both the physical and digital security of its employees’ personal information
as well as the enforcement of the security obligations of its custodians. For US-based employees, the term “employee
information” should not be construed to prevent or discourage the Company’s employees from disclosing or sharing
information related to their wages, benefits, or terms and conditions of employment to exercise their rights under
applicable law, including for the purpose of engaging in protected concerted activity under Section 7 (29 U.S.C.
157) of the
National Labor Relations Act. Notwithstanding this, employees may not disclose sensitive employee information about
others (such as medical information, government issued identification numbers, background check information and bank
account information) that is entrusted to them in performing their job duties for the Company, except as may be required for
legitimate business purposes. Similar rules may be applicable to employees in other countries as well.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
BE AWARE
Question or Concern? Log on to EthicsLine @
www.KOethics.com
5
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
What You Need to Do
As employees
, each of us has as a responsibility to ...
Know and live the Code.
Read it and follow it, along with any other policies
that apply to your job.
Think before you act.
Use good judgment, being honest and ethical in every
action you take. If you are asked to violate the Code, do not do it. Report the
concern as soon as possible using the resources available to you.
Follow the law.
Understand laws that apply to your job and our business.
If you are ever unclear about a law or regulation, contact
Company legal counsel
.
Ask for help.
When an answer is not clear, ask for guidance before taking action.
Stay alert.
Pay close attention to any activity that is inconsistent with our
Code, our policies or the law.
Report concerns.
Do not ignore a violation. Prevent harm to our Company
and its reputation by
reporting your concerns
immediately.
If you are a manager
, you have additional responsibilities ...
Model the Code and our values.
Promote a culture of integrity by making
ethical decisions and showing honesty and integrity in everything you say
and do. Never encourage or direct any employee to achieve a business
result at the expense of violating our Code or the law.
Talk about the Code.
Read the Code and understand it. Refer to it, your
Local Ethics Officer or the Ethics & Compliance resources on Connect
to answer questions. Make ethics conversations part of your routine.
Be informed.
Recognize that you may not always find the answers that
you need in the Code, so know where to go for answers when there
are questions.
Expect the best.
Discuss the importance of ethics and compliance and let
employees know you expect them to always do what is right.
Be responsive and create a “speak up” culture.
Encourage employees to
come to you with questions or concerns. Listen to them carefully and offer
guidance when they need help, including identifying available resources for
reporting. Also, be careful not to create an environment where employees
feel they can
only
bring concerns to local management.
Take action.
Look out for misconduct and report it to your manager,
Local Ethics Officer,
Ethics & Compliance Office
or
EthicsLine
if you see it.
CONSIDER THIS
“We really can’t miss the quarter.”
“Let’s keep this to ourselves.”
“Nobody needs to know about this.”
Comments like these can create a
misunderstanding for employees
who hear them. Be sure to couple
messages about meeting business
goals with a reminder that we can only
do so ethically. Also remind employees
of the many resources available for
expressing their concerns.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
BE AWARE
Question or Concern? Log on to EthicsLine @
www.KOethics.com
6
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
Doing what is right is our goal. If the right thing
to do is not clear, ask yourself:
Is it consistent with our Code?
Is it legal?
Does it follow our policies?
Does it benefit the Company
as a whole – not just a certain
individual or group?
Would I be comfortable if my
actions were made public?
If you can answer “
YES
” to all of these questions, the action is probably okay.
But any “no” or even “maybe” answers are a signal to stop and get advice or
ask questions. After all, it is always better to ask before you act, especially
when you are not sure. Contact any of these resources:
How to Make Good Decisions
Your
Manager
The Ethics &
Compliance
Office
Your Local
Ethics Officer
EthicsLine
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
BE AWARE
Question or Concern? Log on to EthicsLine @
www.KOethics.com
7
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
Your Local Ethics Officer (LEO)
Think of your
LEO
as a keeper of the Code
–
a resource for you if you have
questions or want to raise a concern. In some situations, you will need
written approval from your Local Ethics Officer before you take action.
Examples of situations that may require written LEO approval:
2
»
»
Use of
Company assets
»
»
Conflicts of Interest
(or the appearance of a conflict)
»
»
Gifts, Meals and Entertainment
Some situations are ongoing over a long period of time and will require
approval at least annually, when circumstances change or at other more
frequent intervals as required by the LEO.
Who Is my Local Ethics Officer?
The Company appoints an employee to support each operation as its Local
Ethics Officer. LEOs are authorized to give written approvals and offer
guidance on ethics and compliance issues.
How Can I Reach my LEO?
All Local Ethics Officers are listed on the Ethics & Compliance intranet site.
How Do I Get Approval?
When seeking approval from your LEO, your best option is to use the online Local
Ethics Officer Approval Tool. If you do not have access to the LEO Approval Tool,
contact the Ethics & Compliance Office or your LEO for a hard-copy request form.
What if I Am a Local Ethics Officer and Need Approval?
For LEOs:
When a LEO needs approval under the Code, if an approved technology solution
is not available, approval must come from the Local Ethics Officer at the next
level up in their organization or from the Chief Ethics & Compliance Officer.
For Executive Officers:
The Chief Ethics & Compliance Officer serves as the Local Ethics Officer for
Executive Officers; however, approvals of certain types of conflicts and
use of Company assets will require written approval by the CEO or the Board
of Directors.
2
The Company may implement technology solutions to facilitate approvals required by this Code. References in this Code to
LEO Approval requirements will include approvals by any technology solutions approved by the Ethics & Compliance Office.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
BE AWARE
Question or Concern? Log on to EthicsLine @
www.KOethics.com
8
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
Reporting Concerns
Maybe you sense that something is not right at work. Maybe you saw something
or heard about an act that may violate our Code, our policies or the law. If so, you
have a responsibility to share your concerns by reporting right away
–
even if you
are not sure that a Code violation has occurred.
When you report concerns, you help us handle issues properly, fix problems
before they occur and remedy situations that have already happened.
You also help build trust with each other and with our
customers
, our
suppliers
and
other business partners
.
How Do I Share Concerns?
For Code matters:
Talk to either:
»
»
Your manager
»
»
Your Local Ethics Officer
»
»
The Ethics & Compliance Office
Or contact:
EthicsLine
This reporting service is run by an independent third party, is available 24-7
and allows you to remain anonymous, where permitted by law. You may
either call or report online. Translation services are also available.
To reach EthicsLine:
Visit www.KOethics.com
or Call toll-free using the access code for your country,
which can be found on the website.
Special note for the European Union: Many countries in the European Union
limit the types of reports you can make to EthicsLine. Find out about these
limitations on the Ethics & Compliance intranet and the EthicsLine website.
For legal inquiries:
Contact local legal counsel
For possible criminal matters:
Contact local strategic security
For accounting and finance
policy and procedure inquiries:
Contact local senior finance personnel
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
BE AWARE
Question or Concern? Log on to EthicsLine @
www.KOethics.com
9
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
Reporting Concerns
continued
What Happens When You Report a Code Concern
You may choose to remain anonymous, where permitted by law.
If you do give your name, we will do all we can to protect your identity
consistent with conducting a thorough investigation.
We take every report seriously and our Corporate Audit Department
Code investigation team (or a delegate for locally-managed or other
matters) will investigate it thoroughly and as confidentially as possible.
We expect everyone involved to cooperate fully and honestly.
To ensure consistency in analyzing matters that arise all over the
globe, outcomes from the investigation are presented to the Ethics &
Compliance Committee (or its delegate for locally-managed matters)
who will determine, based on the investigatory facts presented, if
there has been a violation of the Code.
If the Ethics & Compliance Committee determines that the Code has
been violated, it will determine a fair and consistent disciplinary action
in accordance with applicable law.
Those found to have violated the Code can seek reconsideration
in accordance with our Guidelines for Handling Code of Business
Conduct Matters.
For more information on the Code investigation and decision-making
process, consult our Guidelines for Handling Code of Business
Conduct Matters.
No Retaliation
You are the eyes and ears of our Company, and we value your help in avoiding
and uncovering possible misconduct. We strictly prohibit retaliation of any
kind against anyone who shares a good-faith concern or participates in
a Code investigation. Sharing a good-faith concern about the Code honestly,
even if it turns out to be unfounded
–
is never an excuse for any kind
of retaliation.
What is Retaliation?
We define retaliation under our Code as any action that would likely deter
someone from reporting a Code concern or participating in a Code investigation.
Examples of retaliation might include demotion, firing, a reduced salary, job
reassignment, threats, harassment or any other action taken against someone
because they raised a Code concern, participated in a Code investigation,
or attempted to deter someone from violating the Code. While we take the
anti-retaliation provisions of our Code very seriously, these provisions do
not protect you from disciplinary action for your own misconduct, meaning
you should not report a Code concern simply to avoid discipline for your own
violation of the Code or other Company policy.
