Coca Cola_COBC_France_English

8/7/2019 Coca Cola_COBC_France_English

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Acting with IntegrityAround the Globe

Code of Business Conduct

for

Coca-Cola France

Refreshment Services

Coca-Cola Midi


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Act with integrity.

Be honest.

Follow the law.

Comply with the Code.

Be accountable.


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Dear Colleague:

Our Company has an enduring reputation or integrity and ethical conduct. Ourname and our products are trusted everywhere around the world. Our businessis built on this trust and this reputation. It inuences how consumers eel aboutour products, how bottlers and customers regard our work, and how shareownersperceive us as an investment. Because our success is so closely related to ourreputation, its up to all o us to keep it strong.

But acting with integrity is about more than our Companys image and reputation,or avoiding legal issues.

Its about sustaining a place where we all are proud to work; its about who we areas a company. Ultimately, its about each o us knowing that we have done the rightthingthat we have acted honestly and treated each other and our customers,

suppliers and consumers airly.

The Code o Business Conduct is our guide to appropriate conduct. Together withother Company guidelines, such as our Workplace Rights Policy, it sets standardsto ensure that we all do the right thing. Keep the Code with you. Reer to it oten.

When you have questions, ask or guidance.

With your help, I am confdent that our Company will continue to do the rightthing, that we will continue to be an outstanding corporate citizen in everycommunity we serve, and our reputation or integrity will endure. Thank you or

joining me in this eort.

Sincerely,

E. Neville IsdellChairman o the Board

COCA-COLA PLAZA

ATLANTA, GEORGIA

July 2008


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Integrity in Relations with Others 29

Relations with Public Authorities ..........29

Anti-Bribery

Political Activity

Trade Restrictions

Relations with Customers, Suppliers

and Consumers .....................................34Relations with Competitors ...................35

Competition Law

Competitive Intelligence

Addenda ...................................... 39

Administration o the Code...................39

Responsibility

Investigation o Potential Code Violations

DecisionsBreach o the Code

Reporting o Code Decisionsand Investigations

Signature and Acknowledgement

Waivers

Glossary ................................................41

Resources ..............................................43

Ethics & Compliance Intranet Site

Policies and Guidelines

Ethics & Compliance Oce

Acting with Integrity Around

the Globe ....................................... 3

What Is Expected o Everyone .................4

What Is Expected o Managers ................5

When Written Approval Is Required ........6

Raising Concerns ......................................8

Integrity in the Company ............. 11

Business and Financial Records ..............11

Company Assets ....................................13

Use o Time, Equipment and Other Assets

Loans

Use o Inormation .................................16

Nonpublic Inormation

Insider Trading

Privacy

Conicts o Interest......................21

Outside Investments ..............................21

Outside Employment, Speechesand Presentations ..................................22

Outside Service as an Ofceror Director .............................................23

Relatives and Friends .............................24

Gits, Meals and Entertainment .............26

Code o Business Conduct

Contents


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Acting with Integrity

4 What Is Expected o Everyone

5 What Is Expected o Managers

6 When Written ApprovalIs Required

8 Raising Concerns


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Acting with Integrity Around the Globe

Integrity is undamental to The Coca-Cola Company.Along with our other values o leadership, passion,

accountability, collaboration, diversity and quality,

it is a pillar o our Maniesto or Growth.

Integrity means doing what is right. By acting with

integrity, we refect positively on the image and reputation

o the Company and its brands in the over 200 countries

where we operate.

We all want to do what is right, or ourselves and or

The Coca-Cola Company. The Code o Business Conduct

will help guide us. The Code denes how employees

should conduct themselves as representatives o

The Coca-Cola Company. The Code addresses our

responsibilities to the Company, to each other, and tocustomers, suppliers, consumers and governments.

We all must ollow the law, act with integrity and honesty

in all matters, and be accountable or our actions.

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4

What Is Expected o Everyone

Comply with the Code and the LawUnderstand the Code. Comply with the Code and the law wherever you are. Usegood judgment and avoid even the appearance o improper behavior.

Consider Your Actions, and Ask or Guidance

I ever in doubt about a course o conduct, ask yoursel:

Is it consistent with the Code?

Is it ethical?

Is it legal?

Will it reect well on me and the Company?

Would I want to read about it in the newspaper?

I the answer is No to any o these questions, dont do it.

I you are still uncertain, ask or guidance. The Code tries to capture many o thesituations that employees will encounter, but cannot address every circumstance.You can seek help rom any o the ollowing:

Your manager or Department Director Your Legal or Finance Director

Your Local Ethics Ocer

The Ethics & Compliance Ofce

Note on the Glossary:

Throughout the Code, certain words and phrases appear in red. Theseterms are dened in the Glossary at the end o this document.


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What Is Expected o Managers

Promote a Culture o Ethics and ComplianceManagers should at all times model appropriate conduct. As a manager, you should:

Ensure that the people you supervise understand their responsibilitiesunder the Code and other Company policies.

Take opportunities to discuss the Code and reinforce the importance ofethics and compliance with employees.

Create an environment where employees feel comfortable raising concerns.

Consider conduct in relation to the Code and other Company policies when

evaluating employees.

Never encourage or direct employees to achieve business results at theexpense o ethical conduct or compliance with the Code or the law.

Always act to stop violations of the Code or the law by thoseyou supervise.

Respond to Questions and Concerns

I approached with a question or concern related to the Code, listen careullyand give the employee your complete attention. Ask or clarication and

additional inormation. Answer any questions i you can, but do not eel thatyou must give an immediate response. Seek help i you need it. I an employeeraises a concern that may require investigation under the Code, contact yourDepartment Director, Legal Director, Finance or Human Resources Director, LocalEthics Ocer or the Ethics & Compliance Oce.

