Nestlé in society Creating Shared Value and meeting our commitments 2015

Nestlé in society:
Creating Shared Value
Nutrition, health
and wellness
Rural development
Water
Environmental
sustainability
Human rights
and compliance
Our
people
Compliance
G4-50, G4-57, G4-58, Environmental grievance mechanisms G4-DMA, Labor practices grievance mechanisms G4-DMA, G4-LA16, Non-discrimination G4-DMA,
Human rights grievance mechanisms G4-DMA, Anti-corruption G4-DMA, Compliance G4-DMA (Society), Grievance mechanisms for impacts on society G4-DMA,
G4-PR4, G4-PR7, Compliance G4-DMA (Product responsibility)
The Nestlé Corporate Business Principles reflect our commitment to a strong compliance culture as a nonnegotiable
foundation of how we do business. Our principles are actionable and we are prepared to do what is
necessary to ensure that our company is managed in line with them through both internal reporting and external
audits. To help us improve our performance and business practices, we encourage employees, suppliers and
stakeholders to report practices or actions at Nestlé that are believed to be inappropriate or illegal. We properly
investigate all complaints with impartiality and we prohibit retaliation for reports made. When a breach is
uncovered, we act decisively to put an immediate end to it and take appropriate response measures.
Reporting of compliance violations
Our commitment
Ensure that all employees and stakeholders can
easily report possible compliance violations
We aim to enable all our employees to report any incidents of
non-compliance and breaches of the Nestlé Corporate
Business Principles, or other Nestlé internal standards.
Alongside the roll-out of the Nestlé Integrity Reporting
System, information on its use has been made available to all
employees. This has included translated versions in local
markets.
It is stipulated in the Reporting of non-Compliance Best
Practices document, in the Confidentiality chapter, that noncompliance
reports will be dealt with confidentially. Only the
fact that a report has been filed, the particulars of the report
and the identity of the incriminated employee will be shared
with those who need to know for the purposes of handling the
complaint and, if applicable, the investigation. In case the
complainant uses the Integrity Reporting System and chooses
to remain anonymous, Nestlé will be unable to learn of their
identity. If the complainant makes their report anonymously
but through a different reporting channel, Nestlé will fully
honour their decision to remain anonymous and will not try to
find out their identity.
As one of the monitoring channels, the CARE audit
programme’s business integrity section includes the question
‘Does the site investigate every non-compliance report and
protect the rights of both parties (reporting and incriminated)?’
Encouraging our external stakeholders to actively respect
our standards and codes is an important facet of Nestlé’s
business ethics, too. All external stakeholders can report
concerns in their own language through our Tell us reporting
system via a web form or by phone.
To enhance the communication, our strategy is to gradually
reinforce the system, initially as a pilot in countries identified
as potential high-risk areas, before extending it to all countries
where Nestlé operates (and where local data protection law
allows). Our challenge is to help people understand our
different reporting channels and give them the confidence to
use them.
The Nestlé Integrity Reporting System (internal)
Our objectives
By 2015 – The Nestlé Integrity Reporting System (Internal
Grievance Mechanism) or equivalent will be operational in
100% of Nestlé markets and information made available
to employees outlining the steps taken by the company to
manage concerns and complaints.
By 2016 – Reinforce awareness of the existence of
confidential reporting lines is enforced across the
organisation.
Our people should be vigilant for any illegal or non-compliant
activity in their place of work, and are required by our Code of
Business Conduct to report such incidents should they occur.
Incidents related to allegations of corruption, bribery, fraud or
any serious incident that may adversely affect the reputation
or public image of Nestlé are promptly reported directly to
higher levels, including to the Group General Counsel and
Chief Compliance Officer.
The Nestlé Integrity Reporting System enables our
employees to report anonymously, via phone or web form, any
illegal or non-compliant behaviour they observe, as well as to
seek advice or information on our practices. Nestlé’s Reporting
of non-Compliance Best Practices document provides a
general investigation protocol and guidance to promote a fair
and impartial process.
We continued to roll out the system across the business in
2015, and by the end of the year, 100% of markets had
introduced it, up from 98% in 2014 (this includes markets that
have other systems already in place that fulfil the requirements
of the Integrity Reporting System). Information about the
system is made available to employees outlining the steps
taken by the company to manage concerns and complaints.
The system has been well received by our employees and,
importantly, there is little indication that it is being abused by
complaints made in bad faith.
Guidance, including the implementation of a visible link to
the Integrity Reporting System on local intranets together with
an explanatory note, has been provided across the countries to
fulfil our objective.
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