No False Accusations
As much as we encourage honest reporting, we do not tolerate knowingly
false reports. Making a false accusation can divert investigatory resources
away from credible good-faith concerns and damage morale. Report what
you have a reasonable, good-faith belief be true, but never knowingly make
a false accusation, lie to investigators or refuse to cooperate in an investigation,
as these actions may also violate our Code.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
BE AWARE
Question or Concern? Log on to EthicsLine @
www.KOethics.com
10
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
PROTECT
WHAT IS OURS
WE CARE FOR ALL ASSETS THAT
MAKE US COCA-COLA.
We Protect Non-Public Information
We Safeguard Company Assets
We Maintain Accurate Records
We Prevent Money Laundering
Care for
Our Communities
A Fountain
of Information
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
PROTECT WHAT IS OURS
Question or Concern? Log on to EthicsLine @
www.KOethics.com
11
Deal Fairly
with Others
A Fountain
of Information
Demonstrate
Accountability
Care for
Our Communities
Table of
Contents
Be
Aware
Protect What
Is Ours
We Protect Non-Public Information
What We Believe
The formula for Coca-Cola is one of the best-kept secrets ever. We are good
at keeping this and a lot of other non-public information confidential. This is
because we understand that protecting the non-public information about
our Company helps us maintain our competitive advantage and preserve
our reputation as the industry leader.
How We Live It
Our responsibility when it comes to
information is:
»
»
Knowing the kinds of information
considered confidential.
»
»
Knowing the ways to protect it.
We consider any
non-public information
about the Company as well as certain
information about our customers, suppliers,
other business partners or consumers that
you may have (or access) as part of your
job, to be confidential information. It can be
written, spoken or electronic.
We use a classification system to identify and protect non-public information.
Details about information classification can be found in the Information
Protection Policy.
Share non-public information only with those who have both the authorization
to access it and a need to know the information in order to do their jobs. Take
appropriate steps to protect classified information such as asking companies
or individuals outside of Coca-Cola to sign a confidentiality agreement before
gaining access to our information and follow other rules described in the
Information Protection Policy. If you are not sure whether information can be
shared or how to share it, ask your manager or Company legal counsel.
What Else Can You Do?
Watch what you say.
Sharing non-public information with friends or family,
or discussing it in public places such as elevators, public transportation
and restaurants or on social media can put that information at risk of being
disclosed (and possibly misused). Do your part to keep it safe. (Note that this
is not intended to limit or interfere with your rights under the law
–
see the
Your Rights as an Employee section
).
Remember: your duty regarding
non-public information lasts beyond your
employment.
Your commitment to protect
non-public information applies to work
you did before you came to the Company,
and it applies when you leave. Never share
non-public information from your former
employer(s)
–
or ask others to do so
–
and,
if you leave Coca-Cola, do not share our
non-public information with others.
WHAT IS NON-PUBLIC
INFORMATION?
Non-public information about
our Company can include ...
- Business plans, product
formulas, marketing strategies
and new product launches
- Financial information such
as pricing, proposals and
product costs
- Operational information such
as major management
changes and plans for
mergers and acquisitions
ONE MORE SIP
Information Protection Policy
Confidentiality Agreement
and Procedures
Personal and Sensitive
Personal Information
Pop the
Question
Q
My supervisor travels a lot and is very busy. During one of her business trips, she
asked me to log into a Company system that has highly restricted information using
her user ID and password to retrieve some reports that I would not otherwise have
access to. Is that okay?
A
No. It is against Company policy to share passwords. Also, access to highly restricted
information should be limited only to those who are authorized to have access. You
should refuse the request and remind the supervisor that you do not have access to
this system and this information due to its sensitivity. Immediately report this to your
manager, your Local Ethics Officer, the Ethics & Compliance Office or EthicsLine, any
of which can help you address this situation properly. In instances where you would
otherwise be authorized to access the information, steps should be taken to provide
you with appropriate access without using the password of another user.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
PROTECT WHAT IS OURS
Question or Concern? Log on to EthicsLine @
www.KOethics.com
12
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
We Safeguard Company Assets
What We Believe
The buildings we work in, the technology that connects us to others, the
ideas we develop, the emails we exchange, the Company tickets we offer, the
vehicles we use to deliver our product, the computers and mobile devices we
use to do our jobs ... all of this and more are
Company assets
that we are each
entrusted to protect. We use them to carry out Company business and must
protect them from damage, loss, misuse and theft.
How We Live It
Do not use Company assets:
»
»
For an outside business or other personal gain
»
»
For anything illegal or unethical (such as access
to
–
or dissemination of
–
pornographic or
offensive subject matter)
Personal use of some assets, within reason and as allowed by local policies
and procedures, is permitted, but your use should be appropriate, infrequent,
lawful and never interfere with the time, talent and passion you, or any other
employees, bring to work. Personal use may require LEO approval.
Physical assets -
Physical property and resources are made available to each
of us to help us do our jobs. When you safeguard the Company’s assets, you
safeguard our ability to grow and to thrive. Never lend, sell or give them away
unless you are authorized to do so.
Electronic assets -
We count on every employee to appropriately utilize
electronic assets (including computers, hardware, software, mobile devices
and other media). You can do your part by following our policies and using
good judgment. Be aware that any information you create, share or download
onto Company systems belongs to the Company, and we reserve the right to
monitor system use at any time, to the extent permitted by law.
Intellectual property (IP) -
Patents, copyrights, trademarks and trade secrets
are also valuable Company assets. Protect IP with a passion, and remember
that the Company owns any work product (such as ideas, processes and
inventions) that you develop or design in your work with us to the extent
permitted by law. That ownership continues even if you leave our Company.
Did You Know?
»
»
Loans from the Company to any employee are discouraged and must be
approved by the Board of Directors or its designee. Loans to executive
officers are prohibited.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
PROTECT WHAT IS OURS
Question or Concern? Log on to EthicsLine @
www.KOethics.com
13
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
We Safeguard Company Assets
continued
What Else Can You Do?
Observe good security practices.
Use care with any property that has been
issued to you (such as keys or building access cards), and do your part to
prevent misuse, unauthorized use, or access to our facilities.
PROCESS POINT
The use of any Company assets outside
of your Company responsibilities
–
for
example, using a Company computer
to take a class, a piece of equipment
for a home project, or Company tickets
for personal reasons (excluding those
properly accessed through our ticket
management system)
–
requires
advance written approval from your
Local Ethics Officer. This approval must
be renewed annually if you continue to
use the asset outside of work.
ONE MORE SIP
Acceptable Use Policy
Local Ethics Officer
Approval Tool
Pop the
Question
Q
The senior leader of my organization asked for my help in organizing a small silent
auction for a fundraiser to benefit a charity that she supports but which is not
sponsored by the Company. She will be inviting everyone from the department to
attend, and she will be hosting it in Company conference space. Is this an appropriate
use of Company assets?
A
No. Even though well-intentioned, these actions would constitute a misuse of
Company assets. It might also be a violation of other Company policies depending
on your location. You should let this leader know that you cannot assist her in this
capacity. If you feel uncomfortable telling her “no,” you should consult with your
Local Ethics Officer or the
Ethics & Compliance Office
.
Q
I work at a distribution facility and need to move some furniture out of my apartment.
The Company has a small, wheeled platform that would help make moving easier.
Can I borrow it for a day?
A
It depends. Any use of a Company asset like this for a personal reason would require
approval by your Local Ethics Officer.
Q
I am an Account Manager and acquired two Company-owned tickets for a customer and
myself to attend a sold-out concert of a popular band playing in town. At the last minute,
however, my customer tells me he cannot attend. Can I still use the tickets myself?
A
You should make every reasonable effort to find a business use for the tickets first.
Check with your manager and other colleagues to see if they might know of an
appropriate business use. If not, you should check with your
Local Ethics Officer
and
any rules or policies applicable to usage to see whether personal use is an option or if
the tickets should be disposed of another way and to obtain all necessary approvals.
At all times, remember to be honest and transparent about the use of the tickets.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
PROTECT WHAT IS OURS
Question or Concern? Log on to EthicsLine @
www.KOethics.com
14
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
CONSIDER THIS
“Make the numbers work.”
“Hold that sale until next month so
we can meet next quarter’s target.”
“Punch my timecard for me because
I am running a little late.”
Hearing comments like these?
Stop and seek help. If it sounds
illegal or unethical, it probably is.
We Maintain Accurate Records
What We Believe
Accurate recordkeeping and reporting helps us meet our legal and regulatory
requirements. Maintaining financial integrity also reflects positively on our
reputation and credibility. Each of us
–
at every level of our Company
–
has a
responsibility for ensuring the accuracy of all Company business and financial
records.
How We Live It
From resumes, time sheets and benefit claim forms to expense reports, quality
assurance records, budget forecasts and regulatory filings, we all handle
Company “records.” Be sure to follow all internal processes, policies and
generally accepted accounting principles so that our records accurately reflect
all transactions. Be honest, accurate and complete in what you record.