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6

When Written Approval Is Required

Certain actions reerenced in the Codespecically, use o Company assetsoutside o your employment and certain confict o interest situationsrequireprior written approval rom your Local Ethics Ocer. You must renew thisapproval annually i the situation continues. Your Local Ethics Ocer is anemployee at the Group, Business Unit or appropriate Bottling Investments levelwho has been appointed to make these determinations. You can nd your LocalEthics Ocer listed on the Ethics & Compliance intranet site, or you can askyour Human Resources representative to identify your Local Ethics Ofcer.

I you are in a situation where Local Ethics Ocer approval is required, you cancontact your Local Ethics Ocer directly, or you may rst notiy your manageror Department Director, who can help you seek the necessary approval. Anonline tool is available on the Ethics & Compliance intranet site to acilitate theapproval process.

For those who are themselves Local Ethics Ofcers, approval must come fromthe General Counsel and Chief Financial Ofcer of The Coca-Cola Company.Written approvals or executive ocers must come rom the Chie ExecutiveOcer, and written approval or the Chie Executive Ocer must come romthe Board o Directors or its designated committee.


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7

Who Must Follow the Code?This Code of Business Conduct applies to all employees of Coca-Cola France,

Refreshment Services and Coca-Cola Midi. Unless otherwise noted, use of the term

The Coca-Cola Company and the Company throughout this document refers

collectively to all of these entities.

The Code and the Law

Company operations and Company employees are subject to the laws of many countries

and other jurisdictions around the world. Employees are expected to comply with the

Code and the applicable government laws, rules and regulations. If a provision of the

Code conicts with the applicable law, the law controls.

Because The Coca-Cola Company is incorporated in the United States, our employees

around the world often are subject to U.S. laws. Other countries also may apply their

laws outside their borders to Company operations and personnel. If you are uncertain

what laws apply to you, or if you believe there may be a conict between different

applicable laws, consult Company legal counsel before proceeding.


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8

Raising Concerns

We all have an obligation to uphold the ethical standards o The Coca-ColaCompany. I you observe behavior that concerns you, or that may represent a

violation o our Code, raise the issue promptly.Doing so will allow the Company anopportunity to deal with the issue and correct it, ideally beore it becomes a violationo law or a risk to health, security or the Companys reputation.

Resources

You have several options or raising issues and concerns. You can contact any othe ollowing:

Your manager or Department Director

Your Legal or Finance Director

Your Local Ethics Ocer


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No Retaliation

The Company values the help o employees who identiy potential problems that theCompany needs to address. Any retaliation against an employee who raises an issuehonestly is a violation o the Code. That an employee has raised a concern honestlycannot be the basis or any adverse employment action, including separation, demotion,suspension, loss o benets, threats, harassment or discrimination.

I you work with someone who has raised a concern, you should continue to treat theperson with courtesy and respect. I you believe someone has retaliated against you,report the matter to the Ethics & Compliance Oce or your Local Ethics Ocer.

Making False Accusations

The Company will protect any employee who raises a concern honestly, but it is a

violation of the Code to knowingly make a false accusation. Honest reporting does not

mean that you have to be right when you raise a concern; you just have to believe that

the information you are providing is accurate.

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Integrity in the Company

Acting with integrity begins withinThe Coca-Cola Company, and includeshow we deal with Company records,assets and inormation.

11 Business and Financial Records

13 Company Assets

16 Use o Inormation


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Business and Financial Records

Ensure the accuracy o the Company business and nancial records that you

are aware o within the ramework o your proessional duties. These include

not only nancial accounts, but other records such as quality reports, time

records, expense reports and submissions such as benets claim orms and

resumes.

Ensuring accurate and complete business and nancial records is everyonesresponsibility, not just a role or accounting and nance personnel. Accuraterecordkeeping and reporting refects on the Companys reputation and credibility,

and ensures that the Company meets its legal and regulatory obligations.

Always record and classify transactions in the proper accounting period andin the appropriate account and department. Do not delay or accelerate therecording o revenue or expenses to meet budgetary goals.

Estimates and accruals must be supported by appropriate documentationand be based on your best judgment.

Ensure that all reports to regulatory authorities are full, fair, accurate, timelyand understandable.

Never falsify any document.

Do not distort the true nature of any transaction.

Never enable another persons efforts to evade taxes or subvert localcurrency laws. For this reason, payments generally should be made only tothe person or rm that actually provided the goods or services. Paymentsshould be made in the suppliers home country, where it does business,or where the goods were sold or services provided, unless the supplierlegitimately has assigned payment or sold its accounts receivable to another

entity. Exceptions must be approved by the Ethics & Compliance Oce.


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EXAMPLES

Expense Report

Two employees on a business trip eat dinner at a restaurant. One of them

pays for the meal and is reimbursed by the Company for the expense. The

other employee takes a duplicate receipt and submits an expense report for

money he didnt spend. The second employee is disciplined because he

submitted a false expense report.

Revenue Recognition

A sales manager estimated that he would not meet his targets for the month.

To make up the difference, he hired an external warehouse to receive

product and then recorded shipments to the warehouse as sales. The sales

manager falsied nancial records.

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Strive or Accuracy

Employees must strive to be accurate when preparing any information

for the Company, but honest mistakes occasionally will happen. Only

intentional efforts to misrepresent or improperly record transactions, or

otherwise to falsify a Company business record, are Code violations.

Business and Financial Records (continued)


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Company Assets

Protect the Companys assets, and use those assets in the manner intended.

Do not use Company assets or your personal benet or the benet oanyone other than the Company.

Use common sense. For example, the occasional personal phone callor e-mail rom your workplace is acceptable. Excessive personal callsor e-mail is a misuse o assets.

