Policies

Our attitude to corruption is clear: zero tolerance.

At Coca‑Cola HBC, we pride ourselves on being fair, open and honest. Whether we’re dealing with our suppliers, customers or governments, we follow a strict code of integrity, respect, and transparency.

Inappropriate business activities are by no means anything new, nor are they unique to any one business environment. We at Coca‑Cola HBC recognise the risk of bribes – the request or receipt of anything of value or advantage, whether directly or indirectly, to any person, in order to encourage that person or any other to perform a function or activity improperly.

Our zero tolerance policy on corruption marks our company as a model for ethical behaviour in both business and personal life.

We expect our employees to show complete and absolute respect to these standards. Violations of our anti-bribery policy – regardless of location, role or level of seniority – is dealt with the utmost seriousness and to the full extent of our legal capacity.

Our anti-bribery policy and compliance handbook provides our people with the essential knowledge and tools to detect and prevent bribery and corruption. It also shows them where they can find more information.

Our climate change policy statement is set out below. It is owned and endorsed by the Corporate Social Responsibility Committee of the Board of Directors; responsibility for the successful implementation of this programme belongs with every Coca‑Cola Hellenic employee at each level and function in the organisation.

Coca‑Cola Hellenic strives to limit its impacts on climate change and to carry out all its business activities in a sustainable manner. We believe that industry has a key role to play in finding sustainable solutions to today’s climate challenges.

The direct greenhouse gas emissions from Coca‑Cola Hellenic operations result mostly from the use of energy in bottling plants and fleet. Indirect emissions stem from raw materials (ingredients and packaging) and cold drink equipment.

In accordance with our environmental policy, we will:

• Reduce the energy used in our operations
• Implement alternative or renewable energy technologies such as combined heat and power plants and solar panels, where practical to provide additional sustainable energy for our facilities
• Engage with stakeholders to combat climate change
• Work with suppliers to reduce the carbon embedded in packaging materials, the carbon footprint of our cold drink equipment and ingredient suppliers to minimise their carbon impacts
• Set targets to reduce our supply chain carbon emissions
• Report our greenhouse gas emissions, targets, results and activities openly and in accordance with the Greenhouse Gas Protocol

The purpose of this Policy is to: - encourage the reporting, as required under our Code of Business Conduct, of any suspected fraud or corrupt conduct or any other form of inappropriate behavior including potential violations of our Code of Business Conduct (reportable conduct); - provide guidance on how to raise concerns; - confirm that confidentiality will be maintained and that genuine concerns reported honestly can be raised without fear of reprisals, even if they turn out to be mistaken.

Whistleblowing Policy
 
 
1. Our Commitment
Coca‑Cola HBC AG (with all its subsidiaries, the “Company”) is committed to conducting our business with honesty and integrity. We expect all employees (including temporary and contract employees), officers, as well as consultants and agents acting in the Company’s name to maintain high standards and to uphold the values and behaviors in accordance with our Code of Business Conduct.
 
2. Purpose
 
The purpose of this Policy is to: - encourage the reporting, as required under our Code of Business Conduct, of any suspected fraud or corrupt conduct or any other form of inappropriate behaviour including potential violations of our Code of Business Conduct (reportable conduct); - provide guidance on how to raise concerns; - confirm that confidentiality will be maintained and that genuine concerns reported honestly can be raised without fear of reprisals, even if they turn out to be mistaken.
3. Scope
 
The policy applies to the Company and its subsidiaries and covers all employees (including temporary and contract employees), officers, consultant and agents acting in the Company’s name.
 
4. Definition of Whistleblower
 
A whistleblower is defined as an employee, officer, consultant or agent of the Company who wishes to report conduct they believe is in breach of our Code of Business Conduct, or in breach of any applicable law and who perceives a need to avail themselves of protection against reprisal for having made the report. A whistleblower may or may not elect to remain anonymous, but the Company encourages the whistleblower to report on a named, confidential basis. 
 
5. What to Report
 
Any suspected fraud, corrupt conduct, inappropriate behavior reportable under our Code of Business Conduct or illegal activity involving the Company or its employees in any way should be reported. Anyone reporting a concern has to believe that the information provided is accurate.  Knowingly making a false accusation is itself a violation of the Code of Business Conduct. 
 
6. How to Report Issues 
 
Reports of potential violations of the Code of Business Conduct may be submitted through an independently operated whistleblower line (online at www.coca-colahellenic.ethicspoint.com and/or by telephone). This service is available in all languages of the territories where the Company operates.   Individuals also have the option of reporting concerns directly to their local Code Compliance Officers, General Managers, Function Heads, Country or Regional Legal Directors, the Group Chief Compliance Officer, the Corporate Audit Director, the Group COBC Manager, or the Group General Counsel.  

 
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The Group COBC Manager is responsible for maintaining records of reports of potential violations and the actions taken through the case management system. The Corporate Audit Director is responsible for reporting to the Audit and Risk Committee, on a quarterly basis, the number, nature and status of complaints received.
 
7. Confidentiality
 
The Company will take every reasonable precaution to keep the identity of anyone raising a concern confidential, consistent with conducting a thorough and fair investigation and compliance with applicable law. 
 
8. Procedures for Investigation
 
All reports of potential COBC violations (including those relating to fraud) will be acknowledged no later than 3 business days after receipt.  Complaints will be investigated promptly, impartially and appropriately in line with the Company’s approved investigation guidelines. Determination of findings will be reviewed by the relevant disciplinary committee and appropriate action will be taken as required. 
 
9. Protection
 
The Company is committed to ensuring that an individual is not disadvantaged in any way by validly raising concerns about suspected reportable behaviour. In particular, such a person will not be disadvantaged by dismissal, demotion, loss of benefits, threats, harassment, discrimination or bias. If there are concerns surrounding the safety of the whistleblower, he or she may request a leave of absence or a temporary change of workplace, and such requests will be given appropriate consideration.  A breach of this section by any employee, officer, consultant or contractor, will be considered a breach of the Code of Business Conduct and dealt with as such. If an individual raising a concern feels that reprisals have been taken against them as a result of their action, they can appeal through any one of the officers identified in the appendix.
 
