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Harry Cassin
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Thomas Fox
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Benchmarking Alert: Here is Carlsberg Group’s anti-bribery policy

The Danish brewing giant, founded in 1847, employs over 41,000 people globally to produce some of the most widely consumed and beloved beers in the world. How does the Carlsberg Group’s anti-bribery and corruption policy compare?

1. One policy to rule them all. 

This policy applies globally to the management, employees and contract workers of all entities in the Carlsberg Group.

Where the Carlsberg Group participates in existing joint ventures as a non-controlling shareholder, the other shareholder(s) shall be made specifically aware about the significance to Carlsberg of the policy and shall be encouraged to apply the same policy or a similar standard to the joint venture. For contemplated new minority joint venture cooperations, Carlsberg shall strive to commit the other shareholder(s) to adopt the policy or a similar standard for the joint venture.

2. Don’t play with fire. 

Even the mere act of offering is prohibited, regardless of whether or not the item of value is actually accepted by the intended recipient.

3. No facilitating payments.

The Carlsberg Group does not allow the use of facilitating payments. Such payments may be considered a customary way of doing business in some countries, but it is important to understand that the anti-bribery laws of many countries prohibit such payments. Employees and third parties, in particular third-party intermediaries, are prohibited from making facilitating payments on the Group’s behalf.

This is similar to Apple, Novartis,  MicrosoftVolkswagenAirbusGM3M, and Pfizer which ban all facilitating payments. Coca-Cola and Tesla might approve some facilitating payments. Walmart doesn’t mention facilitating payments at all.

4. Key terms are defined. 

The misuse of public office or power for private gain or the misuse of private power in relation to business outside the realm of government.

5. The extortion defense. 

Under exceptional circumstances, i.e. when an employee’s safety is at risk, a facilitating payment may be permissible.

This is similar to GMMicrosoft, and Pfizer, the only three other mentions of extortion we’ve seen.

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View more anti-corruption policy benchmarks here.

Click here to view the Carlsberg Group’s anti-bribery and corruption policy

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