Nestlé believes complying with laws and internal regulations ("Compliance") protects the Company's reputation and provides the basis for the creation of sustainable shared value. We pursue a zero tolerance strategy, yet a principles-based approach to Compliance. Accordingly, we have adopted a cross-functional set up of Compliance where a number of functions contribute to an integrated Compliance management. While responsibility and accountability for Compliance are assigned to the markets as per the Company's custodian concept, a corporate Compliance function and a cross-functional Group Compliance Committee define the framework, facilitate the coordination between the relevant support functions and drive key Compliance initiatives. In addition, the Company has established a Compliance network in the major markets and has replicated the Committee structure where appropriate.
Nestlé's Corporate Business Principles and the Code of Business Conduct are our non-negotiable worldwide minimum standards which are observed in addition to complying with locally applicable legislation. While the Corporate Business Principles, which include our commitment to the ten principles of the UN Global Compact, will continue to evolve and adopt to a changing world, they contain our basic foundation unchanged from the origins of our Company. Together with our Management and Leadership Principles, they reflect the basic idea of fairness, honesty and a general concern for people. Many other policies and standards complement this system.
The roll-out of the Code of Business Conduct marked a major milestone of the Group's Corporate Compliance program in 2008, which also included the adaptation of the Group's Supplier Code and the implementation of various focused compliance initiatives, including the launch of a corporate compliance e-learning tool, an anti-trust learning tool, the anti-fraud program, as well as a self-assessment of the Group's internal control system and an annual risk assessment, both as required by the new Swiss Company law. The Group Compliance function selects such initiatives on an ongoing basis to support the efforts at market level and sets the tone, provides a framework and know-how and supports the coordination and functional leadership by the various relevant functions, all as needed to create trust and protect our reputation in a changed legal and regulatory environment.
At the operational level, CARE is Nestlé's audit program to verify, through independent auditors, that our operations comply with the Corporate Business Principles in the areas of human resources, safety, health and environment. In 2008, a new module on business integrity was added to the program.