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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
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Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Benchmarking Alert: Here’s Coca-Cola’s full anti-bribery policy

The Coca-Cola Company, incorporated in 1892, is one of the world’s oldest, most well-known, and widely consumed brands. How does it’s anti-bribery policy compare?

1. It takes daily effort.

It is therefore vital that you not only understand and appreciate the importance of this Policy, but also comply with it in your daily work.

2. Don’t pay bribes, or you might end up in jail.

Company employees that violate these laws can also face severe civil and criminal penalties, including jail time.

3. No facilitating payments (except sometimes).

The Company’s prohibition on bribery applies to all improper payments regardless of size or purpose, including “facilitating” (or expediting) payments. Facilitating payments refer to small payments to government officials to expedite or facilitate non-discretionary actions or services, such as obtaining an ordinary license or business permit, processing government papers such as visas, customs clearance, providing telephone, power or water service, or loading or unloading of cargo. Generally, facilitation payments are prohibited by this Policy, except for a very limited set of circumstances for which prior written approval must be obtained from both Company Legal Counsel and E&C.

This is similar to Tesla. In contrast, Apple, Novartis,  MicrosoftVolkswagen,  and Airbus ban all facilitating payments. Walmart doesn’t mention facilitating payments at all.

4. Never give a public official a gift card.

It is never permissible to provide gifts, meals, travel, or entertainment to anyone (government officials or commercial partners) in exchange for any improper favor or benefit. In addition, gifts of cash or cash equivalents, such as gift cards, are never permissible.

5. Some employees must certify compliance.

Every quarter, in conjunction with the Company’s Securities and Exchange Commission (“SEC”) Certification process, applicable employees are required to certify the accuracy of several representations related to this Policy. 

This is the first time we’ve seen SEC certification mentioned in an anti-bribery compliance policy.

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View more anti-corruption policy benchmarks here.

Here’s the full eight-page anti-bribery policy:

Anti-Bribery Policy _ The Coca-Cola Company FCPA Blog

 

Click here to download The Coca-Cola Company’s anti-bribery policy

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