10. Feedback
 
Where appropriate, and the identity of the individual raising a concern is known, he/she will receive feedback on the progress of the investigation. Because the Company strives to maintain confidentiality in all investigations it may not be able to inform the individual raising a concern of the final outcome of an investigation.
 
11. Penalties for Breach of this Policy
 
Where any employee (including any temporary or contract employee), officer, consultant or agent of the Company breaches this policy, this will be considered a breach of the Code of Business Conduct and dealt with accordingly.
 
12. Process Visibility
 
Information about the Company’s procedures for the treatment of whistleblowing complaints are available  on the Company’s Intranet and referenced in the Company’s Code of Business Conduct.
 

 
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APPENDIX
 
The authorized officers at the Group level with whom individuals can disclose their concerns in relation to breaches or concerns in respect of this policy are:
 
• William Douglas (Audit & Risk Committee Chairman)  • Jan Gustavsson (General Counsel) • Spyros Mello (Deputy General Counsel and Chief Compliance Officer)

The Code of Business Conduct is Coca‑Cola HBC’s essential over-arching policy. All our employees are responsible for upholding our commitment to the highest standards of business conduct.

Across the board, Coca‑Cola HBC’s employees are committed to the highest standards of business conduct. Our Code of Business Conduct is the foundation of how we safeguard compliance across our company.

The Code enables managers to promote a culture of ethics, based on compliance and leadership by example. They can respond quickly and clearly to employees’ concerns, drawing on the wealth of experience within the company.

We encourage our employees to speak up and look for guidance where needed, and to make sure that they have all necessary approvals for key decisions. This minimises the risk of deviation from or violation of the guidelines set out in the Code of Business Conduct.

We also lend our voice to matters which affect our communities – standing ready to bring our expertise and leadership to resolving matters across suppliers, customers, consumers and competitors. This uncompromising pledge to integrity is one of the many ways in which we drive perfection.

By communicating our Code of Business Conduct effectively, we guarantee an efficient and equitable workplace and a competent and considerate workforce.

All resources are easily accessible, not only to our team but to anyone who would like to find out how they can become effective stewards of responsible business practice.

To whom does the Code of Business Conduct apply?

The Code of Business Conduct applies to everyone working for the company worldwide, regardless of location, role or level of seniority. This includes all employees, managers, Operating Committee members and company directors.

We also expect temporary and contract employees, consultants, agents and any other third party who acts in our name to follow the principles of the Code. Every subsidiary and joint venture which the company controls must adopt and comply with the Code. Where we participate in but do not control a joint venture relationship, we will encourage our partners to meet the requirements of the Code in both the joint venture and their own operations.

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Coca‑Cola HBC's community contributions policy focuses on key investment areas, supports employee involvement and our overall business strategy, standardises our approach across the Group ad, ultimately, helps inspire a better future through long-term sustainable support for beneficiaries.

Introduction

Coca‑Cola HBC is a leading bottler of the brands of The Coca‑Cola Company in terms of volume, with sales of more than 2 billion unit cases. It has a broad geographic footprint with operations in 28 countries, serving a population of approximately 589 million people. Coca‑Cola HBC offers a diverse range of non-alcoholic ready to drink beverages in the sparkling, juice, water, sport, energy, tea and coffee categories. Coca‑Cola HBC is committed to promoting sustainable development in order to create value for its business and for society. This includes providing products that meet the beverage needs of consumers, fostering an open and inclusive work environment, conducting its business in ways that protect and preserve the environment and contribute to the socio-economic development of the local communities.

Coca‑Cola HBC is ranked beverage industry leader by the Dow Jones Sustainability World and Europe Indices, and is also included in the FTSE4Good Index. In conducting operations across 28 countries, we provide guidance, support and supervision to each operation while placing day-to-day management and operation in the hands of local employees with a deep familiarity of their own country, its business practices and community aspirations.

Aim of the Coca‑Cola HBC corporate contributions policy

• Ensure focus by concentrating the company’s corporate contributions into the three strategic community investment areas: Youth development, Water stewardship & Environment protection, Promoting active and healthy living, along with Emergency relief
• Inspire a better future and quality of life for the beneficiaries of the company’s corporate giving and ensuring long-term, sustainable support for chosen beneficiaries
• Support Coca‑Cola HBC’s overall business strategy
• Define clear governance by establishing a Group-wide policy
• Support employee involvement in both community and charitable contributions projects.
• Standardise the corporate contributions guidelines across the Group to increase scale, simplify and build on synergies

Scope

This policy applies to all Coca‑Cola HBC corporate contributions and charitable donations in all 28 country operations of the Group, and to all of its operating units and legal entities, including the Business Service Organization (BSO), Business Solutions and Systems (BSS) and the Corporate Service Center (CSC).

Our community strategy

We are an active member of the community in each of the 28 countries in which we operate.

We realise that our business depends on the communities where we live and work and can only be as healthy and sustainable as they are.

We aim to operate in a responsible way by engaging with stakeholders and communities for sustainable development. Over the last decade we have integrated corporate responsibility and sustainability into everything we do and being true to our purpose and mission, we continuously invest in our communities, working together on key environmental and social issues.

We support communities in three strategic areas and emergency relief:

Youth development

Unemployment among young people is a significant challenge in many markets; therefore we support enterprise educational programmes and offer internships, as well as empower underprivileged young people by providing skills training and access to funds and networks.

Water stewardship and environmental protection

As part of our water stewardship strategy we partner with international and national governmental and non-governmental organisations to preserve and protect important river basins and watershed areas, such as the Danube, including contributions to preserve wetland habitats and biodiversity. We have water stewardship initiatives in all our countries where this is relevant.