Company policy may allow additional personal use of certain assets, suchas a Company car or wireless communication device. Always check relevant

local policies to ensure that you are using Company assets as intended.

Thet o Company assetswhether physical thet such as unauthorizedremoval o Company product, equipment or inormation, or thet throughembezzlement or intentional misreporting o time or expensescould leadto sanctions, according to specic local regulation and in particular accordingto the Companys mandatory internal rules and regulations (the so-calledrglement intrieur). The Company treats workplace thet o assets belongingto other employees the same way it treats thet o Company assets.

The use o Company assets outside o your Company responsibilitiessuch as using your Company work product in an outside venture, or usingCompany materials or equipment to support personal interestsrequires priorwritten approval rom your Local Ethics Ocer.You must have this approvalrenewed annually i you continue to use the asset outside o work.

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Examples o Company Assets

Company money

Company product

The period of activity during which you are at work belongs to the

Company, as you are at the disposal of the employer

The result of your work

Computer systems and software

Telephones

Wireless communication devices

Photocopiers

Tickets to concerts or sporting events

Company vehicles

Proprietary information

Company trademarks

Company Assets (continued)

Use o Time, Equipment and Other Assets

Do not engage in personal activities during work hours that interfere with orprevent you rom ullling your job responsibilities.

Do not use Company computers and equipment for outside businesses,or or illegal or unethical activities such as gambling, pornography or otheroensive subject matter. Reer to the Acceptable Use Policyor additionalinormation and guidance.

Do not take for yourself any opportunity for nancial gain that you learnabout because o your position at the Company, or through the use oCompany property or inormation.

14

Loans

Loans rom the Company to executive ocers are prohibited. Loans rom theCompany to other ocers and employees must be approved in advance bythe Board o Directors or its designated committee.


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EXAMPLES

A Personal Favor

An employee used Company computers and equipment, as well as time at work, to design

and print wedding invitations and birth announcements as a favor for other employees. The

employee misused Company assets.

Teaching

Q: I am a marketing manager and have volunteered to teach a course on marketing at a local

college. I believe that my students would benet from a discussion of how the Company

developed several marketing campaigns. Can I discuss this work in class?

A: Only with prior approval from your Local Ethics Ofcer. The development of marketing

campaigns is a Company work product and a Company asset. Much of this work may be

proprietary, and may not be appropriate to reveal outside the Company.

Personal Assistance

A manager persistently asked an administrative assistant to take care of the managers personal

business on Company time, such as picking up dry cleaning, balancing a personal checkbook

and shopping for personal gifts. The manager misused the assistants work time, which is a

Company asset.

Ticket Swap

A marketing employee had access to Company tickets to sporting events to be used for

consumer promotions. The employee sent some of the tickets to an acquaintance working at a

hotel chain in exchange for free hotel rooms for the employees personal use. The employee

misused Company assets.

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Use o Inormation

Saeguard the Companysnonpublic inormation, which includeseverything rom contracts and pricing inormation to marketing plans,

technical specications and employee inormation.

Nonpublic Inormation

Do not disclose nonpublic inormation to anyone outside the Company,including to amily and riends, except when disclosure is required orbusiness purposes. Even then, take appropriate steps, such as execution oa condentiality agreement, to prevent misuse o the inormation.

Do not disclose nonpublic inormation to others inside the Company unlessthey have a business reason to know, and communications have beenclassied according to the Information Protection Policy.

Employees are obligated to protect the Companys nonpublic inormationat all times, including outside o the workplace and working hours, and evenater employment ends.

Retain or discard Company records in accordance with the Companysrecord retention policies. Company legal counsel occasionally may issue

notices regarding retention o records in the case o actual or threatenedlitigation or government investigation. Employees must abide by thedirections contained in these notices, as ailure to do so could subject theCompany and employees to serious legal risks.

Reer to the Information Protection Policyor additional guidance and tipsor saeguarding inormation.

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What Is Nonpublic Inormation?

It is any information that the Company

has not disclosed or made generally

available to the public. Examples include

information related to:

Employees

Inventions

Contracts

Strategic and business plans

Major management changes

New product launches

Mergers and acquisitions

Technical specications

Pricing

Proposals

Financial data

Product costs

EXAMPLES

Look What I Have

Q: I have just received by accident an

e-mail with a le containing the

salaries of several other employees.

May I share it with other people

at work?

A: No. You and your friends at work

have no business reason to have

this information. You should delete

the e-mail and bring the error to the

senders attention. Disclosing the

information to other employees is a

Code violation.

A New Formula

A Company scientist was excited

about the upcoming launch of a new

product that the scientist had worked

on, and shared details about the

product with family and friends.

The scientist improperly disclosed

nonpublic information.

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Use o Inormation (continued)

Insider TradingTrading in stocks or securities based on material nonpublic inormation, orproviding material nonpublic inormation to others so that they may trade,is illegal and may result in prosecution. Reer to the Insider Trading Policyor additional inormation.

EXAMPLE

A Small Company

Q: I have learned that the Company is considering the acquisition of a

small, publicly-traded beverage company. May I acquire the stock

of this company in anticipation of the acquisition?

A: No. Trading on material nonpublic information is illegal and a

violation of the Code, whether you are trading in the stock of

The Coca-Cola Company or the stock of another company.

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Privacy

The Company respects the privacy o all its employees, business partnersand consumers. We must handle personal data responsibly and incompliance with all applicable privacy laws. Employees who handle thepersonal data o others must:

Act in accordance with applicable law;

Act in accordance with any relevant contractual obligations;

Collect, use and process such information only for legitimatebusiness purposes;

Limit access to the information to those who have a legitimate

business purpose for seeing the information; and

Take care to prevent unauthorized disclosure.

Reer to the Privacy Policyor additional guidance on the handling opersonal data and a description o protected inormation.

