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Code of Business Conduct - Coke

May 31, 2018

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    THE COCA-COLA COMPANY

    The Code of Business Conduct

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    WHAT is THE

    CODE OF BUSINESS CONDUCT?

    The Code is designed to give you a broad andclear understanding of the conduct expected ofall our employees.

    The Code focuses on key integrity issues.

    The Code cannot address every circumstanceand isnt meant to; it isnt a catalogue ofworkplace rules.

    The Company has policies in such areas as faircompetition, securities trading, workplaceconduct and environmental protection.

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    OVERVIEWEXERCISING COMMON SENSE

    Never engage in behavior that harms thereputation of the Company. If you wouldntwant to tell your parents or your children

    about your action or wouldnt want to readabout it in a newspaper dont do it. Some situations may seem ambiguous.

    Exercise caution when you hear yourself orsomeone else say, Everybody does it or No

    one will ever know. The most important message is this: When you

    are uncertain about any situation, ask forguidance.

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    YOUR RESPONSIBILITIESASKING FOR GUIDANCE

    If you want to ask a question about, or report violations of, the

    Code of Business Conduct or any other ethics or compliance issue,

    you have several resources.

    Contact EthicsLineby phone or through a secured Internet site 24

    hours a day, seven days a week. You can report anonymously if youwish. If calling from outside the United States and Canada, use the

    international access codes found on the EthicsLine website.

    866-790-5579 www.KOethics.com

    You also can seek guidance from, or report violations to, your

    management, or responsible employees in Finance, Legal, Strategic

    Security or the Ethics & Compliance Office.

    In all cases, employees will not be subject to retaliation or other adverse

    consequence for reporting any potential Code violation or othercompliance issue.

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    SUBJECT MATTERS UNDER

    the CODE

    Conflicts of Interest

    Financial Records

    Use of Company Assets Working with Customers and Suppliers

    Working with Governments

    Protecting Information

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    CONFLICTS ofINTEREST

    Avoid situations where your personal interestsconflict, or appear to conflict, with those of theCompany.

    You may own up to 1% of the stock in a competitor,customer or supplier without seeking prior approvalfrom your Principal Manager so long as the stock is ina public company and you do not have discretionaryauthority in dealing with that company.

    If you have a financial interest in a transactionbetween the Company and a third party, that interestmust be approved by your Principal Manager prior tothe transaction.

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    PRINCIPAL MANAGER

    Who is my Principal Manager?

    Your Principal Manager is your Division

    President, Group President, Corporatefunction head, or the General Manager of your

    operating unit.

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    CONFLICTS ofINTEREST

    If the spouse of an employee works as a consultant tothe Company, is this a violation of the Code?

    Maybe. If you have a financial interest in a transaction

    between the Company and a third party even anindirect interest through, for example, a familymember that interest generally must be approved byyour Principal Manager prior to the transaction.

    However, if you only have a financial interest in asupplier or customer because someone in your familyworks there, then you do not need to seek priorapproval unless you deal with the supplier or customeror your family member deals with the company.

    The decision:

    The action:

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    CONFLICTS ofINTEREST

    One of the vendors my department uses is a businessowned by my cousin. Do I need to follow any special

    procedure in making purchases from the vendor?

    Yes. You should advise your manager of therelationship. It is essential that vendors be treatedfairly and honestly, and the mere fact of therelationship may cause other vendors to believe thatyour relative is being treated preferentially. Your

    manager may therefore choose to have another personmanage the purchases, may have another personreview all of the transactions, or may locate anothervendor.

    The decision:

    The action:

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    CONFLICTS ofINTEREST

    Can an employee own stock in a company that is acustomer, supplier or competitor of The Coca-ColaCompany?

    Yes. You may own up to 1% of the stock of acompetitor, customer or supplier without seeking priorapproval from your Principal Manager, as long as thestock is in a public company and you do not havediscretionary authority in dealing with that company.

    If you want to purchase more than 1% of the stock ina customer, competitor or supplier, or the company isnon-public, or you have discretionary authority indealing with the company, then you may purchase thestock only with prior approval of your Principal

    Manager.

    The decision:

    The action:

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    FINANCIAL RECORDS

    Every Company financial recordincluding timesheets, sales records and expense reportsmust beaccurate, timely and in accordance with the law.

    Always record and classify transactions in the properaccounting period and in the appropriate account anddepartment. Delaying or prepaying invoices to meet

    budget goals is a violation of the Code.

    Never falsify any document or distort the true nature

    of any transaction. All reports made to regulatory authorities must be full,

    fair, accurate, timely and understandable.

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    FINANCIAL RECORDS

    An Account Executive asks the bottler in his region tooverstate unit case volume in March of 2002 by25,000 cases and to reverse this overstatement in Aprilso that full year reporting is not affected. Has the

    Code been violated?

    Yes. Intentional misclassification of transactionsbetween accounting periods is a violation of the Code.

    The Account Executive should be disciplined under

    the Code for asking the bottler to misreportinformation relied upon by the Companysmanagement, shareholders and others.

    The decision:

    The action:

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    FINANCIALRECORDS

    You are a Division I/S Manager and have recently

    purchased and received several computer supplies

    during December. The Division Finance Manager has

    requested that you call the suppliers to delay invoicing

    the goods to the following year. What should you do?

    Do not do it, and report both issues to one of the

    Companys ethics resources. Should you fail to report

    the request, you also will be in violation of the Code.

    The decision:

    The action:

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    FINANCIALRECORDS

    Two days before month-end I have sold my sales

    budget. I think I can sell and deliver more cases over

    the next two days and hold the invoices to get a jump

    start on the next month. What should I do?

    Dont even think about it. Holding the invoices for

    product physically delivered would be a violation of

    the Code. All transactions should be recorded in the

    proper period.

    The decision:

    The action:

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    FINANCIAL RECORDS

    I was traveling in another city and was scheduled to

    eat dinner with a customer. At the last minute, the

    customer cancelled. I called a friend from college and

    had dinner with him instead. If I submit the receipt

    for both of our dinners and list the name of the

    customer I was scheduled to meet on my expense

    report, is this a violation of the Code?

    Yes. Intentional misrepresentation of expenses is a

    violation of the Code.

    The decision:

    The action:

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    FINANCIAL RECORDS

    While making a sale, my customer demanded that Ichange: the description of the product/service rendered,

    the price actually paid to a higher value, and

    the location to which the product/service was delivered toanother country.

    He advised me that if I do not make these changes he will notbuy anything more from the Company. What should I do?

    Under no circumstances should you agree to thedemand. Such misrepresentation could be illegal andthe document could be used to carry out an illegalactivity. It also violates the Code as an intentionallymisleading entry. Immediately advise the person towhom you report.

    The decision:

    The action:

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    FINANCIAL RECORDS

    I am a route driver and I saw a colleague stealcash from a customer sale and cover the theft

    by altering the invoice. I do not report the

    matter to

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