Governance and oversight
The Nestlé Code of Business Conduct, one of our key policies, including its commitment against any form of corruption or bribery, has been issued jointly by the Executive Board and the Board of Directors. The Code has been deployed throughout the entire organization worldwide and its implementation is accompanied by a robust and comprehensive training regime led jointly by Human Resources, Legal and Group Compliance departments.
Accountability for compliance with the Code of Business Conduct and for adhering to the zero tolerance policy in the area of corruption lies with the Market Head, i.e. the overall responsible CEO in a given territory. The Market Head is supported by dedicated functions such as Legal, Human Resources, Audit and Compliance, which assist in training and advising employees as well as in monitoring employee behaviour and consequence management. Local functions report into the respective corporate functions in order to ensure overall consistency and alignment.
The corporate compliance framework is defined by Group Compliance (see also Managing human rights and compliance), our dedicated compliance function that reports into the Group’s Compliance Committee and the Executive Board.
The Compliance Committee meets bi-monthly.It is our main platform to monitor the Company’s overall compliance performance, to review new projects and to update on any developments in the compliance arena, including our anti-corruption approach. Its make-up is truly cross-functional with all relevant functions represented at senior level. The minutes of the meetings are shared with the CEO .
The Executive Board reviews and validates both our Corporate Compliance Program once per year – on the basis of an annual and comprehensive Compliance Report – and reviews and approves all major Compliance projects on an ongoing basis, again, with the inclusion of our anti-corruption program. With this, it is guaranteed that the Executive Board is fully informed and kept up to date on the overall framework and direction of the Compliance Program as well as on individual projects and initiatives. The Compliance Report mentioned above is also shared with the Audit Committee as well as with the entire Board of Directors.
Anti-corruption monitoring is a component of our business auditing, both internally and externally through our CARE programme. We use audit findings to identify areas for improvement or functions that require additional training.
Activities that infringe on our Code of Business Conduct, including cases of bribery or corruption, are investigated on a case-by-case basis and may result in disciplinary sanctions or criminal charges. We encourage and expect our employees to report any misconduct either openly or confidentially. Our Integrity Reporting System, which we began rolling out in 2011, provides an additional option for anonymous, 24/7 confidential reporting of non-compliance.
Nestlé does not operate in environments where there is risk of high-level bribing. However, we do operate in environments where small bribes and/or facilitation payments are common practice. Thus, our focus is on enforcing our zero-tolerance policy, which includes banning all facilitation payments, regardless of whether they may be permitted under local laws.