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Conicts o Interest

This section o the Code provides rulesor some common conict o interestsituations. The Code cannot address everypotential conict o interest, so use yourconscience and common sense. When youare unsure, seek guidance.

21 Outside Investments

22 Outside Employment, Speechesand Presentations

23 Outside Service as an Ofceror Director

24 Relatives and Friends

26 Gits, Meals and Entertainment


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Act in the best interest o The Coca-Cola Company

while perorming your job or the Company. A conficto interest arises when your personal activities and

relationships interere, or appear to interere, with

your ability to act in the best interest o the Company.

Take particular care i you are responsible or selectingor dealing with a supplier on behal o the Company.Your personal interests and relationships must notinterere, or appear to interere, with your ability to makedecisions in the best interest o the Company. When

selecting suppliers, always ollow applicable Companyprocurement guidelines.

Outside Investments

Avoid investments that could aect, or appear to aect,your decision making on behal o the Company. Specicguidelines apply to ownership o stock o a customer,supplier or competitor o The Coca-Cola Company(Note: Franchise bottlers of Company-trademarked

products are customers.):

If you have discretionary authority in dealing witha company as part o your job with The Coca-ColaCompany, you may not have any nancial interestin that company without prior written approval romyour Local Ethics Ocer.

You may own more than 1% of the stock of anycustomer, supplier or competitor only with the priorwritten approval o your Local Ethics Ocer.

You must renew Local Ethics Ofcer approvalannually i you continue to own the stock.

Conicts o Interest

21

Determining Conictso Interest

In any potential conict

of interest situation, ask

yourself:

Could my personal interests

interfere with those of the

Company?

Might it appear that wayto others, either inside or

outside of the Company?

When unsure, seek guidance.

Mutual Funds

These restrictions on

outside investments do

not apply to mutual funds

or similar investments in

which the employee does

not have direct control over

the particular companies

included in the fund.


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Conicts o Interest

22

Outside Employment, Speeches and Presentations

In general, you may be employed outside o The Coca-Cola Company, as long asyour outside employment does not interere with your ability to do your job withthe Company. Reer also to local employment policies and contracts, which mayimpose additional restrictions.

You may not be employed by, or otherwise provide services or or receive paymentrom, any customer, supplier or competitor o the Company without prior writtenapproval rom your Local Ethics Ocer.You must renew this approval annually.

You must have prior written approval rom your Local Ethics Ocer beoreaccepting reimbursement or expenses, or any other payment, or speeches or

presentations outside The Coca-Cola Company, i:

You are giving the speech or presentation as part of your job withthe Company;

The speech or presentation describes your work with the Company; or

You are formally identied at the speech or presentation as an employeeo the Company.


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23

Serving as a Director at the Request o The Coca-Cola Company

If you serve as a director of another company, such as a bottler, at the request of The

Coca-Cola Company, you may own up to 1% of the stock of that company without

Local Ethics Ofcer approval if stock ownership is required as a condition of service

as a director. If you serve as a director of another company at the request of The

Coca-Cola Company and receive a salary for your service as a director, you may

retain the salary if the other company is publicly traded, but must remit the salary to

The Coca-Cola Company if the other company is privately held.

Outside Service as an Ofcer or Director

In general, you may serve as an ocer or member o the board o directors oanother or-prot business only with prior written approval o your Local EthicsOcer. You must renew this approval annually.

Local Ethics Ocer approval is not required or:

Service as an ofcer or director of another company, such as a bottler, at therequest o The Coca-Cola Company (other approvals may be necessary in sucha case, however, per the Delegation of Authority); or

Service as an ofcer or director of a charitable or other non-prot institution

or trade organization, or or service as an ocer or director o a amily-ownedbusiness, unless the business is a customer, supplier or competitor o TheCoca-Cola Company.

Reer to the Director Appointee Guidelines or more inormation on the obligationso those serving as ocers or directors o other or-prot businesses.


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Conicts o Interest

24

Relatives and Friends

Many employees have relatives who are employed byor invest in customers or suppliers o The Coca-ColaCompany. These nancial interests do not create aconfict under the Code unless:

You have discretionary authority in dealing withany o these companies as part o your job withThe Coca-Cola Company; or

Your relative deals with The Coca-Cola Companyon behal o the other company.

In either o these situations, you must have writtenapproval rom your Local Ethics Ocer, and you mustrenew this approval annually.

You may have riends who are employed by, or haveownership interests in, customers or suppliers o TheCoca-Cola Company. I you deal with such a customeror supplier, take care to ensure that your riendshipdoes not aect, or appear to aect, your ability to actin the best interest o the Company. I you are uncertainwhether your riendship may create an issue, consultyour manager, Local Ethics Ocer or the Ethics &Compliance Oce.

In addition, personal relationships at work must notinfuence your ability to act in the best interest othe Company, and must not aect any employmentrelationship. Employment-related decisions shouldbe based on qualications, perormance, skillsand experience.

Who Is My RelativeUnder the Code?

A spouse, parent, sibling,

grandparent, child, grandchild,

mother- or father-in-law, or

same or opposite sex domestic

partner are all considered

relatives. Also included is

any family member who lives

with you or who is otherwise

nancially dependent on

you, or on whom you are

nancially dependent. Even

when dealing with family

members beyond this

denition, take care to ensure

that your relationship does

not interfere, or appear to

interfere, with your ability to

act in the best interest of The

Coca-Cola Company.


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EXAMPLES

Supplier Selection

Q: It is my job to select a supplier for the Company. One of the

suppliers being considered is a company owned by my spouse.

Do I need to take any precautions?