Promoting active lifestyles

As part of our health and nutrition strategy, we support initiatives across our operating region that encourage people to be more active, and have stepped up our efforts to achieve the global objectives of The Coca‑Cola System (The Coca‑Cola System is the term used to describe the business system of The Coca‑Cola Company and its bottling partners worldwide). During 2014, more than 1.6 million people took part in sports and fitness programmes supported by Coca‑Cola HBC.

Emergency relief

Should our communities be affected by unexpected events of disasters of any kind, we consider it our duty to provide support and engage in emergency relief efforts led by the relevant organisations.

To this end, we continue to strengthen our collaboration with the International Federation of Red Cross and Red Crescent Societies and National Red Cross/Red Crescent societies and other NGOs.

These partnerships enable us to respond rapidly to disasters by delivering safe drinking water and other supplies through our logistics and delivery systems.

Definitions

Corporate contributions fall into the following categories:

• Monetary contributions
• In-kind, such as product donations
• Pro bono support, including but not limited to donating professional level of service and management expertise, skills and time to non-profit organisations and employee time spent volunteering during work hours

Coca‑Cola HBC Group and country compliance

Most of Coca‑Cola HBC’s corporate contributions are managed by its country operations.

Coca‑Cola HBC’s aim is to ensure that the company’s contributions are made in accordance with this policy and the Group Community Strategy.

Please see below for further details on Coca‑Cola HBC’s selection and approval processes.

International and local management

Coca‑Cola HBC operates both international and local contributions.

International corporate contributions are managed by Coca‑Cola HBC’s Group Public Affairs and Communications team while local initiatives are the responsibility of the company’s 28 country operations.

Selection criteria and restrictions

All recipients of Coca‑Cola HBC corporate contributions must be registered as non-profit organisations.

The selection process must comply with the terms and objectives of Coca‑Cola HBC’s Corporate Contributions Policy. Given the objectives of this Policy, the recipients will be involved in the company’s four priority areas: Youth Development, Water stewardship & Environmental protection, Promoting Active Healthy Living and Emergency relief.

Coca-Cola HBC does NOT support:

• Individuals
• Religious, political or legislative organisations
• Organisations that do not have a non-discrimination policy (to ensure they do not discriminate based on race, ethnicity, colour, sex, religion, age, national origin, ancestry, citizenship, sexual orientation, gender identity and/or expression, or disability)
• Organisations that are directly involved in gambling, recreational or illegal drugs, tobacco and armaments (with the exception of those charities and organisations specifically dedicated to tackling addiction or drug abuse)
• Professional local sports or athletic teams
• Travel or organised field trips
• Monuments or memorials
• Family reunions
• Beauty contests or commercial shows
• Marketing or advertising projects
• Land, building or equipment construction or renovation projects
• organisations that do not fully respect human as per the UN Guiding Principles on Business and Human Rights and the resolutions of ILO Conventions
• Anything that may have detrimental effect on our natural environment/ biodiversity
• Entities without good standing and a clean record with authorities

Coca‑Cola HBC will only support organisations that do not conflict with Coca‑Cola HBC’s business principles and Code of Business Conduct and will fully disclose if there is any conflict of interest.

Coca-Coca HBC’s preference is for non-profit organisations that:

• Have long-term goals and objectives that are publicly communicated
• Are committed to sustainable development
• Are well regarded by stakeholders
• Encourage stakeholder engagement and volunteerism
• Are transparent about their activities and report on those publicly

Reducing risk

The guidelines below explain how to reduce risk related to corporate contributions:

• Decisions to give corporate contributions should be approved in accordance with our company’s chart of authority
• Ensure that corporate contributions are not being used as a disguise for bribery
• Perform due diligence of new receivers or partners
• Be aware of potential conflicts of interest
• Avoid donations and sponsorships that may be perceived as political contributions
• Obtain the approval of Coca‑Cola HBC’s Legal department in case any government official is a director or officer of a non-profit organisation or is otherwise closely associated with the non-profit organisation, or requests that the Company donate to the non-profit organisation
• Ensure that all payments are properly recorded in the accounts
• Avoid any confidentiality clauses in charity and sponsorship agreements to enable us to freely publicly disclose such contributions.
• Contributions in a form of donations made to government agencies are permissible, provided that:
  • Coca‑Cola HBC’s Legal counsel has been consulted regarding acceptability under local law
  • There is no expectation that the contribution is given in exchange for any return favour or business advantage from the government (quid pro quo)

Employee volunteering

Coca‑Cola HBC encourages employees to give their time and expertise to support local community and community partner organisations, as well as donate management time and expertise to support non-governmental organisations in their core activities.

Governance

The Coca‑Cola HBC Corporate Contributions policy is managed by the Group Public Affairs and Communications team.

Recommendations are validated by the Sustainability steering committee prior to presentation to the Company’s Operating Committee and the Board of Director’s Social Responsibility Committee.

All organisations requesting support will be informed with resolution in due course.

Payment terms and contracts

Coca‑Cola HBC has standard terms for payments, including those made to charities and non-profit organisations.

All partnerships must be supported by appropriate documentation, i.e., contract, agreement, declarations of compliance to ethics codes, etc. The contract should state in detail amounts payable, payment periods, objectives and purposes of the contribution, as well as any other relevant information, and is subject to review and approval by Coca‑Cola HBC’s Legal department in the local operation or at the Corporate Service Center.

Process for evaluation, communication and renewal

Coca‑Cola HBC evaluates the effectiveness and impact of its corporate contributions. The evaluation will include:

• Ensuring applicants comply and continue to comply with the terms and objectives of Coca‑Cola HBC’s Corporate Contributions Policy.
• Coca‑Cola HBC maintains a regular dialogue with those organisations it supports both to improve management of existing projects and to identify future opportunities. In addition, charitable, non-profit and non-governmental organisations are regularly invited to take part in Coca‑Cola HBC’s annual Stakeholder Forum, which helps assess and determine the content and relevance of the company’s sustainability strategy.
• Coca‑Cola HBC is also committed to communicating its corporate contributions programme to employees and the public at large, via the company’s main communication channels, as part of broader efforts to encourage employee and stakeholder engagement in volunteering initiatives.