What Else Can You Do?
Properly classify transactions.
It is
important that we never distort the
true nature of any transaction. Make
sure you always record and classify
transactions in the proper accounting
period and in the appropriate account
and department. Never speed up or
slow down the recording of a revenue or
expense in order to meet a budgetary
goal.
Maintain our high standards.
We do
not falsify or mischaracterize any
record, account or transaction. And we
cannot establish any undisclosed, unrecorded or off-the-record accounts for
any purpose. If you submit expenses for reimbursement or make payments
on behalf of our Company, include any supporting documentation and
approvals that are required. Estimates and accruals must also be supported by
appropriate documentation and based on your best judgment.
Be honest with regulators.
If your job requires that you disclose information to
the government or regulatory authorities, make sure the information you pro-
vide is full, fair, accurate, timely and understandable.
Manage records properly.
Know and follow the policies that relate to
maintenance, storage and disposal of records. Never destroy or dispose
of information that might be needed for an investigation, an audit or a legal
proceeding. If you receive a legal hold notice, follow the guidelines in the
notification. And, if you are not sure about what is required, check Legal
Counsel and our document retention policy
Pop the
Question
Q
Our team did not utilize all of our approved project budgets this year. In order to
maintain this level of funding in the future, is it okay to ask a supplier to pre-bill us this
year for one of next year’s projects, referencing a current-year purchase order?
A
No. Doing this would falsify expenses recorded in our books and records,
misrepresenting the timing of actual spend. The law requires us to maintain accurate
records and management relies on accurate financial records to steward the business
and make decisions. This action would constitute a violation of our Code.
Q
I work in Quality. During a very busy time, I documented that certain tests were
performed even though I was not able to complete them. The test usually works fine
so the risk of a problem seems very low. Is this a reasonable approach?
A
No. Our customers and consumers trust the quality of our products, so we should never
cut corners or misstate results. Falsifications of this nature represent a Code violation.
Q
I work in Sales and am currently trending below my volume target. I was thinking
about asking a customer to order product that they do not need now, telling them
that they can always return it after the period closes. Is this okay?
A
No. Manipulating the recording of revenue would violate our Code. The request would
likely also put the customer in a terrible position that could damage the relationship.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
PROTECT WHAT IS OURS
Question or Concern? Log on to EthicsLine @
www.KOethics.com
15
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
What We Believe
We would never knowingly look the other way when it comes to illegal
activities, but we understand that criminal activity like money laundering may
not always be obvious, so it is important that we work to reduce our exposure
and speak up about anything suspicious.
How We Live It
Money laundering is a process where
funds generated through criminal
activity
–
such as terrorism, drug
dealing, tax evasion, human trafficking
and fraud
–
are moved through
legitimate businesses in order to hide
their criminal origin. We are committed
to conducting business in a way that
prevents the use of our business
transactions by those who might abuse
them, so we comply with anti-money
laundering, financial crime and anti-
terrorism laws in all countries where
we operate.
We take the time to know our
suppliers
and
other business partners
and the
reputations they have for following the
law, by performing appropriate due
diligence and screenings.
Be proactive when it comes to spotting
financial transactions that might signal
a problem, and report your concern if
you see or suspect an activity or transaction
that is outside of normal process.
What Else Can You Do?
Be alert.
Large cash payments or unusual fund transfers to or from foreign
countries? Customers or suppliers who provide incomplete information or
avoid recordkeeping requirements? These could be warning signs. Know
the types of transactions and activities in your department that are more
susceptible to acts of money laundering and require increased monitoring.
Report any unusual activity to your manager, Local Ethics Officer, Ethics &
Compliance Office or EthicsLine.
CONSIDER THIS
Red flags may include a request to ...
Transfer payment to or from entities
or countries not related to the
transaction
Process a transaction in a way that
circumvents the normal process
Exchange many small-denomination
bills for a large one
Make payments in cash
Red flags are a signal to ask more
questions to better understand the
transaction. If it sounds suspicious,
speak up
–
awareness is the key to
combatting money laundering.
We Prevent Money Laundering
PROCESS POINT
One of the best ways to prevent money laundering is to comply with
our
due diligence screening procedures
.
Request for third-country payments: We do not make it possible for others to avoid
taxes or local currency laws. That is why, in general, a payment to a supplier should
be made only to the person or company that actually provides the good or service,
in a country where the supplier either does business or has sold goods or provided
services to our Company. Exceptions to this policy must be
approved by the
Ethics & Compliance Office
.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
PROTECT WHAT IS OURS
Question or Concern? Log on to EthicsLine @
www.KOethics.com
16
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
DEMONSTRATE
ACCOUNTABILITY
OUR NAME IS SYNONYMOUS WITH INTEGRITY,
AND IT IS UP TO US TO KEEP IT THAT WAY.
We Avoid Conflicts of Interest
We Are Responsible with Gifts,
Meals and Entertainment
We Build Transparent Relationships
Care for
Our Communities
A Fountain
of Information
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
DEMONSTRATE ACCOUNTABILITY
Question or Concern? Log on to EthicsLine @
www.KOethics.com
17
Deal Fairly
with Others
A Fountain
of Information
Demonstrate
Accountability
Care for
Our Communities
Table of
Contents
Be
Aware
Protect What
Is Ours
What We Believe
We are all expected to act in the best interest of our Company. This means we
must never allow our personal interests to influence our actions on behalf of
the Company. Every decision we make while on the job must be objective and
with our Company’s business interests in mind.
How We Live It
In business, the line between personal
and professional interests can become
easily blurred. Separating the two can be
challenging, especially when personal
relationships, outside employment or
investments are involved.
Before you act on the Company’s behalf,
you need to be able to recognize and
avoid potential conflicts of interests.
A conflict happens when you allow
personal interests to interfere with the
business decisions you make as an
employee. Even the appearance of a
conflict is inappropriate and can damage
our Company and our reputation.
Get to know the types of situations that can lead to conflicts or the appearance
of a conflict. Potential conflicts should be disclosed and approved via the Local
Ethics Officer Approval Tool.
What Else Can You Do?
Recognize potential conflicts
. You may not realize right away that a situation
may be a conflict of interest. Conflicts take many different forms, but very often
they involve:
Personal Investments and Opportunities
.
In building your financial
portfolio, you will find many companies in which to invest. Be aware that
there are rules when these investments involve Company
suppliers
,
customers
,
competitors
or
other business partners
, especially if you deal
with these organizations through your job. This would be a conflict, as
would taking an opportunity for personal gain that you discovered through
your work.
Did You Know?
»
»
If you have
discretionary authority
to deal with a
supplier
,
customer
or
other business partner
, you may not have any financial interest in that
company without the approval of your LEO. If you have no discretionary
authority with that company, you may own up to 1% of its stock, as well
as up to 1% of the stock of a competitor.
»
»
With your LEO’s approval, you may own more than 1% of any customer,
supplier, other business partner or competitor stock so long as you do
not have discretionary authority.
»
»
These rules apply to publicly traded and privately held companies.
But, these restrictions do not apply to mutual funds or other
investments that hold a broad range of companies where you do
not control which companies are in the fund.
»
»
Approvals under this section must be renewed annually if you continue
to own the stock.
CONSIDER THIS
When someone says
…
“Could you put in a good word for me?”
“No one needs to know
–
you can do
the work in your free time.”
“My nephew has a company
…
”
Be aware. These can be warning
signs of a possible conflict.
We Avoid Conflicts of Interest
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
DEMONSTRATE ACCOUNTABILITY
Question or Concern? Log on to EthicsLine @
www.KOethics.com
18
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
Outside Employment
.
Having a second job or consulting opportunity is
permitted so long as it does not interfere with your ability to do your job with
the Company.
Did You Know?
Before taking any second job or consulting opportunity with a customer,
supplier, other business partner or competitor, you must seek approval
from your LEO.
Outside Speeches or Presentations
.
We are often asked to speak at
conferences or make presentations because we are Company employees or
because of our expertise arising from our job responsibilities. A conflict can
arise if you are offered payment or reimbursement of expenses in connection
with this.
Did You Know?
Honorariums from our suppliers, customers and other business partners are
prohibited, and those from other organizations are generally discouraged and
should be declined. If you are unable to decline an honorarium, you should ask
that a donation be made in your honor to a charity of your choice directly by the
paying entity.
Before accepting an honorarium, other payment or reimbursement for
expenses from any third party for outside speeches or presentations, you must
receive approval from your LEO if:
»
»
Your speech or presentation is a part of your job with the Company.
»
»
It describes your work for the Company.
»
»
You are introduced as an employee of the Company.
If your speech or presentation will discuss matters related to the Company, you
may also need approval from your manager,
Public Affairs
,
Legal Counsel
and
others regarding your content.