A: In this situation, your interest in your spouses business conicts

or at least appears to conictwith your responsibility to select

the best supplier for The Coca-Cola Company. You should consult

your manager and Local Ethics Ofcer. The best course of action iseither for you not to be involved in the selection process, or for your

spouses business to be eliminated from consideration.

My Brother

Q: My brother works for Company X, which is one of our customers,

but he has no dealings with The Coca-Cola Company. I work in

Sales, but have had no contact with Company X. I now have been

asked to manage the Company X account. What should I do?

A: Tell your manager about your brothers employment, because in

your new job you will have discretionary authority in dealing

with Company X. If your manager still wants you to work on

the Company X account, seek written approval from your Local

Ethics Ofcer.

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Conicts o Interest

26

Gits, Meals and Entertainment

Do not accept gits, meals or entertainment, or any other avor, rom customers or suppliersi doing so might compromise, or appear to compromise, your ability to make objectivebusiness decisions in the best interest o The Coca-Cola Company.

Acceptance o gits, meals or entertainment that exceeds the ollowing limitations must

be approved in writing by yourLocal Ethics Ocer.

Gits

Do not accept gifts in exchange for doing, or promising to do, anything for a customeror supplier.

Do not ask for gifts from a customer or supplier. Do not accept gifts of cash or cash equivalents, such as gift cards.

Do not accept gifts of more than modest value. Examples of acceptable gifts include alogo pen or t-shirt, or a small git basket at holiday time.

Gifts of symbolic value, such as trophies and statues that are inscribed in recognition of abusiness relationship, may be accepted.

Gifts or discounts offered to a large group of employees as part of an agreementbetween the Company and a customer or supplier may be accepted and used asintended by the customer or supplier.

Meals and Entertainment

Do not accept meals or entertainment in exchange for doing, or promising to do,anything or a customer or supplier.

Do not ask for meals or entertainment from a customer or supplier.

You may accept occasional meals and entertainment from customers and suppliers ifthe event is attended by the customer or supplier, and the costs involved are in linewith local custom for business-related meals and entertainment. For example, ordinarybusiness meals and attendance at local sporting events generally are acceptable.

EXAMPLE

Special Discounts

An employee who was managing the Companys relationship with a travel agency accepted from

the agency discounted rates for personal travel that were not available to other employees. The

employee violated the Code provisions on conicts of interest by accepting this personal benet.


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Travel and Premium Events

I you are invited by a customer or supplier to an event involving out-o-town travel orovernight stay, or to a premium event such as the Olympics, World Cup, Super Bowl orAcademy Awards, consult your manager to determine i there is adequate business rationaleor your attendance. I there is, The Coca-Cola Company should pay or your travel andattendance at the event.

Reusing Gits, Meals and Entertainment

I you are oered a git, meal or entertainment that exceeds the limits noted above, politelydecline and explain the Companys rules. I returning a git would oend the giver, or thecircumstances under which it was given preclude its return, you may accept the git, but shouldnotiy your Local Ethics Ocer. The Local Ethics Ocer will work with you either to donate theitem to charity, or to distribute or rafe the item among a large group o employees.

Gits, Meals and Entertainment or Customers and Suppliers

Gits, meals and entertainment or customers and suppliers must support the legitimatebusiness interests o the Company and should be reasonable and appropriate under thecircumstances. Always be sensitive to our customers and suppliers own rules on receivinggits, meals and entertainment.

Do not give Company stock as a git on behal o the Company under any circumstances.

Tickets and Housing or Personal Use

Tickets to sporting events or other entertainment venues that are offered by a customer or

supplier for your personal use, without attendance by the customer or supplier, are considered

gifts. They should not be accepted, unless offered to a large group of employees as part of an

agreement between the Company and the customer or supplier. The same is true of personal use

of a condominium or vacation home, or personal travel on a private aircraft.

Local RulesBusiness Unit and Consolidated Bottling Operation management, in consultation with the Local

Ethics Ofcer, may adopt local rules setting more specic limits on the acceptance of gifts, meals

or entertainment, such as particular monetary thresholds. All local rules will be reported to the

Ethics & Compliance Ofce, and will be posted on the Ethics & Compliance intranet site.

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Integrity in Relations with Others

The Coca-Cola Companys externalrelationships are critical to our success.We must deal airly and lawully witheveryone we encounter.

29 Relations with Public Authorities

34 Relations with Customers,Suppliers and Consumers

35 Relations with Competitors


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Relations with Public AuthoritiesThe global nature o our business oten requires

that we interact with ocials o various governments

around the world. Transactions with governments are

covered by special legal rules, and are not the same

as conducting business with private parties. Consult

Company legal counsel to be certain that you are

aware o, understand and abide by these rules.

In general, do not oer anything to an agent o public

servicedirectly or indirectlyin return or avorabletreatment.You must obtain prior approval romCompany legal counsel beore providing anything o

value to an agent o public service. Ensure that anysuch payments are properly recorded in the appropriateCompany account.

Anti-Bribery

Many countries, including the United States, havepassed legislation criminalizing bribery o agents o

public service. The sanctions or violating these laws canbe severe, including signicant individual and corporatenes, and even imprisonment.

Bribes Are Prohibited

A bribe is giving or oering to give anything o value toan agent o public service to infuence a discretionarydecision. Examples o bribes include payment to anagent o public service to encourage a decision to

award or continue business relations, to infuence theoutcome o a government audit or inspection, or toinfuence tax or other legislation. Other payments toagents o public service also may constitute bribes insome jurisdictions. Consult Company legal counselregarding local anti-bribery laws.

29

Anything o Value

This phrase literally meansanything that might have

value to an agent of public

service, including cash, gifts,

meals, entertainment, business

opportunities, Company

product, offers of employment

and more. There is no monetary

threshold; any amount could be

construed as a bribe.

