CCEP´s Anti – Corruption Policy

CCEP´s Anti – Corruption Policy

  1. Purpose 

    This Anti-Corruption Policy (the „Policy“) outlines acceptable and non-acceptable behaviours to ensure compliance with the highest ethical standards in business and prevent any improper payments, gifts or inducements of any kind to and received from any person, including officials in the private or public sector, customers and suppliers. 

  2. Definitions 

    The following terms have the following meaning in this Policy

    Bribe: A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

    Corruption: The misuse of a public office or power for private gain or the misuse of private power in relation to business outside the realm of government.

    Facilitation payments: Small sums paid to government officials to facilitate or expedite routing. Non-discretionary government actions are considered facilitation payment.

    Kickbacks: The return of a sum paid or due as a reward for awarding of furthering business. 

  3. What does „Anti-Corruption“ mean

     Corruption can take place in many types of activities. It usually is designed to obtain financial benefits or other personal gain. For example, bribes are intended to influence behaviour. They could be in the form of money, a privilege, an object of value, an advantage, or merely a promise to influence a person in an official or public capacity. Usually, two people are involved end both will benefit. Examples of a Bribe include:

    • Offer or receipt of cash in the form of a kickback, loan, fee or reward;
    • Giving of aid, donations or voting designed to exert improper influence. 
  1. Areas of concern

    The areas of business where corruption, including bribery, can most often occur include:

    1. Gifts, entertainment and hospitality 

      Gifts, entertainment and hospitality are acceptable if they are reasonable, proportionate and made in good faith and in compliance with our Company Policies.

      Examples of gifts, entertainment and hospitality include the receipt or offer of gifts, meals or tokens of appreciation and gratitude, invitations to events, functions, or other social gatherings, in connection with matters related to our business. Such activities are acceptable provided they fall within reasonable bounds of value and occurrence. 

      How do you know if an offered gift, entertainment or hospitality by CCEP or to CCEP is acceptable? First, take a step back and ask yourself the following: 

      • What is the intent – is it to build a relationship or is it something else?
      • How would it look if these details were on the front of a newspaper?
      • What if the situation were reversed – would there be a double standard?

        If you find it difficult to provide a comfortable answer to one of the above questions, ask your Manager.

        What to do when you doubt if you can accept? If you are unsure if you should accept something of value; ask your Manager. If your Manager is participating, seek a higher-level Manager advice.

        As a general rule, CCEP employees and business partners should not provide gifts or hospitality to, or receive them from, a government or other public official (or their close families and business associates). You may give a modest gift to these parties when appropriate and allowed by local law provided you discussed it with and received written approval in advance from your Manager.

    2. Facilitation Payments 

      Facilitation payments are not allowed. If you are unsure whether certain payments represent facilitation payments, please contact your Manager.

    3. Procurement Process 

      You must follow CCEP processes and adhere to the system of internal controls around supplier selection. Supplier selection should never be based on receipt of a gift, hospitality or payment. When supplier selection is a formal, structured invitation for the supply of products or services (often called a ‘tender’), it is most important we maintain documentation supporting our internal controls. In the public sector, such a tender process may be required and determined in detail by law to ensure that such competition for the use of public money is open, fair and free from corruption. 

      A tender process includes an invitation for other parties to make a proposal, on the understanding that any competition for the relevant contract must be conducted in response to the tender, no parties having the unfair advantage of separate, prior, closed-door negotiations for the contract where a bidding process is open to all qualified bidders and where the sealed bids are in the open for scrutiny and are chosen on the basis of price and quality. 

    4. Political, Community and Charitable Contributions 

      You are not allowed to make political contributions from Company funds without authorization.  Political contributions, as permitted by law, must be approved in advance by the Managing Director.  

      Contributions made by CCEP to community projects or charities need to be made in good faith and in compliance with this Anti-Corruption Policy and all relevant CCEP’s Policies and procedures.  

  2. Books, Records and Internal Control Requirements

    Expenses must never be hidden or purposefully misclassified. Many serious global bribery and corruption scenarios are found to involve inaccurate record-keeping. It is important to ensure to maintain accurate books, records and financial reporting.

    All business areas must maintain an effective system of internal control and monitoring of our transactions. Certain monitoring controls are identified in our policies, specifically regarding approval of travel and entertainment expenses. It is each employee´s responsibility to be knowledgeable of control procedures and ensure compliance. 

  3. Responsibility

    CCEP takes corruption and bribery very seriously. Any violation of this policy will be regarded as a serious matter by the Company and is likely to result in disciplinary action, including termination, consistent with local law.

    Bribery can be a criminal offense. Each employee can be held accountable whether he/she pays a bribe him-/herself or whether he/she authorizes, assists, or conspires with someone else to commit bribery. 

  4. How to Raise a Concern

If an employee wants to ask a question about the requirements in this policy or is concerned that an anti-corruption violation is occurring or has occurred, report it immediately to one of the following:

  • Your manager; or
  • A higher level manager; or
  • E-mail at: