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WHAT is THE
CODE OF BUSINESS CONDUCT?
866-790-5579 www.KOethics.com
• You also can seek guidance from, or report violations to, your
management, or responsible employees in Finance, Legal, Strategic
Security or the Ethics & Compliance Office.
In all cases, employees will not be subject to retaliation or other adverse
consequence for reporting any potential Code violation or other
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compliance issue.
SUBJECT MATTERS
UNDER the CODE
• Conflicts of Interest
• Financial Records
• Use of Company Assets
• Working with Customers and Suppliers
• Working with Governments
• Protecting Information
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CONFLICTS of INTEREST
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PRINCIPAL MANAGER
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CONFLICTS of INTEREST
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CONFLICTS of INTEREST
The action: • Can an employee own stock in a company that is a
customer, supplier or competitor of The Coca-Cola
Company?
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FINANCIAL RECORDS
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FINANCIAL RECORDS
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FINANCIAL RECORDS
The action: • I am an accounting clerk and over the last few months
I have noticed that one of the sales office staff has
purchased two televisions and charged them to repairs
and maintenance expense. The invoices have been
approved, but based on what I normally see, this looks
suspicious. What should I do?
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FINANCIAL RECORDS
The action: • I am a route driver and I saw a colleague steal
cash from a customer sale and cover the theft
by altering the invoice. I do not report the
matter to my supervisor. How many times has
the Code been violated?
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USE of COMPANY ASSETS
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USE of COMPANY ASSETS
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USE of COMPANY ASSETS
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WORKING with
CUSTOMERS & SUPPLIERS
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WORKING with
CUSTOMERS & SUPPLIERS
The action: • I have become good friends with one of my vendors
that we buy from regularly. Does the Code prevent
me from purchasing from this vendor?
The decision: • No. The mere fact that you are friends with a vendor
does not prohibit you from business dealings.
However, the Code requires that you avoid situations
where your personal interests conflict with or have the
appearance of conflicting with those of the Company.
Therefore, avoid giving preferential treatment to the
friend. Ask your manager for guidance if you remain
uncertain.
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WORKING with
CUSTOMERS & SUPPLIERS
The action: • What if I participate in a customer or supplier
sponsored contest and win a television or a
vacation. Does the Company’s Code mean I
cannot accept it?
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WORKING with GOVERNMENTS
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PROTECTING INFORMATION
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PROTECTING INFORMATION
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PROTECTING INFORMATION
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ADMINISTRATION of THE CODE
REPORTING VIOLATIONS
If you want to ask a question about, or report violations of, the
Code of Business Conduct or any other ethics or compliance issue,
you have several resources.
• Contact EthicsLine by phone or through a secured Internet site 24
hours a day, seven days a week. You can report anonymously if you
wish. If calling from outside the United States and Canada, use the
international access codes found on the EthicsLine website.
866-790-5579 www.KOethics.com
• You also can seek guidance from, or report violations to, your
management, or responsible employees in Finance, Legal, Strategic
Security or the Ethics & Compliance Office.
In all cases, employees will not be subject to retaliation or other adverse
consequence for reporting any potential Code violation or other
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compliance issue.
ADMINISTRATION of THE CODE
REPORTING VIOLATIONS
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ADMINISTRATION of THE CODE
DISCIPLINE
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ADMINISTRATION of THE CODE
INQUIRIES
• Employees must follow the law wherever they are around the world.
• Employees must avoid conflicts of interest. Be aware of appearances.
• Financial and management records–both for internal activities and
external transactions–must be timely and accurate.
• Company assets–including computers, materials and work time–must
not be used for personal benefit.
• Customers and suppliers must be dealt with fairly and at arm’s
length.
• Employees must never attempt to bribe or improperly influence a
government official.
• Employees must safeguard the Company’s nonpublic information.
• Violations of the Code include asking other employees to violate the
Code, not reporting a Code violation or failing to cooperate in a
Code investigation.
• If you have questions about any situation, ask. Always ask.
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QUESTIONS?
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