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
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.
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