The U.S. ForeignCorrupt Practices Act

Because The Coca-Cola

Company is incorporated in the

United States, the U.S. Foreign

Corrupt Practices Act, which

prohibits bribes to ofcials of

non-U.S. governments, applies

to all employees around the

world. Consult Company legal

counsel about additional local

laws that may be applicable.


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30

Relations with Public AuthoritiesAnti-Bribery (continued)

Certain Payments May Be Acceptable

A payment to an agent o public service may be allowableunder certain narrow exceptions. Obtain approval romCompany legal counsel beore making any such payment. Insome circumstances, legal counsel may be able to provideblanket approvals or certain well-dened interactions withagents o public service. In addition, employees shouldconsult Public Aairs & Communication personnel responsible

or relations with authorities to ensure that they are acting inaccordance with Company policy and guidelines regardingrelations with these authorities.

Hiring Ofcials

The Company may hire ocials to perorm services that havea legitimate business purpose, and that do not confict withthe ocials duties, such as hiring an o-duty police ocer toprovide security at a Company event. All such hiring decisionsmust be approved in advance by Company legal counsel.

Improper Payments by Third Parties

The Company may be held liable or bribes paid by a third-party agent or consultant acting on the Companys behal.Take particular care when evaluating a prospective thirdparty who might interact with the authorities on behal othe Company. You must not engage a third-party agent orconsultant i there is reason to believe that the agent orconsultant may attempt to bribe an ocial. Also, ensure thatall agents and consultants agree to abide by the Code of

Business Conduct for Suppliers to The Coca-Cola Company,which contains anti-bribery provisions.

Reer to the Anti-Bribery Policyor more specic guidanceabout payments to agents o public service and engagingthird parties.

Who Are Agentso Public Service?

Employees of any

public organization or

government-controlled

entity anywhere in

the world

Political parties and

party ofcials

Candidates for

political ofce

Employees of

public international

organizations, such as

the United Nations

It is your responsibility

to understand whether

someone you deal with

is an ofcial. When in

doubt, consult Company

legal counsel.


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EXAMPLES

A Sign o Good Will

Q: A public health inspector has arrived at a Company manufacturing plant. May I present a

case of product to the inspector as a sign of good will?

A: No. You should never give anything of value to an ofcial without prior approval fromCompany legal counsel. Legal counsel would advise you that giving the product, or

anything else of value, to the health inspector under these circumstances could be perceived

as a bribe intended to inuence the inspectors review of the facility.

Increase in Commission

Q: A consultant the Company uses to assist with government relations recently asked us for a

large increase in commission. I suspect the consultant may intend to pass this money on to

local ofcials. What should I do?

A: Report your suspicions to Company legal counsel at once. No such payments should bemade to the consultant until the Company has investigated your concerns.

Facilitating PaymentsThe U.S. Foreign Corrupt Practices Act allows companies to make facilitating payments, which

are small sums paid to non-U.S. ofcials to expedite or facilitate non-discretionary actions

or services, such as obtaining an ordinary license or phone service. At times, such payments

may be necessary to obtain these services. Nonetheless, the Company discourages facilitating

payments. Moreover, such payments may be illegal under local law. Always consult Company

legal counsel regarding the acceptability of any facilitating payment under local law, and ensure

that any facilitating payment is recorded properly in the Company accounts.

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32

Relations with Public Authorities (continued)

Political Activity

The Coca-Cola Company encourages personalparticipation in the political process in a mannerconsistent with all relevant laws and Companyguidelines.

Personal Political Activity

The Company will not reimburse employees forpersonal political activity.

Your job will not be affected by your personalpolitical views or your choice in politicalcontributions.

Do not use the Companys reputation or assets,including your time at work, to urther your ownpolitical activities or interests.

A Political Friend

Q: My friend is running forpolitical ofce, and I

would like to help with the

campaign. Is this allowed?

A: Yes. Your personal political

activity is your business.

Just make sure that you do

not use Company resources,

including Company time,

e-mail or the Company

name, to advance the

campaign.


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33

Trade Restrictionsand Boycotts

Detailed information on U.S.

trade restrictions that may be

in effect at any given time

are posted on the Ethics &

Compliance intranet site. For

any questions about yourobligations in this area, including

trade restrictions that may be

imposed by governments other

than the U.S., contact Company

legal counsel.

Trade Restrictions

The Company must comply with all applicable traderestrictions and boycotts imposed by the U.S. or Frenchgovernment. Such restrictions prohibit the Companyrom engaging in certain business activities in speciedcountries, and with specied individuals and entities.These restrictions include, or example, prohibitionson interaction with identied terrorist organizationsor narcotics trackers. Sanctions or non-compliance

can be severe, including nes and imprisonment orresponsible individuals, and the Company may beprohibited rom urther participation in certain trade.

The Company also must abide by U.S. and French anti-boycott laws that prohibit companies rom participatingin any international boycott not sanctioned by the U.S.or French government.


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34

Relations with Customers, Suppliers and Consumers

The Company values its partnerships with customers, suppliersandconsumers. Treat these partners in the same manner we expect to

be treated.

Always deal airly with customers, suppliers and consumers, treatingthem honestly and with respect:

Do not engage in unfair, deceptive or misleading practices.

Always present Company products in an honest andorthright manner.

We expect that our suppliers will take no action contrary to the principleso our Code. Accordingly, the owner o each supplier relationship shouldensure that adherence to the Code of Business Conduct for Suppliers toThe Coca-Cola Companyis a condition o the supplier agreement.

EXAMPLES

A Lengthy Report

A customer asked a sales executive to prepare a lengthy and detailed

report, including product information that would take much effort to

acquire. The sales executive populated the report with false data, in

order to get something back to the customer quickly. These actions were

dishonest and constituted unfair treatment of a customer.A Customer Meeting

Q: I am attending a customer meeting with another Company employee,

and the other employee makes what I believe to be an intentionally

false statement about our capabilities. What should I do?