Reviewing and updating this Policy

This Policy is reviewed at least once a year by Coca‑Cola HBC’s Group Public Affairs and Communications team and learnings are integrated, stakeholder feedback is collected and the policy is amended.

 

Responsible officer for maintaining Coca‑Cola HBC’s Corporate contributions policy:

Petya Djoneva

Group Community Affairs Director

Public Affairs and Communications

Coca‑Cola HBC AG

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Our environmental policy is set out below. The responsibility for overseeing the implementation of this policy lies with the Corporate Social Responsibility Committee of the Board of Directors.

Coca‑Cola Hellenic is committed to conducting all its business activities responsibly with due regard to environmental impact and sustainable performance. The Company believes that the environment is everybody’s responsibility and all employees are accountable for environmental performance.

Coca‑Cola Hellenic seeks to achieve steady improvement in meeting its environmental standards while working to minimize any negative impact on the local and global environment as the Company grows its business.

To reach these targets, Coca‑Cola Hellenic:

• Conducts operations in compliance with all applicable laws and regulations and applies its high internal environmental standards
• Implements and certifies the internationally recognised environmental management system, ISO 14001, in all of its operations to ensure accountability and continuous improvement
• Includes environmental strategies and objectives in its business planning process to ensure that management of environmental impact remains an integral part of its operations
• Identifies environmental aspects, sets environmental goals, monitors results and audits processes in order to assess its performance against internal and external environmental standards
• Identifies and implements ways to improve the efficiency with which the Company uses materials and resources, prevents pollution, minimises emissions, and recycles waste
• Commits to conserve watersheds by saving water and treating wastewater
• Commits to protecting the climate by reducing energy use and coolant emissions
• Plays a leading role within the beverage industry in promoting sustainable packaging by light weighting, recycling beverage containers and using recycled content in its packages
• Encourages and equips its employees to identify and act upon opportunities to improve environmental performance and waste management in the areas where they work
• Partners with stakeholders in seeking and developing solutions to those environmental problems on which the Company can make an effective and lasting contribution
• Communicates its environmental requirements and performance to stakeholders

 

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Our fleet safety policy is set out below. The responsibility for overseeing the implementation of this policy lies with the Corporate Social Responsibility Committee of the Board of Directors.

Coca‑Cola Hellenic cares about the health and safety of its employees and those affected by the Company’s business activities. As part of its Occupational Health and Safety policy, the senior management of the Company has committed to minimising the risk of injury and death resulting from work-related vehicle accidents and encourages all employees to apply safe vehicle practices during non-business hours.

Coca‑Cola Hellenic’s commitment to minimise the risk of vehicle accidents requires all operations to:

• Comply with all vehicle and driver safety legislation
• Communicate fleet safety responsibilities and accountabilities to all employees
• Provide specific vehicle safety training including safe eco-driving and defensive driving
• Set safety as a criterion for vehicle selection
• Ensure criteria for driver selection
• Ensure vehicle safety features are appropriate for the working environment
• Ensure vehicle safety features are fitted, operational and used in all Company vehicles
• Ensure that all vehicles are operated within their designated load and occupancy limits
• Implement vehicle maintenance procedures to ensure vehicles are safe for use on the road
• Plan routes and journeys including breaks to prevent fatigue
• Investigate accidents and implement preventive measures to avoid recurrences
• Review road safety performance and include improvement measures in business plans

In addition, the Company supports driver-education sessions to create awareness of the risks of fatigue and distraction such as using mobile phones, reading maps and programming satellite navigation systems.

A Fleet Safety Policy Support document provides information to assist compliance with this policy and countries have local fleet safety policies to manage their specific risks and legal requirements.

The scope of this policy covers Coca‑Cola Hellenic employees driving on Company business, but the principles and practices of the Fleet Safety Policy are strongly recommended also for contractors, suppliers and others engaged in business with Coca‑Cola Hellenic.

 

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Our genetically modified organism position statement is set out below.

Coca‑Cola Hellenic does not use ingredients that are genetically modified or derived from genetically modified organisms in any of the 28 countries in which it operates. Given this situation, and as there is no requirement either regulatory or commercial to label the absence of such ingredients, the company does not do so.

It is the Company’s position that it supports the responsible use of modern biotechnology within the framework of effective regulatory control and the provision of adequate information about its use. The use of such technology to improve food crops can bring important benefits to mankind, and individual applications should be judged on their merits.

Coca‑Cola Hellenic acknowledge the fact that the public view of the use of genetically modified ingredients in foods is still evolving, and notes that the debate and public acceptance of these is at different stages in countries in Europe and the rest of the world.

As the public discussions continue, the Company is monitoring the situation and is prepared to review and modify its policy in light of any developments that may occur.

Coca‑Cola Hellenic encourages reasonable and scientifically sound solutions and supports and assists suppliers in adhering to the same standards.

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Our health & wellness policy is set out below. It is owned and endorsed by the Corporate Social Responsibility Committee of the Board of Directors; responsibility for the successful implementation of this programme belongs with every Coca‑Cola Hellenic employee at each level and function in the organisation.

Coca‑Cola Hellenic cares about the health of its consumers. The Company offers an increasingly wide range of drinks, from traditional sparkling beverages, including regular and low calorie, to juices, waters and other still drinks. All of these can be enjoyed as part of a healthy diet.

Our range of drinks is suitable for a wide variety of drinking occasions from morning till night. In addition, the Company supports activities promoting fitness and physical exercise.