We Avoid Conflicts of Interest
continued
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
DEMONSTRATE ACCOUNTABILITY
Question or Concern? Log on to EthicsLine @
www.KOethics.com
19
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
Serving Other Organizations
.
Accepting a role as director, advisory member
or officer for another organization may interfere with your obligations to the
Company and create a conflict of interest. Approval from the
Ethics & Compliance
Office
is required as outlined below. The Company generally discourages sitting
on the board of a customer or supplier if you have discretionary authority in
dealing with that customer or supplier as part of your job.
For-profit service:
If you serve as a director, advisory member or officer of a
for-profit company, you must disclose this service to the
Ethics & Compliance
Office
and receive approval. Disclosure and approval is required on an annual
basis with the exception of those circumstances where the Company requests
that you sit on a bottler or equity investee board as part of your job for the
Company. In such instances, approval is only required at the time of
appointment in accordance with the Delegation of Authority.
Non-profit service:
If you serve as a director, advisory member or officer of
a non-profit organization and you have discretionary authority over whether
money or other support will be provided on behalf of the Company to the
non-profit, you must disclose this service to the
Ethics & Compliance Office
and receive approval on an annual basis.
Family-owned business or trade association
/
organization:
Annual disclosure
and approval by the
Ethics & Compliance Office
for service to a family-owned
business or trade association is only required where the family-owned business
or trade association is a customer, supplier or competitor of the Company.
Did You Know?
If you are offered a salary as part of your service, you may retain that salary.
»
»
If you serve as director of a bottler or equity investee at the Company’s
request, you may own up to one percent of their stock without
Ethics &
Compliance Office
approval if stock ownership is a condition of your service.
»
»
Unless your service as a director is for a bottler or equity investee or has
otherwise been designated as having a legitimate business purpose for the
Company, service to another organization is considered a personal activity
and should not interfere with your ability to do your job with the Company,
and time away from work to support this activity is subject to applicable
time-off and vacation polices.
»
»
Service as a director, advisory member or officer of a
competitor
requires
annual
Ethics & Compliance Office
review and approval.
Personal Relationships
.
Many of our employees may have
relatives
who
work for, or have investments in, our
customers
,
suppliers
,
other business
partners
or
competitors
. Having a personal relationship with any third party
that you work with can suggest to others that you give preferential treatment
to your friends and family. Conflicts may arise if either your relative interacts
with the Company on the third party’s behalf, or if you have discretionary
authority in dealing with that third party. Occasionally, friendships you develop
with individuals associated with our customers, suppliers or other business
partners may also have at least the appearance of influencing your actions on
behalf of the Company.
Did You Know?
»
»
You need the approval of your LEO if your relative works for, or has
an investment in, a customer, supplier or other business partner,
and either:
»
»
You have discretionary authority in dealing with the third party, or
»
»
Your relative deals with the Company on behalf of the third party.
»
»
You also need the approval of your LEO if your relative works for,
or has any investment in, a competitor
–
a relative may own less
than 1% of stock in a competitor if it is a publicly-traded company
without LEO approval.
»
»
A relative can be a: spouse, sibling, parent, grandparent, child,
grandchild, in-law or a same or opposite sex domestic partner.
For the purposes of our Code, a relative can also be someone who
lives with you, someone who is financially dependent on you, or who
you are financially dependent upon regardless of familial relationship.
»
»
Beyond the relative definition above, be careful that your relationships
with other family members and friends do not interfere with your
ability to make decisions on behalf of, or otherwise do your job for, the
Company, as these other close relationships may also create a conflict.
»
»
If you are unsure if a personal relationship creates the appearance
of a conflict, contact your manager,
Local Ethics Officer
, the
Ethics &
Compliance Office
or
EthicsLine
. Always err on the side of disclosure.
We Avoid Conflicts of Interest
continued
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
DEMONSTRATE ACCOUNTABILITY
Question or Concern? Log on to EthicsLine @
www.KOethics.com
20
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
IS IT A
CONFLICT?
ASK YOURSELF ...
COULD IT LOOK
THAT WAY TO
SOMEONE ELSE?
COULD MY PERSONAL
INTERESTS OR
RELATIONSHIPS
INFLUENCE THE
DECISIONS I MAKE?
IF
YES
, IT IS PROBABLY
A CONFLICT. SEEK
GUIDANCE WHEN
YOU ARE NOT SURE.
We Avoid Conflicts of Interest
continued
ONE MORE SIP
Director Appointee Guidelines
Delegation of Authority
Employment of Relatives Policy
Pop the
Question
Q
Through my relationship with a supplier to whom I have recently awarded a contract,
I became aware that this supplier is expanding and buying a smaller company. Based
on the information gathered and the potential growth and opportunity, I would like
to purchase stock in the supplier. Can I do this without approval given my current role
with the Company?
A
No. Since you have discretionary authority in dealing with the Company as part of
your job, you may not have any financial interest in that company without prior
written approval from your Local Ethics Officer. Additionally, this investment
would be considered insider trading, which is a violation of the Code and the law.
Q
I noticed that a customer’s stock is doing well and would be a good personal
investment for me and my family. Can I invest in the customer’s stock since
I have no contact with the customer as part of my job?
A
Yes. If the investment is 1% or greater, you would need prior Local Ethics Officer
approval. Since your current position does not involve contact with the customer,
your request would likely be approved by your LEO and would require subsequent
annual approvals.
Q
I am responsible for planning a big meeting at our facility and need a caterer.
Coincidentally, my sister just started a catering business. This event would be a big
help to her. I know she would do a great job and offer great pricing. Can I hire her?
A
No, not without approval from your Local Ethics Officer. Even though there may be
legitimate reasons for hiring her, it could look to others that she was awarded the
job just because she is your sister.
PROCESS POINT
If you feel you may be getting involved
in a possible conflict of interest or the
appearance of one, report it immediately
to your Local Ethics Officer through
the LEO Approval Request Tool or
another technology solution approved
by the Ethics & Compliance Office. Not
disclosing a conflict is serious and
could lead to disciplinary action.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
DEMONSTRATE ACCOUNTABILITY
Question or Concern? Log on to EthicsLine @
www.KOethics.com
21
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
What We Believe
We value the relationships we have built with our
customers
,
suppliers
and
other business partners
. It is important that these relationships
remain positive and ethical
–
never influenced by offers of inappropriate
gifts or hospitality.
How We Live It
The exchange of gifts and entertainment is nothing new in business. It is a
traditional way to express gratitude and build relationships. But an overly
generous gift can pressure the recipient to return the favor or feel indebted to
the giver
–
with decisions that benefit the giver and create a conflict of interest
or perception of a conflict of interest.
The Company’s policy is simple. We do not exchange gifts or entertainment
that look like an attempt to improperly influence a business decision. No matter
if you are the giver or the recipient, you need to recognize when an offer is
excessive under our policy.
It can be difficult to tell when a gift crosses the line, and laws and customs in
different countries vary widely. That is where our position on gifts, meals and
entertainment can help. Read the provisions in this section closely to learn
what is or is not acceptable.
What Else Can You Do?
Just say “no.”
Decline gifts of any value from current or potential suppliers,
customers or other business partners if it would create the appearance of
a conflict of interest. And never request gifts, meals, entertainment or favors
from these third parties
–
doing so is a violation our Code.
We Are Responsible with Gifts, Meals and Entertainment
CAN I EVER
ACCEPT A GIFT?
ONLY ACCEPT
IF IT IS:
»
»
Modest in value
»
»
A token item like a pen, t-shirt
or logo branded item
»
»
Symbolic, like a modestly-
priced, inscribed trophy
or statue
»
»
Approved for a large group
of employees
DO NOT ACCEPT IF IT IS:
»
»
Given in exchange for some action
»
»
Any value of cash or a cash equivalent,
like a gift card or gift certificate
»
»
In the form of stocks or securities
»
»
More than modest in value
»
»
Not available to others, like a special discount
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
DEMONSTRATE ACCOUNTABILITY
Question or Concern? Log on to EthicsLine @
www.KOethics.com
22
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
We Are Responsible with Gifts, Meals and Entertainment
continued
Sometimes, you may not be sure if
a gift is excessive or not, for example:
Do I need to do anything if I receive a gift?
If you receive a gift that exceeds
these limitations, you must contact your Local Ethics Officer for approval.
Be mindful that there are some gifts that your Local Ethics Officer cannot
approve, such as gifts of stock
/
securities, cash or cash equivalents.
But I might offend the giver!
Sometimes it can be difficult to refuse a gift,
especially if you are worried about insulting the giver or if you have been
presented with a gift in front of a group. If you cannot decline the gift, accept
it, but immediately notify your Local Ethics Officer, who will work with you to
donate, distribute or raffle it among a large group of employees. Also, share
our Company’s rules regarding gifts with the giver to help prevent similar
situations in the future.