A: Correct the error during the meeting if possible. If that is not

possible, raise the issue with the employee, your manager, or other

responsible Company personnel after the meeting, and ensure that

the Company corrects any customer misperception. If you are correct

that the other employee intentionally lied to a customer, the employee

violated the Code.


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35

Relations with Competitors

Take care in dealing with competitors, and gathering inormation aboutcompetitors. Various laws govern these sensitive relationships.

Competition Law

The Coca-Cola Company competes airly, and complies with all applicablecompetition laws around the world. These laws oten are complex, and varyconsiderably rom country to countryboth in the scope o their coverageand their geographic reach. Conduct permissible in one country may beunlawul in another. Penalties or violation can be severe.

Accordingly, the Company has adopted Competition Law Guidelinesapplicable in various parts o the world. Employees should consultCompany legal counsel and these Guidelines to understand the particularcompetition laws and policies applicable to them.


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36

Relations with Competitors (continued)

Competitive Intelligence

Employees are encouraged to collect, share and use inormation about ourcompetitors, but to do so only in a legal and ethical manner. Just as the Companyvalues and protects its own nonpublic inormation, we respect the nonpublicinormation o other companies.

Acceptable Intelligence Gathering

It is acceptable to collect competitive intelligence through publicly availableinformation or ethical inquiries. For example, you may gather and use informationrom sources such as:

Publicly available lings with government agencies

Public speeches of company executives

Annual reports

News and trade journal articles and publications

You also may ask third parties about our competitors, or accept competitiveintelligence oered by a third party, as long as there is no reason to believe that

the third party is under a contractual or legal obligation not to reveal such inormation.

Prohibited Activities

The ollowing basic restrictions apply to our ability to gather competitive intelligence:

Do not engage in any illegal or illicit activity to obtain competitive information.This includes thet, trespassing, eavesdropping, wiretapping, computer hacking,invasion o privacy, bribery, misrepresentation, coercion, espionage or threats.

Do not accept, disclose or use competitive information that you know or have

reason to believe was disclosed to you in breach o a condentiality agreementbetween a third party and one o our competitors.

Do not disclose or use competitive information that is, or you believe shouldhave been, marked proprietary or condential without consulting Companylegal counsel.

Reer to the Competitive Intelligence Policyor more detailed guidance.


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37

EXAMPLES

A Former Employer

Q: We have just hired an employee who worked very recently for one

of our competitors. May I ask the employee for information about

our competitor?

A: Consult Company legal counsel before asking the employee

anything about a former employers business. Never ask a former

employee of a competitor about any information that the person

is under a legal obligation not to reveal. This would include anyof our competitors trade secrets, and probably other condential

information as well.

A Competitors Proposal

Q: As I prepare to propose a deal to a customer, the customer offers

me a presentation containing our competitors proposal so that we

can respond. May I accept it?

A: Perhaps. First, ask whether the customer is prohibited from sharing

this information by a condentiality agreement. If the customerconrms that it is under no obligation to protect the information,

you may accept the information. Once you have the presentation,

if it is marked condential or proprietary, or you believe it

should have been, consult Company legal counsel before disclosing

or using the information.


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Addenda

39 Administration o the Code

41 Glossary

43 Resources


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The Code o Business Conduct is designed to ensure consistency in how employees

conduct themselves within the Company, and in their dealings outside o theCompany. The procedures or handling potential violations o the Code have been

developed to ensure consistency in the process across the organization.

No set o rules can cover all circumstances. These guidelines may be varied as necessaryto conorm to local law or contract.

Responsibility

The responsibility or administering the Code rests with the Ethics & ComplianceCommittee, with oversight by the Chief Financial Ofcer, General Counsel and Audit

Committee o the Board o Directors. The Ethics & Compliance Committee is comprisedo senior leaders representing corporate governance unctions as well as operations.

Investigation o Potential Code Violations

The Company takes all reports o potential Code violations seriously and is committed tocondentiality and a full investigation of all allegations. The Companys Audit, Finance,Legal and Strategic Security personnel may conduct or manage Code investigations.Employees who are being investigated or a potential Code violation will have anopportunity to be heard prior to any nal determination. The Company ollows localgrievance procedures in locations where such procedures apply.

Decisions

The Ethics & Compliance Committee issues recommendations about Code violationsand local Management may take disciplinary measures based on local regulationimplemented to that end and, in particular based on the Companys mandatory internalrules and regulations (the so-called rglement intrieur).

Administration o the Code

39


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Administration o the Code

40

Breach o the Code

Regarding breach o the Code, the Code reers or disciplinary measures to thelocal regulation and, in particular, to the Companys mandatory internal rules andregulations (the so-called rglement intrieur). In the light o the seriousness othe breach o the Code and in accordance with local employment law, the Companymay take all measures that appear to be necessary.

A notation o the nal decision, and a copy o any document concerning a potentialmeasure, will be placed in the employees personnel le as part o the employeespermanent record under the conditions and limits set by the local regulation.

Reporting o Code Decisions and Investigations

The Ethics & Compliance Oce periodically reports all pending Code investigationsand nal Code decisions to senior management o the Company and to the AuditCommittee o the Board o Directors. The Ethics & Compliance Oce also posts arepresentative sample o Code violations, with personal identiying characteristicsremoved, on the Ethics & Compliance intranet site or the education o employees.

Signature and Acknowledgement

All new employees must sign an acknowledgement orm conrming that theyhave read the Code o Business Conduct and agree to abide by its provisions. All

employees will be required to make similar acknowledgements on a periodic basis.Failure to read the Code or sign the acknowledgement form does not excuse anemployee rom compliance with the Code.