Coca‑Cola Hellenic is committed to satisfying consumer demand for:

A broad choice of beverages

• We will continue to expand our range to include traditional sparkling beverages, juices, waters, teas, coffees and functional beverages that are improved, enhanced, and fortified for better health
• We will continue to promote low and no calorie beverages. The average calorie content of the Company’s beverages has declined by nearly 20 percent since 2001
• We will provide an appropriate choice of portion sizes so as to help consumers manage their intake of calories

Increased consumer information

Coca‑Cola Hellenic is committed to responsible communication about its products and to promoting clear, user-friendly front-of-pack nutritional labelling, together with nutrition programmes and supporting materials, to help consumers make well-informed choices.

Coca‑Cola Hellenic uses back-of-pack labelling to provide detailed information about calories, sugar, fat, saturated fat and salt content per serving, and a proportion of a healthy diet. This enables consumers to make informed decisions about weight control. Additional information is provided in Company publications, its website and consumer response services.

Responsible sales and marketing

Coca‑Cola Hellenic does not market its soft drinks in primary schools or target media advertising to children under the age of 12, and is working with third-party distributors to adhere to the same commitments.

In schools where children are above 12 years of age, the Company discusses with educators, parents and other stakeholders what beverages they feel are most appropriate.

Comprehensive lifestyle programmes

Coca‑Cola Hellenic is a founding signatory of the UNESDA1 Commitments, a set of voluntary industry obligations that address consumer information and education, healthy lifestyles and physical activity, advertising, beverage choice and research in the European Union. The commitments support the European Union (EU) Platform for Action on Diet, Physical Activity and Health, the major multi-stakeholder partnership to combat obesity, and apply to all the Company operations within the EU.

Promoting sports and physical activity

Coca‑Cola Hellenic actively develops, participates in, and financially supports a wide variety of sporting events and other physical activities as a means of promoting overall fitness and, in particular, encouraging people to manage body weight and prevent obesity. The Company works with government agencies, sports and nutrition experts, and industry members in coordinating exercise initiatives and nutritional education programmes.

We encourage our employees to be fit and healthy, providing them with advice and information on nutrition, health and wellness as well as providing gym facilities in a number of locations.

 

1 European Beverages Association

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Our HIV / Aids policy is set out below.

Outline

Coca‑Cola Hellenic is fully committed to the well being of its employees. The Company recognises that its employees can be exposed to the risk of acquiring HIV/ AIDS and that the high incidence of HIV/AIDS in some countries is compounded by the absence of social or medical support systems to treat affected people.

This policy has been established to address these issues in two ways:

• To reduce the risk of infection to employees and their families through education programmes that create awareness to how HIV / AIDS is transmitted, and how infection can be prevented
• To ensure that by working closely with local governments, appropriate help organisations and The Coca‑Cola Company, Coca‑Cola Hellenic can contribute to the provision of antiretroviral drugs for affected staff and their families in countries where there is a high incidence of HIV/AIDS and where treatment is not readily available

This Policy has been formulated with reference to the Joint United Nations Programme on HIV/AIDS, ILO Code of Practice on HIV/AIDS and The Coca‑Cola Company Africa Corporate Guidelines.

Purpose

• To create awareness on the issue of HIV/AIDS by educating staff, providing confidential counselling and advice to ensure that affected employees are treated with respect and dignity
• To provide guidance on such issues as testing, screening, confidentiality and nondiscrimination in employment

Confidentiality

The HIV status of any individual will be kept strictly confidential. Medical records of associates with HIV will be considered as confidential information.

Access to such information is strictly limited to medical personnel within the Company and may be disclosed only if legally required and with the consent of the employee concerned.

Voluntary disclosure

An employee who is infected with the HIV virus or suffers from AIDS is not obliged to inform the Company. If an employee discloses to his or her Manager or Human Resources representative information on their physical condition, such as HIV/AIDS, the Manager will be supportive and listen to the employee, noting key concerns. If the Human Resources representative is not aware of the situation, the Manager will contact the Human Resources representative for guidance and resources to help address the employee’s needs, only with the consent of the employee. Every instance will be handled on a case-by-case basis to balance the needs of the employee with the needs of the business.

Medical testing

The Company will not require new job applicants or Coca‑Cola Hellenic employees to disclose HIV/AIDS related personal information unless required by applicable law.

Employees who wish to determine their HIV/AIDS status may arrange to be tested voluntarily, subject to the completion of informed consent documentation and pre- and post-test counselling.

Counselling

Where counselling is not available, the Company will make available supplementary information and education programmes to all employees. Where possible and appropriate, this service and programmes will be extended to family members of associates.

We will also seek assistance from established community support and counselling groups. Information for these resources can be requested confidentially from the Human Resources Manager, or HR representative.

Reasonable accommodation and job security

Coca‑Cola Hellenic will take measures to extend reasonable accommodation to employees with HIV/AIDS related illnesses. This could include re-arrangement of working time, special equipment, opportunities for rest breaks, time off for medical appointments, flexible sick leave, part-time work and return to work arrangements.

Employees who are HIV positive, are free to continue to work and will be treated like any other employee with regard to training, promotion, transfer, discipline and other social welfare. Provisions under the existing Company policies and procedures regarding sick leave and impairment/disability will be applicable as instituted in instances of chronic ill health.

The Company will not dismiss an employee purely on the basis of his/her HIV/AIDS status.

Where an employee with an AIDS related condition is too ill to continue to work and where alternative working arrangements, including extended sick leave, have been exhausted, the employment relationship may cease in accordance with anti-discrimination, labour laws and Company policies and procedures.

Risk reduction and management

Coca‑Cola Hellenic will work to ensure a safe and healthy working environment, including the application of precautions and the provision and maintenance of protective equipment and first aid.

Non-discrimination grievance and disciplinary procedures

Where an employee perceives discrimination to be occurring as a result of his/her HIV/AIDS status, that individual shall have recourse to the Company’s internal grievance procedures.