What about meals and entertainment?
Just as you do with gifts, do not
accept meals or entertainment in exchange for some action. We recognize
that sharing meals and entertainment is common in business, so you may
accept occasional meals from customers, suppliers and other business
partners if they also attend, and the costs are reasonable and customary.
Travel and Premium Events.
If you receive an offer of paid travel to an out-of-
town location or to a premium event like the Olympics, World Cup, Super Bowl
or an award show, first, talk to your manager. Together you can determine
if there is a good business reason for you to attend. Then, if there is a good
business reason to attend, the Company should at a minimum pay for your
travel (airfare and lodging) and any other expenses deemed appropriate by
your Local Ethics Officer. Receipt of travel or premium event tickets should
always be approved by your Local Ethics Officer.
WHEN IT IS OKAY
WHEN IT IS NOT OKAY
AN OFFER TO GO
TO LUNCH WITH
A NEW SUPPLIER
A GIFT BAG AT
A SUPPLIER’S
CONFERENCE FILLED
WITH SNACKS AND
SMALL TOILETRIES
A GOLF OUTING AND
LUNCH AT A LOCAL
COURSE WITH
A SUPPLIER
AN OFFER TO HAVE A
DRINK WITH A SUPPLIER
A SMALL DESK CLOCK
WITH A SUPPLIER’S
CORPORATE LOGO
AN EXTRAVAGANT
MEAL FOR YOUR
WHOLE FAMILY PAID
FOR BY A SUPPLIER
NOT IN ATTENDANCE
A GIFT BASKET FILLED
WITH AN EXPENSIVE
ELECTRONIC FITNESS
TRACKER, AMONG
OTHER ITEMS, SENT
TO YOU BY A SUPPLIER
AIRFARE AND
ACCOMMODATIONS
AT A GOLF RESORT
A CASE OF
FINE WINE
AN EXPENSIVE
WATCH
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
DEMONSTRATE ACCOUNTABILITY
Question or Concern? Log on to EthicsLine @
www.KOethics.com
23
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
We Are Responsible with Gifts, Meals and Entertainment
continued
What about giving gifts, meals and entertainment?
There are also times when
you may need or want to provide gifts, meals or entertainment to a business
contact. In these instances, be sure that the gift, meal or entertainment
supports a legitimate business purpose and is reasonable and appropriate
under the circumstances. Always be mindful that our business partners have
their own rules on receiving gifts, meals and entertainment and never offer
anything that would violate those rules and put the business partner in a
potentially uncomfortable position.
ONE MORE SIP
Travel & Entertainment Policy
Local Rules
PROCESS POINT
Depending on where you work, your
local management team
–
in consultation
with the Ethics & Compliance Office
–
may adopt more specific limits on
what you may accept. You can find
more information on the Ethics &
Compliance intranet site.
Pop the
Question
Q
An agency I work with knows that I am an avid skier. Before the holidays, they sent
me ski equipment and clothing to use on my family vacation. This firm has worked for
our Company for many years with good results, and everyone wants to continue the
relationship. Can I accept the gift?
A
No. A gift of this nature is lavish and clearly beyond what would be acceptable. It creates
the appearance that we make decisions based upon what is given to us personally
rather than what is best for the Company. Therefore, the gift must be returned.
Q
A supplier invited me to go with him to a sold-out concert. Two days before the concert,
his plans changed and he gave me the tickets so that I could take my spouse instead.
Can I accept the tickets?
A
No. In this situation, the tickets from the supplier are a gift. The event would be
considered entertainment only if the supplier joined you for the concert. Since the
tickets are of more-than-modest value, you cannot accept them without LEO approval.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
DEMONSTRATE ACCOUNTABILITY
Question or Concern? Log on to EthicsLine @
www.KOethics.com
24
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
We Build Transparent Relationships
What We Believe
Our
suppliers
,
customers
,
consumers
and
other business partners
place a
great deal of trust in our brands and we are determined to never let them down.
We see them as real partners
–
essential to our Company’s growth and success.
How We Live It
Our relationships with our suppliers, customers, consumers and other business
partners must be fair, positive and productive, always based on mutual trust
and respect. Building these relationships is an ongoing process and requires
an enduring commitment to high standards of business conduct. In every
interaction we have with these third parties, we must demonstrate honesty
and a commitment to our values.
Just one deceptive or dishonest act can seriously damage a relationship.
So make sure you understand your responsibilities and always deal fairly
with our suppliers, customers, consumers and other business partners.
Integrity is not a unilateral obligation
–
it is a responsibility we share with our
suppliers and other business partners. That is why we require our suppliers
and certain other business partners to adhere to our Supplier Code of Business
Conduct. If you are responsible for a supplier relationship, help us ensure that
we are only doing business with suppliers and other business partners who
share our commitment to doing what is right by including contractual
provisions regarding our Supplier Guiding Principles and, where applicable,
supporting audits to ensure compliance.
What Else Can You Do?
Speak the truth.
Everything we tell our
customers, suppliers, consumers and
other business partners must be truthful,
including our product labels, advertising
and other communications. Do not
engage in any unfair, deceptive or
misleading practices.
Treat them fairly.
Be fair and honest in your interactions with customers,
suppliers, consumers and other business partners. Avoid anything that even
looks like a possible conflict of interest, and do not offer or provide anything
to these business partners in exchange for an advantage for the Company.
Ensure their accountability.
If you work with any supplier or other business
partner, make sure they know about and uphold their commitment to our
Supplier Code and any other policies. Hold them accountable for any violations
that you see or suspect.
Choose suppliers ethically.
If you are involved in selecting suppliers for the
Company, make your choice objectively, selecting them based on price, quality
and services they offer. Follow all procurement requirements.
Respect our government partners, too.
If your work involves government
interactions or compliance with government inspections, investigations or
requests for information, cooperate fully
–
make sure you understand the rules
and regulations that apply to you, and that any information you submit on behalf
of the Company is accurate and truthful. Similarly, if your work involves sales to
the government, make sure you know and follow all of the procurement, sourcing,
due-diligence and other requirements that relate to this work. If your work involves
managing a government contract, make sure we are meeting our obligations.
ONE MORE SIP
Privacy Policy
Supplier Code of
Business Conduct
Pop the
Question
Q
During a call with a customer, my co-worker provided inaccurate information to them.
I am hesitant to contact them because I do not want them to think we are dishonest.
What should I do?
A
It would be a violation of our Code to deliberately leave out important information.
You and your co-worker should reach out to the customer immediately and correct
any mistakes. While the customer may be unhappy that they received the incorrect
information initially, your honesty will be appreciated in the end by the customer and
the Company.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
DEMONSTRATE ACCOUNTABILITY
Question or Concern? Log on to EthicsLine @
www.KOethics.com
25
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
DEAL FAIRLY
WITH OTHERS
WE HAVE BUILT A REPUTATION FOR
DOING THINGS THE RIGHT WAY.
We Compete Fairly
We Comply with Trade
Compliance Laws
We Do Not Tolerate Bribery
We Do Not Trade on
Inside Information
We Follow Privacy Laws
Care for
Our Communities
A Fountain
of Information
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
DEAL FAIRLY WITH OTHERS
Question or Concern? Log on to EthicsLine @
www.KOethics.com
26
Deal Fairly
with Others
A Fountain
of Information
Demonstrate
Accountability
Care for
Our Communities
Table of
Contents
Be
Aware
Protect What
Is Ours
We Compete Fairly
What We Believe
We compete fairly and within legal boundaries. We know that everyone benefits
from a competitive marketplace, so we follow the antitrust and fair competition
laws in all locations where we operate and avoid even the appearance of unfairly
restricting another company’s ability to compete against us.
How We Live It
We build market share and brand loyalty by delivering quality products, not
by engaging in unfair or anti-competitive practices. Some agreements with
customers
,
suppliers
,
competitors
or
other business partners
have the
potential to limit free and open competition, so if you are responsible for areas
of our business where antitrust or fair competition laws apply, make sure you
know how they apply in the country (or countries) where you operate.
Never enter into any agreement or understanding
–
even an informal
understanding
–
with a competitor to:
»
»
Set prices on our products and services
»
»
Divide territories, markets or customers
»
»
Prevent another company from entering the market
»
»
Participate in any form of bid rigging
»
»
Refuse to deal with a customer or supplier for improper reasons
»
»
Boycott another company
What Else Can You Do?
Be careful at conferences and trade shows.
Do not discuss or exchange
information with competitors (or potential competitors) about topics such
as pricing, costs, terms or conditions of sale, market segments, clients or
marketing strategies. If a discussion turns to a competitively sensitive subject,
stop the conversation, remove yourself from the situation and immediately
report the incident to Company legal counsel.
Gather
competitive intelligence
ethically and lawfully.