Waivers

Waivers o any provisions o this Code or ocers o the Company must beapproved by the Board o Directors or its designated committee and will bedisclosed promptly to the extent required by law.


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41

Glossary

The Glossary defnes some o the terms used in the Code o Business Conduct. Ithese defnitions or other words or phrases used in the Code are still unclear, please

consult your Local Ethics Ofcer or the Ethics & Compliance Ofce.

Agents o Public Service Employees o any government anywhere in the world, evenlow-ranking employees or employees o government-controlled entities. The termalso includes political parties and party ocials, candidates or political oce, andemployees o public international organizations, such as the United Nations.

Anything o value Anything that might have value to a government ocial, includingcash, gits, meals, entertainment, business opportunities, Company product, oers oemployment and more. There is no monetary threshold; any amount could be construedas a bribe.

Bribe Giving or oering to give anything o value to a government ocial toinfuence a discretionary decision. Local law may impose a broader denition in somejurisdictions.

Company assets Includes, among other things, the Companys money or product,the period o activity during which the employees are at the disposal o the employerand the result o their work, computer systems and sotware, telephones, wirelesscommunication devices, photocopiers, tickets to concerts and sporting events,Company vehicles, proprietary inormation and Company trademarks.

Competitive intelligence Inormation about our competitors.

Competitor For the purposes of the Conicts of Interest and Competitive Intelligenceprovisions only, competitor means any business or entity, other than The Coca-ColaCompany or one o its subsidiaries or bottlers, that manuactures or sells wholesaleany non-alcoholic beverage or beverage concentrate, or any business or entity that isactively considering such activity.

Customer Any business or entity to which The Coca-Cola Company or one o itssubsidiaries or bottlers sells concentrate or nished product bearing a trademark o

The Coca-Cola Company. Franchise bottlers of Company-trademarked products areconsidered customers.

Discretionary authority in dealing with a company The authority to infuencethe Companys selection o a supplier or to infuence signicantly the Companysrelationship with an existing customer or supplier.


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Glossary

42

Ethics & Compliance Committee A committee comprised o senior leadersrepresenting corporate governance unctions and operations, responsible or

administration o the Code o Business Conduct.

Facilitating payments Small payments to government ocials made to expediteor acilitate non-discretionary actions or services, such as obtaining an ordinarylicense or phone service.

Local Ethics Ofcer An employee at the Group, Business Unit or appropriateBottling Investments level, appointed jointly by the Ethics & Compliance Committeeand the relevant business leader, empowered to provide written approvals oractions under the Code in the areas o Conficts o Interest and Company Assets. A

list o Local Ethics Ocers can be ound on the Ethics & Compliance intranet site.Material nonpublic inormation Nonpublic inormation that would be reasonablylikely to aect an investors decision to buy, sell or hold the securities o a company.Examples include a signicant merger or acquisition involving the Company, theCompanys earnings or volume results beore they are announced, and a changein control o senior management o the Company. Many other matters may bematerial. I you are uncertain whether nonpublic inormation o which you are awareis material, consult Company legal counsel.

Nonpublic inormation Any inormation that the Company has not disclosed or

made generally available to the public, which may include inormation related toemployees, inventions, contracts, strategic and business plans, major managementchanges, new product launches, mergers and acquisitions, technical specications,pricing, proposals, nancial data and product costs.

Relative A spouse, parent, sibling, grandparent, child, grandchild, mother- orather-in-law, or same or opposite sex domestic partner, as well as any other amilymember who lives with you or who is otherwise nancially dependent on you, or onwhom you are nancially dependent.

Supplier Any vendor o product or services to the Company, including consultants,

contractors and agents. The denition also includes any supplier that the Companyis actively considering using, even i no business ultimately is awarded.


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43

Resources

Ethics & Compliance Intranet Site

The Company maintains an Ethics & Compliance intranet site with additional inormationabout the Code, other policies and guidelines, training, and other ethics and compliancematters. I you do not have access to the Company intranet, ask your manager,Department Director, Legal Director, Finance or Human Resources Director, Local EthicsOcer, or contact the Ethics & Compliance Oce or more inormation.

Policies and Guidelines

The Code o Business Conduct does not address all workplace conduct. The Companymaintains additional policies and guidelines that may provide urther guidance on mattersin the Code or address conduct not covered by the Code. Here is a list of many of these

policies. All o these policies are available on the Ethics & Compliance intranet site.

Acceptable Use Policy

Anti-Bribery Policy

Code of Business Conduct for Suppliers to The Coca-Cola Company

Competition Law Guidelines

Competitive Intelligence Policy

Delegation of Authority

Director Appointee Guidelines Information Protection Policy

Insider Trading Policy

Privacy Policy

Travel & Entertainment Policy

Workplace Rights Policy


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Ethics &Compliance

Resources

44

Ethics & Compliance Ofce

The Ethics & Compliance Oce is available to answer any questions about theCode or Company compliance policies, or to discuss any concerns you may haveabout your obligations resulting rom this Code.

To contact the Ethics & Compliance Oce:

Call +1-404-676-5579

E-mail [email protected] Fax to +1-404-598-5579

Mail to: Ethics & Compliance OfceThe Coca-Cola CompanyOne Coca-Cola PlazaAtlanta, GA 30313 USA

To contact your Local Ethics Ocer:

You can nd your Local Ethics Ocer listed on the Ethics & Compliance intranet

site, or you can ask your Human Resources representative to identify your LocalEthics Ocer.

2008 The Coca-Cola CompanyE Printed on 100% post-consumer waste recycled paper.


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The Coca-Cola Company reservesthe right to amend, alter orterminate this Code at any time

and or any reason, subject to theapplication o the local procedure.


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