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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
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Benchmarking Alert: Taking the Kraft Heinz global anti-corruption policy off the shelf

Kraft Heinz produces some of the world’s favorite foods that have been pantry staples for generations. Every person reading this post is almost certain to have at least one Kraft Heinz product in their kitchen. How hearty is its anti-bribery and corruption policy?

1. A succinct definition of bribery and corruption. 

The anti-bribery/anti-corruption laws that apply to Kraft Heinz and its employees are generally broad in their scope and application. These laws make it illegal for anyone to offer, promise, give, solicit, or receive – directly or indirectly – money or “anything of value” to or from a Government Official or someone in the private sector in order to obtain or retain business or secure some other “improper advantage.” Under these laws, bribes can take many forms, including cash, gifts, entertainment, travel, charitable donations, or favors given (e.g., getting a job at the Company for the child of a Government Official).

2. Your job is on the line.

Any employee who fails to comply with this Policy will be subject to appropriate disciplinary action, up to and including termination of employment.

However, no person subject to this Policy will suffer adverse consequences for refusing to offer, promise, pay, give, or authorize an improper or unlawful payment, benefit, advantage, or reward, even if doing so results in the loss of business opportunities for Kraft Heinz.

3. No facilitation payments.

The laws of most countries, including the UK, do not permit making facilitation payments. Accordingly, the Company strictly prohibits Facilitation Payments.

This is similar to Burberry, Disney, Unilever, Carlsberg, Apple, Novartis, Microsoft, Volkswagen, Airbus, GM, 3M, and Pfizer that all ban facilitating payments. Coca-Cola, Tesla, and ExxonMobil might approve some facilitating payments. Walmart doesn’t mention facilitating payments at all.

4. The extortion defense… has its limits.

We value the safety of our employees. You will not be penalized for actions take that would otherwise violate this policy where there is an imminent threat of danger to life or safety . . . This exception will be interpreted narrowly. Any employee who relies in bad faith on this provision to provide an otherwise prohibited payment will be subject to appropriate discipline, up to and including termination.

This is similar to Disney, Unilever, Carlsberg, GM, Microsoft, Pfizer, and ExxonMobil the only other mentions of extortion we’ve seen.

5. Training day.

All white collar employees and selected blue collar employees must undergo anti- corruption training provided by the Company on a periodic basis. The nature, content and frequency of that training will be determined by the Company based on your job responsibilities, seniority, and location.

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View the full fourteen-page Kraft Heinz global anti-bribery and corruption policy.

View more anti-corruption policy benchmarks here.

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