Obtaining information
about our competitors is a normal business practice and necessary to be an
effective competitor, but make sure you do it properly. Use public or other
permitted sources and be honest about who you are and who you work for. Do
not gather, or ask someone else to gather, information using any illegal or illicit
activity; refer to the Competitive Intelligence Policy for what illicit activity means.
Follow the steps in the Competitive Intelligence Policy when you receive or are
offered competitive intelligence from internal or external sources.
Win business the right way.
Deal honestly and fairly with our customers.
Promote positive business relationships and never take unfair advantage of
anyone by misleading or deceiving them. Be truthful about our Company and
what we sell
–
do not make any claims you cannot substantiate, and do not
make inaccurate remarks about our competitors or erroneous comparisons
between their products and ours.
Consult with Legal Counsel.
The Company employs competition law experts
who can help you assess the legality of any proposed conduct. Reach out to
them for guidance before you act.
ONE MORE SIP
Competition Law Guidelines
Competitive Intelligence Policy
PROCESS POINT
In gathering competitive information, make sure you ...
»
»
Review the information to determine whether it is highly
sensitive or marked confidential.
»
»
Ask if anyone has an obligation to keep the information confidential.
»
»
If necessary, consult with Company legal counsel.
»
»
Document how you handled the information.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
DEAL FAIRLY WITH OTHERS
Question or Concern? Log on to EthicsLine @
www.KOethics.com
27
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
We Comply with Trade Compliance Laws
What We Believe
Our products are enjoyed around the world, so we are careful to comply with
the laws and regulations that govern international trade. We expect those in our
Company to know and understand the requirements that apply to the movement
of our products, services and technologies.
How We Live It
In order to put our products into the hands of consumers everywhere, we follow
all applicable import and export laws and regulations associated with the
countries where we operate. We do not conduct unauthorized business with
countries or third parties that are subject to trade embargoes or economic
sanctions. And, as a United States-based company, we cannot participate in
boycotts that the United States does not support.
What Else Can You Do?
Follow the rules.
If you are responsible for or involved with the movement
of Company goods (including ingredients, finished product, promotional or
marketing items, equipment, etc.), people, services, technology, money or
information across international borders, make sure you know and comply
with the trade laws and regulations of the countries in which you do
business. Be aware that the laws of more than one country may apply.
Know the end-use and end-user of our transactions and be aware of
applicable programs to reduce duties and tariffs.
ONE MORE SIP
Trade Sanctions Policy
Anti-Boycott Policy
Import
/
Export Policy
PROCESS POINT
More information about your obligations as
they relate to U.S. trade restrictions, as well as
restrictions that may be imposed by governments
other than the U.S., can be found on the International
Trade Group intranet site.
If you are writing a contract, you should be sure to
use our standard import
/
export and trade sanctions
clauses and engage our International Trade Group
when you need assistance.
Pop the
Question
Q
I am part of the sourcing team at one of the Company’s non-U.S. based concentrate
supply facilities and have been asked to purchase sour cherries from a supplier in Iran.
The supplier is designated as a “Blocked Person” and appears on the U.S. government
Specially Designated Nationals list. Since the facility where I work is outside the U.S.
and I am not a U.S. national, is it ok for me to purchase this product from the supplier?
If not, can I have an independent third party source this item on the Company’s behalf?
A
No. Our Trade Sanctions Policy and the law make clear that all “U.S. Persons” must
comply with applicable trade sanctions laws and regulations. The definition of a U.S.
Person generally includes our Company and its employees, regardless of where they
are located. Additionally, it would be a violation of our Policy and the law to authorize
a third party to make this purchase on our behalf.
Q
To avoid paying customs duties in its country, an international customer has asked
that I sign an origin declaration or certificate of origin identifying that the Company’s
products originate in Mexico. I know the product was bottled in Mexico, but am not
aware of the manufacturing process. Can I sign the declaration
/
certificate of origin?
A
Only with prior approval from the Corporate International Trade Group. Origin
declarations and certificates of origin are governed by local and international laws,
and require a detailed analysis of the manufacturing process under an established
set of rules. An incorrect statement may result in false declarations to the customs
authorities and subject the Company to significant fines and penalties, even when
we are not the importer or exporter.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
DEAL FAIRLY WITH OTHERS
Question or Concern? Log on to EthicsLine @
www.KOethics.com
28
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
We Do Not Tolerate Bribery
Do not make facilitation payments.
A
facilitation (or “grease”) payment
is a small payment made to a
government official to speed up
routine government actions like
processing paperwork, delivering
mail, installing phones or turning the
power on. Regardless of amount,
regardless of custom in that country,
we do not pay them.
What about people who do
business on the Company’s behalf?
As a company, we are not only
responsible for the actions of our
employees, but also for the actions
of anyone who represents us. So, if
you are responsible for hiring third
parties, follow our due diligence
procedures. And if you are responsible for managing third parties, monitor their
work, speak up and report to the Ethics & Compliance Office anytime you see or
suspect a bribe.
What We Believe
Our success is based on the quality of our products, never on unethical or illegal
behavior. We do not tolerate acts of bribery or corruption. And we never offer
or accept
anything of value
in order to get business, keep business or gain an
unfair advantage.
How We Live It
In the drive to be successful in our business, there may be instances where you
are asked to give or accept a bribe. Do not do it. The consequences of violating
bribery laws can be severe
–
for you and for our Company. If the only way to make
a sale or maintain customer loyalty is through payment of a
bribe
, walk away
–
business won this way is not business we value or want.
Follow anti-bribery and anti-corruption laws wherever you do business and,
regardless of what local laws may permit, never offer, pay, promise to pay or
accept anything of value either directly or indirectly to improperly influence
the judgment or actions of others.
Laws in some countries make a distinction between bribing a
government
official
and bribing someone who is not a government official. For us, there
is no difference. Payment of a bribe
–
to anyone
–
is prohibited.
What Else Can You Do?
Learn to spot a bribe.
Bribes come in many forms, and they are not always
obvious. A gift, the promise of a job, the offer of a trip, a charitable contribution
–
all could be considered bribes, if offered in exchange for any decision or
favorable treatment.
Ask first and obtain necessary approvals.
Before you offer or accept anything of
value, check our policies, and ask for help if you are not sure of what to do. Giving
anything of value to a government official requires following the appropriate
approval procedures. If an offer is permitted by our policies, be accurate and
complete in recording payments or expenses.
CONSIDER THIS
“Do not worry, that is just the way
we do business in this country.”
“This payment does not
require approval.”
“A political contribution might
help speed things along.”
Hearing comments like these? Stop
and seek help. If it sounds illegal or
unethical, it probably is.
ONE MORE SIP
Anti-Bribery Policy
Supplier Code of
Business Conduct
PROCESS POINT
Anything of value given to a government
official requires prior, written approval
from Company legal counsel and must be
recorded properly in our books
and records.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
DEAL FAIRLY WITH OTHERS
Question or Concern? Log on to EthicsLine @
www.KOethics.com
29
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
We Do Not Trade on Inside Information
What Else Can You Do?
Know what kind of information is inside information. Examples include
material, non-public information about:
»
»
A significant merger or acquisition
»
»
Positive or negative earnings’ information or volume results
»
»
The gain or loss of a significant
customer or supplier
»
»
Pending regulatory action
»
»
A change in control or in senior management
»
»
Significant litigation
»
»
New products, etc.
Play it safe.
If you are not sure if information
is material and whether it is non-public inside
information, treat it as though it is, and ask
Company legal counsel or the
Office of the
Secretary
about it before proceeding.
What We Believe
It is not fair
–
in fact, it is illegal
–
to buy or sell securities based on
material,
non-public (“inside”) information
we may know about because of our jobs
with the Company. We comply with the law and believe everyone should make
investment decisions based on the same set of rules, so we do not trade on
inside information or tip off others so that they may trade. Insider trading is
unfair because it puts the interest of the insider above those to whom he owes
a fiduciary duty.
How We Live It
We are exposed to information about our Company, or other organizations with
which we conduct business, that is not known by the public but, if it was, might
influence a reasonable investor to make a decision to buy or sell Company stock
or other securities. That knowledge makes us “insiders,” and trading on inside
information is against the law.
ONE MORE SIP
Insider Trading Policy
Pop the
Question
Q
I have learned that the Company is considering the acquisition of a small, publicly-
traded beverage company. My brother just lost his job and really needs the money to
support his family. Since it will not benefit me personally, can I tell him about this so he
can acquire the stock of this company in anticipation of the acquisition?