Coca‑Cola Hellenic will take the corrective and disciplinary actions necessary against employees found to be involved in harassment or discrimination against employees directly or indirectly affected with HIV/AIDS.

Information sharing

In order to ensure the Company is in a good position to respond to the health needs of its workforce and to assist its efforts in future manpower planning, it may undertake means to obtain a realistic assessment of the HIV situation in the Company. Such assessment will be undertaken on a voluntary participation basis, and information will be kept confidential.

The Company ensures such information will not disclose the identity of individuals.

Policy review

This policy will be reviewed and updated as and when the need arises or when developments relating to it necessitate policy review.

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Coca‑Cola HBC's human rights policy is set out below.

• Respect for human rights is fundamental to the sustainability of Coca‑Cola HBC and the communities in which we operate. In our Company we are committed to ensuring that people are treated with dignity and respect.
• Coca‑Cola HBC’s Human Rights Policy is guided by international human rights principles encompassed in the Universal Declaration of Human Rights, the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, the United Nations Global Compact and the United Nations Guiding Principles on Business and Human Rights.
• The Human Rights Policy applies to Coca‑Cola HBC, the entities that it owns, the entities in which it holds a majority interest, and the facilities that it manages. The Company is committed to upholding the principles in this Policy. Our Supplier Guiding Principles apply to our suppliers and are aligned with the expectations and commitments of this Policy.

Respect for human rights

Coca‑Cola HBC respects human rights. We are committed to identifying and preventing any adverse human rights impacts in relation to our business activities through human rights due diligence and preventive compliance processes.

Community and stakeholder engagement

We recognise our impact on the communities in which we operate. We are committed to engaging with stakeholders in those communities to ensure that we listen to, learn from and take into account their views as we conduct our business. Where appropriate, we are committed to engaging in dialogue with stakeholders on human rights issues related to our business. We believe that local issues are most appropriately addressed at the local level. We are also committed to creating economic opportunity and fostering goodwill in the communities in which we operate through locally relevant initiatives.

Valuing diversity

We value the diversity of our people and the contributions they make. We have a long-standing commitment to equal opportunity and do not accept discrimination and harassment. We are dedicated to maintaining workplaces that are free from discrimination or harassment on the basis of race, sex, color, national or social origin, religion, age, disability, sexual orientation, political opinion or any other status protected by applicable law. The basis for recruitment, hiring, placement, training, compensation and advancement at the Company is qualification, performance, skills and experience. 

Regardless of personal characteristics or status, the Company does not tolerate disrespectful or inappropriate behaviour, unfair treatment or retaliation of any kind. Harassment is unacceptable in the workplace and in any work-related circumstance outside the workplace. These principles apply not only to Company employees but also to the business partners with whom we work. 

Freedom of association and collective bargaining

We respect our employees’ right to join, form or not to join a labour union without fear of reprisal, intimidation or harassment. Where employees are represented by a legally recognised union, we are committed to establishing a constructive dialogue with their freely chosen representatives. We are committed to bargaining in good faith with such representatives.

Safe and healthy workplace

We provide a safe and healthy workplace and comply with applicable safety and health laws, regulations and internal requirements. We are dedicated to maintaining a productive workplace by minimising the risk of accidents, injury and exposure to health risks.

We are committed to engaging with our employees to continually improve health and safety in our workplaces, including the identification of hazards and remediation of health and safety issues.

Workplace security

We are committed to maintaining a workplace that is free from violence, harassment, intimidation and other unsafe or disruptive conditions due to internal and external threats. Security safeguards for employees are provided as needed and will be maintained with respect for employee privacy and dignity.

Forced labour and human trafficking

We prohibit the use of all forms of forced labour, including prison labour, indentured labour, bonded labour, military labour, slave labour and any form of human trafficking.

Child labour

We prohibit the hiring of individuals that are under 18 years of age for positions in which hazardous work is required.

Work hours, wages and benefits

We compensate employees competitively relative to the industry and local labour market. We operate in full compliance with applicable wage, work hours, overtime and benefits laws.

Guiding and reporting for employees

We are committed to creating workplaces in which open and honest communications among all employees are valued and respected. Our policy is to follow all applicable labor and employment laws wherever we operate.

If you believe that a conflict arises between the language of the policy and the laws, customs and practices of the place where you work, if you have questions about this policy or if you would like to report a potential violation of this policy, you should raise those questions and concerns through existing processes, which make every effort to maintain confidentiality. You may ask questions or report potential violations to local Management, Human Resources, Legal Department or Business Resilience. Coca‑Cola HBC is committed to investigating, addressing and responding to the concerns of employees and to taking appropriate corrective action in response to any violation.

 

The Company reserves the right to amend this policy at any time

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At Coca‑Cola Hellenic we benefit greatly from the skills, experience and commitment of the diverse range of people who work with us.

We recognise that that diversity is essential to us being able to best serve our customers and strive to ensure that no one is treated inappropriately or disrespectfully at our workplace. This is aligned with our Values to act with integrity and care for our people.

At Coca‑Cola Hellenic we benefit greatly from the skills, experience and commitment of the diverse range of people who work with us. We recognise that that diversity is essential to us being able to best serve our customers and strive to ensure that no one is treated inappropriately or disrespectfully at our workplace. This is aligned with our Values to act with integrity and care for our people.

This policy sets out our approach to inclusion and diversity and the avoidance of discrimination at work.

Inclusion and diversity for the purposes of this policy means the creation of a respectful work environment in which people neither discriminate nor are discriminated against in any context on the basis of the following characteristics:

1. Age
2. Disability
3. Gender or gender reassignment
4. Sex or sexual orientation
5. Marital or civil partnership status
6. Family status including pregnancy, maternity, paternity or other carer status
7. Race including ethnic origin, nationality or colour
8. Religious, political or other beliefs
9. Full-time or part-time status
10. Any other characteristic in respect of which legal protection is afforded by local law

Discrimination for these purposes includes one of the above characteristics being a factor in someone not being treated as favourably as they would otherwise have been treated, even if that characteristic was not the only or the main factor related to the treatment.

