Nestlé in society Creating Shared Value and meeting our commitments 2015

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Nestlé in society: Creating Shared Value Nutrition, health and wellness Rural development Water Environmental sustainability Human rights and compliance Our people G4-50, Compliance G4-DMA (Environmental), Non-discrimination G4-DMA, Security practices G4-DMA, G4-HR7, Anti-corruption G4-DMA, Compliance G4-DMA (Society), Grievance mechanisms for impacts on society G4-DMA, G4-PR4, Compliance G4-DMA (Product responsibility) The CARE audit programme Compliance regarding human rights and labour practices, business integrity, safety and health, environmental sustainability and security is assessed through the CARE programme, which relies on an independent external audit network. • All sites owned or operated by Nestlé are audited on a three-year auditing cycle following the annual action plan discussed and approved by the Group Compliance Committee (US CARE programme is carried out every five years); • Any gaps are addressed through detailed action plans and implementation is monitored closely; and • The programme is led by a Market CARE Coordinator who is responsible for ensuring that audits are performed in a timely fashion, action plans are implemented and all information is uploaded in SAP. In 2015, we carried out 250 CARE audits across Nestlé, taking our cumulative total to 2207 audits since 2005. The audits, which take place every three years (every five years for the CARE program in the United States), are performed by three leading independent audit companies: SGS, Bureau Veritas and Intertek. Where necessary, we introduce detailed action plans that are thoroughly and systematically monitored. The findings are classified in three categories: • Minor – an isolated and non-repetitive finding or minor issue; • Major – a systematic finding or major issue or infringement against local legislation; and • Critical – an exceptional issue, which requires immediate notification to the Nestlé Group Compliance Committee. CARE gaps identified 2015 Human rights and labour practices Safety and health Environmental sustainability Business integrity Security Minor 64 40 39 12 21 Major 5 2 0 0 1 Critical 0 0 0 0 0 By the end of 2015, we had identified 184 CARE gaps. We have introduced corrective action plans to cover these gaps, 36 of which are now closed. The remaining corrective action plans are in the process of being implemented. Nestlé in society – Creating Shared Value and meeting our commitments 2015 246
Nestlé in society: Creating Shared Value Nutrition, health and wellness Rural development Water Environmental sustainability Human rights and compliance Our people G4-56, Anti-corruption G4-DMA, G4-SO3, G4-SO4, G4-SO5 Anti-corruption and privacy Nestlé strives to combat bribery and corruption wherever these practices arise. They can have a negative impact on our performance and operations, and on stakeholders’ perception of Nestlé as a company. However, we recognise that these activities can and do occur in some of the countries in which we operate. We, therefore, aim to ensure that our commitments, policies and standards for combating bribery and corruption are clear and applicable for all our people and our suppliers. Communicating transparently about data privacy to our consumers and protecting personal data against cybercrime are also of paramount importance for Nestlé. We actively adopt initiatives or develop internal tools to ensure proactive disclosure of how personal data is used, often going beyond what is legally required. Anti-corruption Nestlé is firmly opposed to bribery and corruption and we will not tolerate these practices in our operations. Our Code of Business Conduct sets out clearly our stance on these issues. Our Anti-Corruption Programme is being rolled out to all markets and businesses, and a compliance e-learning course ensures employees understand what is expected of them. Our commitment Work against corruption and bribery Shaped by our Code of Business Conduct and the UNGC, we have pledged our commitment to maintaining a strong culture in four areas: • We will not use bribes: our Code of Business Conduct states that employees must never, directly or through intermediaries, offer or promise any personal or improper financial or other advantage in order to obtain or retain a business or other advantage from a third party, whether public or private. • We will not accept bribes: Nestlé prohibits its employees from accepting any improper financial or other advantage in return for any preferential treatment of a third party. We will not allow employees or other representatives to base commercial decisions on anything but rational, objective and transparent criteria. • We are against facilitation payments: we have a zero-tolerance policy on facilitation payments (payments made to a public or government official that act as an incentive for the official to complete some action or process expeditiously to the benefit of the person making the payment) which prohibits our employees from making any such payments, regardless of whether they are permitted under local laws. • We will not use others to do what we consider wrong: anyone working on Nestlé’s behalf must not break any of our commitments and shall not take any actions to violate, or cause its business partners to violate any applicable anti-bribery laws and regulations, including the US Foreign Corrupt Practices and the UK Bribery Acts. If these rules are broken, we will end the relationship immediately. Our objectives By 2015 – Reinforce the Anti-Corruption Programme and communicate it to all markets and businesses. Roll out a new compliance e-learning to ensure employees understand what is expected of them. By 2016 – Adoption of local Anti-Corruption Policy implementation procedures in those markets and businesses where there is a need for further reinforcement. By 2017 – All employees with computers to complete the compliance e-learning. Anti-corruption training for our employees Nestlé is mindful of the many issues involved in anti-corruption activities and in ensuring that our business principles are reinforced in everything we do. This is why we place great emphasis on appropriate training and awareness raising, enabling the company to identify, monitor and address issues whenever they arise. Based on our standards as to who must be trained on anticorruption and compliance, and how often depending on seniority and length of service, we continued the deployment of many online courses in 2015. These included translated versions for local markets and reached 22 729 employees, of whom 6568 (29%) occupy management positions. This training will continue to be deployed locally throughout 2016, and be defined by markets according to local conditions. Monitoring anti-corruption Our CARE audit programme enables us to monitor anticorruption processes, allowing for the identification of improvement areas or opportunities for additional training. Employees are encouraged to report misconduct through our Integrity Reporting System. New employees are also required to declare any conflicts of interest on joining, and some markets regularly question employees on potential conflicts. We take all allegations of bribery and corruption seriously. We thoroughly investigate each incident before deciding if there should be any disciplinary action. No public allegations of corruption were made against Nestlé in 2015 and 10 internal private bribery complaints were confirmed. Nestlé in society – Creating Shared Value and meeting our commitments 2015 247
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Nestlé in society Creating Shared Value and meeting our commitments 2015

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