A
No. Trading on material non-public information is illegal and a violation of the Code,
whether trading in the stock of the Company or the stock of another company. And
the rules do not just prohibit you from buying or selling stock, but also from tipping
others to do so. Do not share the information with your brother or anyone else. If you
have additional questions, you should contact your
Local Ethics Officer
,
Ethics &
Compliance Office
,
EthicsLine
or the
Office of the Secretary
.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
DEAL FAIRLY WITH OTHERS
Question or Concern? Log on to EthicsLine @
www.KOethics.com
30
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
We Follow Privacy Laws
What We Believe
The basis of any good relationship is trust. When our
customers
and consumers
do business with us, they entrust us with their personal information or third
parties’ personal information. Our employees do the same when they join
the Company. We take our responsibility and obligations to our customers,
consumers and employees seriously to collect, use and process any personal
information only for legitimate business purposes and protect it from possible
loss, misuse or disclosure.
How We Live It
Keeping personal information secure is critical to our people, our business and
our reputation. We recognize this responsibility and follow the laws requiring us
to protect personal information that can identify an individual or which relates to
an identifiable individual, also known as personal information (PI). Please know
that certain PI can be sensitive and require an extra level of protection and a
higher duty of care based on applicable law.
Many Company employees work with PI (including sensitive personal information)
as a part of their jobs. If you are one of them, guard this information well by following
the Company’s policies regarding the access, transfer and use of this information.
PI includes information about anyone such as:
»
»
Email addresses
(including business email addresses)
»
»
Telephone numbers
»
»
Employee ID number
»
»
IP-addresses
»
»
Credit card information
»
»
Financial information
If you are not sure whether you are handling any PI or whether your use is in
accordance with Company policies and procedures, ask your manager or
contact the Privacy office.
What Else Can You Do?
If you have to use it, use it with care.
Only collect PI for legitimate business
reasons, and only use it for the purposes of its collection. Access only the
limited amount of PI that you need to do your job, and only share it on a need-
to-know basis with authorized people who also need the information for
completing their work. Never share it with any unauthorized person outside
of our Company or anyone in the Company who does not require use of such
information to complete their job.
Protect your co-workers.
You would never want your PI to be disclosed.
The same goes for your co-workers. Secure their PI as you would your own,
protecting it from deliberate or accidental exposure. Whether you work with
this information or come across it inadvertently, do all you can to handle it
properly and uphold data privacy and protection laws wherever we work.
Protect our customers and consumers.
We are committed to protecting the
PI of our customers, consumers and other third parties. We have a Privacy
Policy to govern our Company-wide use of PI. Additionally, we comply with
our legal obligations to protect PI from unauthorized disclosure and ensure
the integrity and availability of PI.
ONE MORE SIP
Privacy Policy
»
»
Medical information
»
»
Names of family members
»
»
Name and government
identification number
»
»
A combination of certain
information such as
consumer habits
and demographics
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
DEAL FAIRLY WITH OTHERS
Question or Concern? Log on to EthicsLine @
www.KOethics.com
31
Deal Fairly
with Others
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
A Fountain
of Information
CARE
FOR OUR
COMMUNITIE
S
WE WORK AS A TEAM
–
SUPPORTING
OTHERS AND LEAVING A POSITIVE
FOOTPRINT ON OUR WORLD.
We Respect Human Rights
We Show That We Care
A Fountain
of Information
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
CARE FOR OUR COMMUNITIES
Question or Concern? Log on to EthicsLine @
www.KOethics.com
32
Deal Fairly
with Others
A Fountain
of Information
Demonstrate
Accountability
Care for
Our Communities
Table of
Contents
Be
Aware
Protect What
Is Ours
We Respect Human Rights
What We Believe
Respect for human rights is one of the Company’s fundamental values.
Through our actions and policies, we strive to respect and promote human
rights by upholding the UN Guiding Principles on Business and Human
Rights in our relationships with our employees,
suppliers
and independent
bottlers. Our aim is to help increase the enjoyment of human rights within
the communities where we operate. We expect all employees, bottling
partners and suppliers to avoid causing or contributing to human rights
infringements through their business actions.
The framework for our engagement on human rights is The Coca-Cola
Company’s Human Rights Policy, which covers the following topics:
»
»
Respect for Human Rights
»
»
Community and Stakeholder Engagement
»
»
Diversity and Inclusion
»
»
Freedom of Association & Collective Bargaining
»
»
Safe and Healthy Workplace
»
»
Workplace Security
»
»
Forced Labor and Human Trafficking
»
»
Child Labor
»
»
Work Hours, Wages and Benefits
»
»
Land Rights and Water Resources
»
»
Healthy Lifestyles
»
»
Guidance and Reporting for Employees
How We Live It
»
»
Make respect for Human Rights, aligned with our Human Rights Policy,
part of the way you work. Keep Human Rights at the core of your own
behavior and display what “respect” looks like.
»
»
Apply the same Human Rights standards that you would apply to your
co-workers when engaging with suppliers, customers, communities and
any other group that might be affected by our actions and choices.
»
»
Apply a Human Rights lens to your work activities and decision-making,
especially when considering new business processes, acquisitions
or partnerships.
»
»
Ensure that the vendors we engage comply with the Company’s
Supplier Guiding Principles.
»
»
Be proactive. Human Rights risks can appear in any country and in any
context, so remain attuned to new or emerging risks. If you become
aware of a possible human rights infringement, report it immediately.
You may report directly through higher levels of management,
Human Resources
,
Company legal counsel
or
EthicsLine
.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
CARE FOR OUR COMMUNITIES
Question or Concern? Log on to EthicsLine @
www.KOethics.com
33
Deal Fairly
with Others
Demonstrate
Accountability
Care for
Our Communities
Table of
Contents
Be
Aware
Protect What
Is Ours
A Fountain
of Information
We Respect Human Rights
continued
ONE MORE SIP
Human Rights Policy
Supplier Guiding Principles
Human Rights Due
Diligence Checklists
Implementation Guides
Other Resources on Journey
Pop the
Question
Q
How do I apply human rights in my
daily work?
A
As you go about your day, think about
the impact that your work has on
people, including your actions as well
as your plans. If you think there may
be any negative impacts to anyone
inside or outside of the Company, you
may be putting the Company at risk
of violating the Human Rights Policy.
Seek guidance as outlined above and
in the full Human Rights Policy.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
CARE FOR OUR COMMUNITIES
Question or Concern? Log on to EthicsLine @
www.KOethics.com
34
Deal Fairly
with Others
Demonstrate
Accountability
Care for
Our Communities
Table of
Contents
Be
Aware
Protect What
Is Ours
A Fountain
of Information
We Show That We Care
What We Believe
What makes our Company special? It is about more than what we create
–
it
is about the people who create it and the consumers who enjoy what we
create. Our products are made for people everywhere by people who care
about delivering their very best. While our Code cannot encompass all of our
important Company policies, there are some standards that sit at the core of
who we are as an organization even if they are administered by other parts
of the organization, such as our Human Rights Policy and Supplier Guiding
Principles which establish a foundation for respecting people and
environments across the world.
How We Live It
We look beyond ourselves and our needs, setting our sights on building a
better world. To be good neighbors, we expect the best from ourselves,
making sure our business decisions always have a positive impact on
communities, the environment and people everywhere.
Remember that as an employee, you represent the Company to the world.
You can help demonstrate our good citizenship by upholding our high
standards and being aware of your own actions and how they might
affect others.
What Else Can You Do?
Respect Each Other
Promote fairness, diversity and inclusion.
Each person is a key player on
our team, deserving of respect. Show that you appreciate others’ varied
backgrounds, skills and cultures. Never single anyone out for negative
treatment, and be fair in all employment decisions. Base your decisions only on
factors like skills, qualifications, performance and business needs
–
never on
personal characteristics.
Watch for harassment.
It takes many forms and can be verbal, physical, visual
or sexual in nature. It might look like intimidation, bullying, racial slurs, sharing
offensive material or making offensive or sexual jokes, comments or requests.
It happened
–
now what do I do?
If you see, experience or suspect harassment
or discrimination, speak up about it
–
either directly to the person or through
your manager,
Human Resources
,
Employee Relations
,
Company legal
counsel
or
EthicsLine
(in accordance with local regulations for EthicsLine
reporting). We take this behavior seriously and do not tolerate retaliation
against anyone who reports in good faith.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
CARE FOR OUR COMMUNITIES
Question or Concern? Log on to EthicsLine @
www.KOethics.com
35
Deal Fairly
with Others
Demonstrate
Accountability
Care for
Our Communities
Table of
Contents
Be
Aware
Protect What
Is Ours
A Fountain
of Information
We Show That We Care
continued
Be a Good Neighbor
Care for people.
Protect the safety of your co-workers, suppliers and the public,
and follow laws regarding working conditions. Ensure that our suppliers and
other business partners do the same.
Help us preserve the environment.
Do your part by using resources responsibly,
helping to curb emissions, following environmental laws and regulations and
participating in our sustainability, recycling and replenishment efforts.
Support communities.
Respect, learn from and support the communities and
cultures with which we work. Understand the impact our business may have on
communities, including with regards to land rights. Take advantage of the many
community outreach opportunities that the Company is involved in to make a
personal impact.