Harassment includes any disrespectful actions or statements related to the above characteristics or any other form of behaviour that does not involve being treated with respect and dignity. It includes any verbal or physical conduct designed to threaten, intimidate or coerce, or verbal taunting that, in the employee's opinion, impairs his or her ability to perform his or her job. This applies in the workplace and outside the workplace (when dealing with customers, suppliers or other work-related contacts, and on work-related trips or events including social events).

Sexual harassment in any form is prohibited under this policy. Sexual harassment is defined as unwelcome sexual advances, requests for sexual favours, and other verbal or physical conduct of a sexual nature when submission to or rejection of such conduct is used as the basis for employment decisions, or when such conduct has the purpose or effect of creating an intimidating, hostile, or offensive working environment.

Application

This policy applies to all people who work for us (including our employees, contractors, consultants, advisors, temporary workers and agency workers) and applies throughout the course of their dealings with us, including when they apply to work for us and after they cease working for us. It covers all aspects of employment with us, including recruitment, pay and conditions, training, appraisal, promotion, conduct at work, disciplinary and grievance procedures, and termination of employment. The policy creates both rights to be enjoyed by people who work for us and responsibilities for those same people to behave in a similar manner to ensure that others enjoy those same rights.

Leaders and managers within our business should assume particular responsibility to give effect to inclusion and diversity and robustly and promptly address any conduct that breaches this policy of which they become aware.

Complaints

Incidents of non-compliance with this policy or of any other conduct that affects inclusivity and diversity should ordinarily be reported to line managers in the first instance. Such incidents may alternatively be reported to a line manager’s line manager or to a member of Human Resources. We are committed to dealing promptly and thoroughly (and with as much confidentiality and sensitivity as is possible) with any such complaints.

We do not tolerate any form of victimisation relating to any complaint made in good faith. Victimisation includes not only conduct directed at the complainant but also conduct directed at any other person involved in any related investigation.

Sanctions

We may commence disciplinary or other applicable proceedings under our Code of Business Conduct against any person who we consider may have breached this policy. Such proceedings may lead to the imposition of appropriate disciplinary sanctions up to and including dismissal.

Policy status

We reserve the right to review and amend this policy to ensure that we are adequately promoting inclusion and diversity.

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Our occupational health & safety programme is set out below. It is owned and endorsed by the CSR committee of the Board of Directors; responsibility for the successful implementation of this programme belongs to every Coca‑Cola Hellenic employee at each level and function in the organisation.

Coca‑Cola Hellenic is committed to developing and applying effective occupational health and safety (OH&S) systems, standards and practices appropriate to risks associated with its business activities. The Company delivers its OH&S programme through structured implementation of the Occupational Health and Safety Assessment Series standard OHSAS 18001. This is enhanced by The Coca‑Cola Company and Coca‑Cola Hellenic specific occupational health and safety standards. This programme aims to provide and maintain a healthy, safe working environment and to minimise the risks to employees, contractors, visitors and others who may be affected by the activities of the company, while fulfilling consumer and customer expectations of high quality, safe products.

The commitment to providing a healthy and safe working environment supports the following health and safety principles:

1. Provide an environment where work-related health and safety risks are controlled to prevent injuries and occupational ill health
2. Comply with all national government and regulatory OH&S requirements in all Coca‑Cola Hellenic territories and to conform to relevant international standards by implementing continuous improvement programmes
3. Implement an effective OH&S management programme integral to ongoing business activities, which will:
   • Identify, assess and control risks from known causes of occupational injuries and ill health associated with workplace processes and working environments
   • Ensure that all employees, at every level of the organisation, understand and commit to implementation of the Coca‑Cola Hellenic OH&S policies and practices
   • Develop employee OH&S competency through effective training and leadership at all levels within the organisation
   • Subject OH&S systems, procedures and performance to internal and external audit and validation
   • Investigate the causes of work-related injuries and ill health and take action to prevent recurrence
   • Align the requirements of OH&S with all other business disciplines and ensure that they are subject to performance measurement and continuous improvement programmes
   • Include health and safety strategies in the annual business planning process to ensure that the subject remains an integral part of operations
   • Set annual measurable OH&S objectives for all operations, and at group level, to ensure continuous improvement and compliance with all standards

Coca‑Cola Hellenic reports its OH&S performance in its annual Integrated Report as part of its commitment to achieving excellence in OH&S performance.

 

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Our post-consumer packaging waste management policy is set out below. It is owned and endorsed by the Corporate Social Responsibility Committee of the Board of Directors. Responsibility for the successful implementation of this programme belongs with every Coca‑Cola Hellenic employee at each level and function in the organisation.

Coca‑Cola Hellenic is committed to continually improving its environmental performance in the area of packaging and packaging waste. All Coca‑Cola Hellenic territories are committed to continuous improvement, which is measured and evaluated for effectiveness.

