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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 PepsiCo’s anti-bribery policy out of the cooler

PepsiCo produces some of the world’s most beloved drinks and snacks, including Pepsi, Gatorade, and Cheetos. With over 300,000 employees globally, how does its anti-bribery policy compare?

1. The policy applies from top to bottom.

This policy applies to all PepsiCo Associates. For purposes of this policy, PepsiCo Associates include:

– All PepsiCo associates around the world (including employees of our subsidiaries)

– Members of the PepsiCo Board of Directors when they act in their capacity as directors

– The employees, officers, and directors of any joint venture or affiliate over which PepsiCo has majority ownership or management control (e.g., consolidated subsidiaries)

2. Keep an eye on third-party red flags.

PepsiCo may be liable for the actions of Third Parties who offer or pay a Bribe to a Government Official on behalf of PepsiCo. Bribes made through PepsiCo Third Parties are prohibited. It is also a breach of this policy to ignore warning signs that a Third Party’s actions may result in a Bribe being given or offered.

3. No facilitation payments.

No PepsiCo Associate may give or offer a Bribe or Facilitating Payment. PepsiCo does not allow Facilitating Payments and such payments are a violation of this policy, even where allowed by law. Accordingly, all references within this policy to a Bribe also include Facilitating Payments.

This is similar to Glencore, Ferrari, Kraft Heinz, 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. Extortion defense.

PepsiCo Associates must never pay a Bribe, except where a refusal to pay a Bribe demand would create an immediate threat to their health or safety. All Bribe payments made to avoid a dangerous situation, and all Bribe demands (regardless whether the payment was actually made), must be reported immediately to the local Compliance & Ethics officer or local Law Department.

5. Charitable donations involving government officials.

Charitable donations include the donating of cash, product, or corporate resources (including personnel time). Charitable donations or sponsorships made directly or indirectly to a Government Official are never allowed. However, donations to, or sponsorships of, Government Entities or relating to a Government Official, may be given in limited circumstances. For purposes of this policy, a donation or sponsorship recipient is considered “relating to” a Government Official if the recipient entity is known to be owned, managed, or directly controlled by a Government Official, including where a Government Official sits on the board.

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View the full six-page PepsiCo global anti-bribery policy compliance policy.

View more anti-corruption policy benchmarks here.

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