What about my personal political activities?
The Company encourages
personal participation in the political process so long as it is consistent with
applicable law; however, we will not reimburse you for personal political activity
and you should not use the Company’s reputation or assets (including your time
at work) to further your own political activities and interests. Your job will not be
affected by your personal political views or your choice in political contributions.
If you plan to seek or accept a public office, you must obtain prior approval from
Company legal counsel
.
Will you support my charitable activities?
The Company is known for its
charitable activities and we have identified charitable organizations and
activities that we support as an organization. We encourage you to get involved
in these or other organizations that are important to you; however, your personal
charitable endeavors should be undertaken without pressuring or requesting
others within the Company or with whom we do business to support it, by
using your own funds, your own time and without the use of Company assets.
Requests for formal Company support should follow the appropriate processes.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
CARE FOR OUR COMMUNITIES
Question or Concern? Log on to EthicsLine @
www.KOethics.com
36
Deal Fairly
with Others
Demonstrate
Accountability
Care for
Our Communities
Table of
Contents
Be
Aware
Protect What
Is Ours
A Fountain
of Information
We Show That We Care
continued
Communicate Responsibly
Use social media wisely.
If the subject of our Company comes up while you
are on social media, make it clear in your postings that you are a Company
employee, and your views are your own
–
you are not speaking for the
Company. Never disclose confidential information about the Company, our
customers
,
suppliers
,
competitors
or
other business partners
, and never
post anything that might constitute a threat, intimidation, harassment
or bullying.
What if I already spoke on the Company’s behalf?
If you realize later that
you may have sounded as though you were speaking for the Company in a
post, contact your manager or EthicsLine so the Company can respond and
minimize any harm that may have been done.
ONE MORE SIP
Equal Opportunity
Equal Opportunity and Affirmative
Action Policy Statement
Supplier Code of Business Conduct
Non-Solicitation Policy
Political Contributions Policy
Social Media Principles
(located on Journey)
Supplier Guiding Principles
Human Rights Policy
PROCESS POINT
If you are contacted by the media or
anyone else outside of the Company,
refer the request to those authorized
to respond on behalf of the Company.
For example, media requests should
go to Media Relations. Financial and
investor requests should go to Share
Owner Services.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
CARE FOR OUR COMMUNITIES
Question or Concern? Log on to EthicsLine @
www.KOethics.com
37
Deal Fairly
with Others
Demonstrate
Accountability
Care for
Our Communities
Table of
Contents
Be
Aware
Protect What
Is Ours
A Fountain
of Information
The Last Drop
Thank you for your commitment to The Coca-Cola
Company and our Code of Business Conduct.
Coca-Cola’s reputation as
The Real Thing
was built by generations of dedicated,
hardworking employees like you who do the right thing every day, in every act
and every transaction.
Be inspired and work each day in a way that
inspires others.
Follow not only our Code, our policies and the laws and regulations that apply
to your work, but also your conscience. When something does not feel right or
puts our Company, our people or those we serve at risk, report your concerns.
When you do, you preserve our good name and reputation and help us to better
navigate the Coca-Cola journey for generations to come.
Deal Fairly
with Others
A Fountain
of Information
Demonstrate
Accountability
Care for
Our Communities
Table of
Contents
Be
Aware
Protect What
Is Ours
Question or Concern? Log on to EthicsLine @
www.KOethics.com
38
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
THE LAST DROP
A FOUNTAIN
OF INFORMATION
CHECK HERE FOR DEFINITIONS OF
KEY TERMS AND FOR INFORMATION
ABOUT PEOPLE AND RESOURCES
AVAILABLE TO HELP YOU LIVE OUR CODE.
Glossary
Resources
Care for
Our Communities
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
A FOUNTAIN OF INFORMATION
Question or Concern? Log on to EthicsLine @
www.KOethics.com
39
Deal Fairly
with Others
A Fountain
of Information
Demonstrate
Accountability
Care for
Our Communities
Table of
Contents
Be
Aware
Protect What
Is Ours
Glossary
Anything of value
A term that can refer to cash, gifts, meals, entertainment,
business opportunities, Company product, offers
of employment and more
–
there is no minimum or
maximum amount associated with this term.
Bribe
Giving or receiving anything of value in exchange for an
improper decision or action.
Company asset
A term that refers to everything belonging to the
Company, including its money or product, employees’
time at work and work product, computer systems
and software, electronic and communication devices,
photocopiers, tickets to concerts and sporting events,
Company vehicles, proprietary information and
Company trademarks.
Competitive intelligence
Information about our competitors.
Competitor
For the purposes of the Conflicts of Interest and
Competitive Intelligence provisions only, any business
entity other than our Company, our subsidiaries
or bottlers that manufactures or sells wholesale any
non-alcoholic beverages or beverage concentrate or is
actively considering doing so.
Customer
Any business or entity to which our Company
–
or one
of our subsidiaries or bottlers
–
sells concentrate or a
finished product bearing a trademark owned or licensed
by the Company. Franchise bottlers of Company-
trademarked products are considered customers.
Discretionary authority
In dealing with a company, it is the authority to influence
our Company’s selection of a supplier or our relationship
with an existing customer or supplier.
EthicsLine
Our reporting service, administered by a third party,
through which employees and others can ask questions
or raise concerns about the Code of Business Conduct
or other ethics and compliance matters. EthicsLine also
accepts calls regarding the Human Rights Policy and
involving employee relations in countries where such
reports are allowed. While all concerns are received
using the same contact information, human rights, labor
and employee relations matters are handled outside of
the Code process.
Ethics & Compliance Committee
A committee comprised of senior leaders representing
corporate governance functions and operations,
responsible for administration of our Code of
Business Conduct.
Facilitation payments
Small payments made to government officials to expedite
or facilitate non-discretionary actions or services, such as
obtaining an ordinary license or phone service.
Government officials
Employees of any government anywhere in the world, even
low-ranking employees or employees of government-
controlled entities. The term also includes political
parties and party officials, candidates for political office,
employees of public international organizations, such as
the United Nations, and government employees who may
be acting in a commercial capacity, such as professors,
doctors at public hospitals and military personnel.
Local Ethics Officer (LEO)
An employee at the Group, Business Unit or appropriate
Bottling Investments level, recommended by business
leaders and appointed by the Ethics & Compliance
Committee, empowered to provide written approvals for
actions under the Code in the areas of Conflicts of Interest
and Company Assets. A list of Local Ethics Officers can be
found on the Ethics & Compliance intranet site.
Material non-public information
Non-public information that would be reasonably likely to
affect an investor’s decision to buy or sell the securities
of a company. Trading in such information provides an
unfair advantage by allowing the insider to profit based
on information not known to the public.
Non-public information
Any information that our Company has not disclosed
or made generally available to the public and which it
considers to be confidential.
Other business partners
Any other business partners who are not customers
or suppliers as defined and which may include trade
associations, talent and sponsorship partners.
Relative
A term that includes a spouse, parent, sibling,
grandparent, child, grandchild, in-law or same or
opposite sex domestic partner, as well as any other
family member who lives with you or who is otherwise
financially dependent on you or on whom you are
financially dependent.
Supplier
Any vendor of products or services to the Company,
including consultants, contractors and agents. The term
also refers to any supplier that our Company is actively
considering using, even if no business ultimately is awarded.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
A FOUNTAIN OF INFORMATION
Question or Concern? Log on to EthicsLine @
www.KOethics.com
40
Deal Fairly
with Others
A Fountain
of Information
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities
Resources
If you need advice or wish to raise a concern, start with your manager
–
he or she is in
the best position to understand and take appropriate action. If you feel uncomfortable
speaking with your manager, you may contact any of the following resources:
FOR
RESOURCE
CONTACT INFORMATION
Reporting Code of Business
Conduct concerns
Legal questions
Written approvals and guidance on
ethics and compliance issues
Questions about our Code of
Business Conduct
Possible criminal matters
Accounting and finance policy
and procedure questions
HR-related policy and
procedure questions
Inquiries regarding
insider trading
Human Rights
Policy questions
EthicsLine, your Manager, your Local Ethics Officer,
or the Ethics & Compliance Office
Company legal counsel
Your Local Ethics Officer (LEO)
The Ethics & Compliance Office,
or your Local Ethics Officer (LEO)
Strategic Security
Senior Finance Personnel
Human Resources or Employee
Relations Representatives
Office of the Secretary
Global Workplace Rights team
Contact your local finance support.
THE COCA-COLA COMPANY
•
INTEGRITY - THE ESSENTIAL INGREDIENT
•
A FOUNTAIN OF INFORMATION
Question or Concern? Log on to EthicsLine @
www.KOethics.com
41
Deal Fairly
with Others
A Fountain
of Information
Demonstrate
Accountability
Table of
Contents
Be
Aware
Protect What
Is Ours
Care for
Our Communities