The Company supports the implementation of post-consumer packaging schemes in all countries. The objectives are to:

• Co-own the country packaging management scheme (recovery organisation)
• Participate as an active member of the Management Board of Recovery Organisations with the appropriate participation at a senior level
• Own and take responsibility for collected material as members of authorised recovery organisations
• Implement efficient recovery organisation schemes at the lowest sustainable costs
• Develop and execute Business Plans according to the highest standards

To achieve these objectives, Coca‑Cola Hellenic:

• Enhances post-consumer packaging collection schemes and supports the education and awareness of consumers
• Engages in public awareness campaigns, selective waste collection education and anti-littering campaigns
• Works with government and industry to create a legal framework in which economic progress, diversion of material from landfill and emissions reductions can be achieved simultaneously
• Supports the view that public policy and regulatory interventions must encourage the development and implementation of appropriate technological solutions and enable the amendment of market mechanisms
• Promotes the development and expansion of organised collections of post-consumer packaging materials at public events to avoid littering
• Works to close the packaging loop in a sustainable manner
• Is committed to invest in Bottle-to-Bottle Recycling Plants in all countries with sustainable resources, i.e. cost-effective and efficient post-consumer PET collection schemes
• Includes packaging and packaging waste strategies in the annual business planning process to ensure that the subject remains an integral part of operations
• Sets annual measurable food safety and quality objectives for all operations, and at group level, to ensure continuous improvement and compliance with all standards

Coca‑Cola Hellenic will endeavour to:

• Influence policy, regulation and innovation by working to develop structured stakeholder dialogue, supporting the creation of equitable closed-loop packaging solutions, encouraging market mechanisms and promoting technological sorting innovations
• Activate cross-sector packaging associations to support solutions for dealing with the environmental impact of used packaging and packaging materials
• Ensure Coca‑Cola Hellenic consumers enjoy variety and freedom of choice in products and packaging options
• Enhance the efficiency and effectiveness of established post-consumer packaging waste management organisations
• Continue to drive light-weighting efforts for primary packaging and encourage the use of reusable and more efficient packaging design
• Continue to increase the recycled content of beverage packaging with emphasis on PET beverage bottles

 

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Our quality & food safety policy is set out below. It is owned and endorsed by the Corporate Social Responsibility Committee of the Board of Directors; responsibility for the successful implementation of this programme belongs with every Coca‑Cola Hellenic employee at each level and function in the organisation.

Coca‑Cola Hellenic believes that success depends on the supply of high quality products, packages and services that meet or exceed customer and consumer expectations of premium brand products. Fundamental to this belief is the responsibility to ensure the food safety of all products that the Company manufactures.

The Company is committed to continually enhance the reputation of the brands it produces and maintain consumer confidence in its products through the development and implementation of quality and food safety systems, standards and practices. All Coca‑Cola Hellenic operations commit to continuous improvement, which is measured, evaluated and validated for effectiveness through internal and external audits.

The Company believes that the responsibility for achieving quality commitments lies with each Coca‑Cola Hellenic employee in the execution of their jobs and their relationship with stakeholders. Food safety is the responsibility of all employees that have direct influence on ingredients, packaging, manufacturing, storage and the transport of products.

The following food safety and quality principles are the foundation of the Coca‑Cola Hellenic commitment to quality:

• Manufacture and deliver products that meet the highest food safety and quality standards.
• Meet or exceed all statutory and regulatory requirements for quality and food safety.
• Ensure sustainable food safety and quality performance through implementation and certification of effective quality management systems compliant with ISO 9001:2008, ISO 22000:2005, FSSC 22000 and The Coca‑Cola Management System standards in all operations and PAS 223:2011 where applicable.
• Validate the effectiveness of the food safety and quality management systems through internal and external audit processes recognised by the International Standards Organisation and The Coca‑Cola Company.
• Build food safety and quality capability through structured programmes that develop technical skills, increase awareness, manage risk and drive increasing levels of excellence.
• Continually review food safety policies, standards and procedures to effectively manage food safety risks associated with changes in products, processes and technologies.
• Include food safety and quality strategies in the annual business planning process to ensure that food safety and quality remains an integral part of operations.
• Set annual measurable food safety and quality objectives for all operations, and at group level, to ensure continuous improvement and compliance with all standards.
• Ensure that suppliers and contractors embrace the same food safety and quality commitments, and monitor the materials and services they supply through audits and incoming goods inspections.
• Communicate food safety requirements to suppliers, contractors, customers and consumers by establishing specifications for ingredients and packaging materials, product storage and consumer guidelines.
• Communicate food safety and quality aspects, strategies and performance to associates, consumers, customers and principal stakeholders that have an impact on, or are affected by the Company’s food safety and quality management systems.

 

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Our risk management policy is set out below.

 

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We’ve set out the key principles of our tax policy, how we will behave and how we will manage our processes.

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As a member of UNESDA, we uphold its commitments on public education, healthy lifestyles, physical activity programmes, consumer information, advertising and commercial communication, research, promotions and choice.

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Our water stewardship policy is set out below. It is owned and endorsed by the Corporate Social Responsibility Committee of the Board of Directors; responsibility for the successful implementation of this programme belongs with every Coca‑Cola Hellenic employee at each level and function in the organisation.

Water is vital to human and community development. Coca‑Cola Hellenic strives to limit its impacts on watersheds and promote water stewardship activities in the communities where it operates. We will ensure that our use of water respects the needs of our communities.

We believe that industry has a key role to play in finding sustainable solutions to today’s water challenges. We recognise that human development and climate change will profoundly influence water availability and will work to mitigate changes and adapt to them.

The direct water impacts of Coca‑Cola Hellenic operations result mostly from the use of water in bottling plants. Indirect impacts result from the virtual water embedded in its ingredients and, to a lesser extent, from its packaging.

In accordance with our environmental policy, we commit to: 

• Minimise the impact from operations, by decreasing water use and ensuring that wastewater is fully treated to levels that sustain aquatic life
• Assess future water availability and reduce environmental and social risks linked to our use of water
• Work with suppliers to understand the water footprint of raw materials, in particular agricultural products such as sugar and fruit
• Engage communities to increase awareness and protection of water resources, through local and international partnership programmes
• Provide emergency supplies of water to communities in the aftermath of disasters
• Contribute to the development of water standards and policies, locally and internationally, in partnership with key stakeholders
• Work with organisations and initiatives such the UN Global Compact Water
• Share and promote water stewardship practices

We report comprehensively and transparently on our water impacts and activities, under the guidance of key stakeholders.

 

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"Coca-Cola HBC Responsible Marketing policy: Premium Spirits" is set out below.