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Code of Conduct (CoC)

Our Ethics & Compliance Programme ensures we are conducting our operations in a lawful

and ethical manner. The Programme is overseen by our Audit Committee, and is applicable

to all employees, our officers and our Directors. It also supports how we work with our

customers, suppliers and third parties. As of 31 December 2018, the new Code of Conduct

(CoC) has been formally adopted in all the territories in which we operate, as well as our

shared service centre in Bulgaria. Our CoC ensures that we act with integrity and

accountability in all of our business dealings and relationships, in compliance with all

applicable laws, regulations and policies. It aligns with the UN Global Compact, the US

Foreign Corrupt Practices Act, the UK Bribery Act, the 2016 and 2018 UK Corporate

Governance Codes, The EU General Data Protection Regulation, the Spanish and

Portuguese Criminal Codes and Sapin II.3

 

Supplier Guiding Principles (SGPs) .4

 

In addition, we have amended our standard supplier

contracts to include specific anti-slavery obligations on suppliers, including the express

undertaking that neither the supplier nor any other person in its supply chain uses (or has

attempted to use) trafficked, bonded, child or forced labour.4

 

All procurement managers who interact with suppliers are given training on SGPs and

SAGPs as part of their induction. Following the launch of our new Code of Conduct,

employees in all countries where CCEP operates, have received the CoC mandatory training

on the new CoC. Our awareness-raising campaign on the new CoC included short

introductory animations on key business principles and focused on the ways to make a report

or share a concern.6