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SCCE ECEI 2014
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2014 European Compliance & Ethics Institute – London
Dominic Hall and Maaike BurgerEthics and Compliance Coca-Cola Enterprises20 May 2014
A Strong Partnership
MarketplaceExecution
Communityand Customer
Brand Marketing
Customer Focus
Customer Focus
Long-TermSustainableProfitableGrowth
Production/Distribution
Marketplace Execution
Community and Customer Brand
Marketing
Franchise Leadership
Brand Development/Innovation
Brand Marketing
Consumer Focus
Consumer Focus
SCCE ECEI 2014
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We build successful brands
Great Britain
France
Norway
Sweden
Belgium
Netherlands
$8.2 billion revenue
90+ years in Europe
40+ brands
12,000+ employees
17 manufacturing facilities
170 million consumers
CCE Overview
SCCE ECEI 2014
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Legislation
Cultural sensitivity
Communication
Implementing a successful European Hotline
Legislation
Meeting both Sarbanes‐Oxley requirements and European Data Privacy legislation
Varying European data protection legislation
SOX vs. European legislation ‐ tips
SCCE ECEI 2014
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Meeting both SOX and European legislation
SOX requirements
European Data Protection restrictions
CCE’s hotline scope
Potential hotline scope
European data protection legislation
For illustrative purposes only
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SOX vs. European legislation ‐ tips
Encourage “Confidential” reporting
Transfers of Data Outside of the EEA
Retention of Data
Communicate with employees
Authorization Procedures
Updated guidance from CNIL
Amended authorised whistleblower scheme nowincludes:
Financial, accounting, banking and anti‐briberymatters
Anti‐competitive practices Harassment and discrimination at the workplace Issues relating to safety, health and hygiene at the
workplace Environmental protection
SCCE ECEI 2014
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Communication ‐ what’s in it for me ?
To improve your working life
To help your team
To help the company
Why should I speak up?
Why should I encourage my
team to speak up?
Code of Business Conduct & Policies
Direct / local manager
Senior Manager
HR, Legal
E&C
The RIGHT call process
SCCE ECEI 2014
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Practical tips
*Source: “Inside the Mind of a Whistleblower,” National Business Ethics Survey, May 31, 2012
Hotline should be the last resort
Take all reports seriously*
Collaborate
“What’s in it for me?”
External provider
Highly Confidential – Not for Distribution
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Ethics and Compliance FrameworkFramework driven by: Federal Sentencing Guidelines, FCPA, UK Bribery Act
Key Elements
Legal
Human Resources
Risk, Control and Compliance
Security
Public Affairs and Communication
Enterprise Risk Management
Internal Audit
CO
MM
UN
ICA
TIO
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Doing things the Way – Our Guiding Principles
1. Working with each other2. Promoting health and safety in
the workplace3. Preventing substance abuse4. Working with customers and
suppliers
5. Interacting with competitors6. Avoiding conflicts of interest7. Protecting company assets8. Maintaining accurate records
9. Complying with anti-corruption laws10.Avoiding insider dealing11.Upholding our environmental
commitments12.Engaging in government and
political activities
CollaborationGovernance
Top Level Commitment
Strategy
Mission / Vision
Organization
Laws and Regulations
Standards and Procedures
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