SUSTAINABILITY REPORT 2018

RISK MANAGEMENT AND ETHICS

Ethics

*** You can check the table by scrolling to the right

Priority Areas 2018 Goals Performance in 2018 Status 2019 Goals
Business Ethics To continue to give our training on Code of Ethics and anti-bribery policy to all management teams and all newcomers in all CCI countries. Training has been given to all newcomers as part of the orientation program. Ongoing
  • To continue to give our training on Code of Ethics and anti-bribery policy to all employees in all CCI countries and to use other communication channels like digital boards, internal social media platform to raise awareness.
  • To co-operate with EBRD to run an ethics and compliance training program which will be initiated in CCI's distributors with the aim of reducing the third-party risks.
To continue to review and update Code of Ethics and anti-bribery policy in line with TCCC practices. It will be completed in 2019.
  • To continue to review and update Code of Ethics and anti-bribery policy in line with TCCC practices.
  • To prepare policies about third-party relationships, gift and entertainment, conflict of interest.

Integrity and honesty are fundamental virtues for CCI. It is our whole-hearted obligation to protect our most valuable asset; the Coca-Cola brand and Coca-Cola İçecek.

The CCI Code of Ethics guides our employees to live by our values and “do the right thing”. The scope applies to all CCI operating geographies. Our CCI Code of Ethics and Code of Ethics Handbook are publicly available for everyone on CCI corporate website >

CCI’s Corporate Governance Committee ensures full implementation and enforcement of the Code of Ethics. Implementation of the Code is under the responsibility of the CCI Ethics and Compliance Officer and the Local Ethics and Compliance Officers. CCI Ethics and Compliance Committee, consists of the CFO, the Human Resources Director, the General Counsel, the Corporate Affairs Director and the Chief Audit Executive.

The Corporate Governance Committee also developed necessary mechanisms for stakeholders to report any illegal or unethical practice within the company to the Corporate Governance Committee or the Audit Committee.

There are several channels available for our employees to express their concerns on ethical issues. They can direct their concerns to their managers or Local Ethics and Compliance Officers, or use the CCI Ethics Service, which is run by a completely independent third party that is available 24/7 to all employees. There are translators providing translation services online in Arabic, English, Georgian, Russian and Turkish.

CCI Ethics Service communication channels are

  1. E-mail: employee’s name and e-mail address are kept confidential
  2. CCI Ethics and Compliance websites www.ccietikhat.com (in Turkish) and www.cciethicsline.com (in English, Russian and Arabic): employees can login to the page anonymously and enter their message.
  3. A dedicated phone number.

CCI Ethics and Compliance Officer keep records of all incidents across CCI and monitors the review processes and ensures they are completed. CCI Internal Audit Department handles investigations concerning Code of Ethics violations and the CCI Ethics and Compliance Committee makes decisions based on the findings of the investigations. Certain categories of decision-making authority may be delegated to Local Ethics and Compliance Committees in accordance with the Guidelines for Handling Code of Ethics Matters.

We impose disciplinary measures that fit the nature and circumstances of each Code violation. Letters of reprimand are issued for less significant, first-time offenses. Violations of a more serious nature may result in suspension without pay, loss of progress payments and bonuses or termination of employment.

All newly recruited employees must sign an acknowledgement form confirming that they have read the Code of Ethics and agree to abide by its provisions. All employees are required to periodically make this acknowledgement. The Code of Ethics Handbook and Guidelines for Handling Code of Ethics Matters are shared with our employees. Representatives and consultants assigned by CCI and third parties doing work on behalf of CCI may also obtain a copy of the Code and learn therein about their obligations. Since 2013, our employees are trained on the revised Code of Ethics, the Code of Ethics Handbook and procedural provisions. In addition, digital in-office screens and internal social media are used in order to increase awareness and to refresh the information about ethics rules. This year for the first time with the participation of all countries, CCI celebrated Global Ethics Day.

In this scope, 624 human-hours of training and approximately 50 informative posts were provided for the countries in the reporting period.