Policies

Our attitude to corruption is clear: zero tolerance.

At Coca‑Cola HBC, we pride ourselves on being fair, open and honest. Whether we’re dealing with our suppliers, customers or governments, we follow a strict code of integrity, respect, and transparency.

Inappropriate business activities are by no means anything new, nor are they unique to any one business environment. We at Coca‑Cola HBC recognise the risk of bribes – the request or receipt of anything of value or advantage, whether directly or indirectly, to any person, in order to encourage that person or any other to perform a function or activity improperly.

Our zero tolerance policy on corruption marks our company as a model for ethical behaviour in both business and personal life.

We expect our employees to show complete and absolute respect to these standards. Violations of our anti-bribery policy – regardless of location, role or level of seniority – is dealt with the utmost seriousness and to the full extent of our legal capacity.

Our anti-bribery policy and compliance handbook provides our people with the essential knowledge and tools to detect and prevent bribery and corruption. It also shows them where they can find more information.

Our climate change policy statement is set out below. It is owned and endorsed by the Corporate Social Responsibility Committee of the Board of Directors; responsibility for the successful implementation of this programme belongs with every Coca‑Cola Hellenic employee at each level and function in the organisation.

Coca‑Cola Hellenic strives to limit its impacts on climate change and to carry out all its business activities in a sustainable manner. We believe that industry has a key role to play in finding sustainable solutions to today’s climate challenges.

The direct greenhouse gas emissions from Coca‑Cola Hellenic operations result mostly from the use of energy in bottling plants and fleet. Indirect emissions stem from raw materials (ingredients and packaging) and cold drink equipment.

In accordance with our environmental policy, we will:

• Reduce the energy used in our operations
• Implement alternative or renewable energy technologies such as combined heat and power plants and solar panels, where practical to provide additional sustainable energy for our facilities
• Engage with stakeholders to combat climate change
• Work with suppliers to reduce the carbon embedded in packaging materials, the carbon footprint of our cold drink equipment and ingredient suppliers to minimise their carbon impacts
• Set targets to reduce our supply chain carbon emissions
• Report our greenhouse gas emissions, targets, results and activities openly and in accordance with the Greenhouse Gas Protocol

The Code of Business Conduct is Coca‑Cola HBC’s essential over-arching policy. All our employees are responsible for upholding our commitment to the highest standards of business conduct.

Across the board, Coca‑Cola HBC’s employees are committed to the highest standards of business conduct. Our Code of Business Conduct is the foundation of how we safeguard compliance across our company.

The Code enables managers to promote a culture of ethics, based on compliance and leadership by example. They can respond quickly and clearly to employees’ concerns, drawing on the wealth of experience within the company.

We encourage our employees to speak up and look for guidance where needed, and to make sure that they have all necessary approvals for key decisions. This minimises the risk of deviation from or violation of the guidelines set out in the Code of Business Conduct.

We also lend our voice to matters which affect our communities – standing ready to bring our expertise and leadership to resolving matters across suppliers, customers, consumers and competitors. This uncompromising pledge to integrity is one of the many ways in which we drive perfection.

By communicating our Code of Business Conduct effectively, we guarantee an efficient and equitable workplace and a competent and considerate workforce.

All resources are easily accessible, not only to our team but to anyone who would like to find out how they can become effective stewards of responsible business practice.

To whom does the Code of Business Conduct apply?

The Code of Business Conduct applies to everyone working for the company worldwide, regardless of location, role or level of seniority. This includes all employees, managers, Operating Committee members and company directors.

We also expect temporary and contract employees, consultants, agents and any other third party who acts in our name to follow the principles of the Code. Every subsidiary and joint venture which the company controls must adopt and comply with the Code. Where we participate in but do not control a joint venture relationship, we will encourage our partners to meet the requirements of the Code in both the joint venture and their own operations.

Our environmental policy is set out below. The responsibility for overseeing the implementation of this policy lies with the Corporate Social Responsibility Committee of the Board of Directors.

Coca‑Cola Hellenic is committed to conducting all its business activities responsibly with due regard to environmental impact and sustainable performance. The Company believes that the environment is everybody’s responsibility and all employees are accountable for environmental performance.

Coca‑Cola Hellenic seeks to achieve steady improvement in meeting its environmental standards while working to minimize any negative impact on the local and global environment as the Company grows its business.

To reach these targets, Coca‑Cola Hellenic:

• Conducts operations in compliance with all applicable laws and regulations and applies its high internal environmental standards
• Implements and certifies the internationally recognised environmental management system, ISO 14001, in all of its operations to ensure accountability and continuous improvement
• Includes environmental strategies and objectives in its business planning process to ensure that management of environmental impact remains an integral part of its operations
• Identifies environmental aspects, sets environmental goals, monitors results and audits processes in order to assess its performance against internal and external environmental standards
• Identifies and implements ways to improve the efficiency with which the Company uses materials and resources, prevents pollution, minimises emissions, and recycles waste
• Commits to conserve watersheds by saving water and treating wastewater
• Commits to protecting the climate by reducing energy use and coolant emissions
• Plays a leading role within the beverage industry in promoting sustainable packaging by light weighting, recycling beverage containers and using recycled content in its packages
• Encourages and equips its employees to identify and act upon opportunities to improve environmental performance and waste management in the areas where they work
• Partners with stakeholders in seeking and developing solutions to those environmental problems on which the Company can make an effective and lasting contribution
• Communicates its environmental requirements and performance to stakeholders

Our genetically modified organism position statement is set out below.

Coca‑Cola Hellenic does not use ingredients that are genetically modified or derived from genetically modified organisms in any of the 28 countries in which it operates. Given this situation, and as there is no requirement either regulatory or commercial to label the absence of such ingredients, the company does not do so.

It is the Company’s position that it supports the responsible use of modern biotechnology within the framework of effective regulatory control and the provision of adequate information about its use. The use of such technology to improve food crops can bring important benefits to mankind, and individual applications should be judged on their merits.

Coca‑Cola Hellenic acknowledge the fact that the public view of the use of genetically modified ingredients in foods is still evolving, and notes that the debate and public acceptance of these is at different stages in countries in Europe and the rest of the world.

As the public discussions continue, the Company is monitoring the situation and is prepared to review and modify its policy in light of any developments that may occur.

Coca‑Cola Hellenic encourages reasonable and scientifically sound solutions and supports and assists suppliers in adhering to the same standards.

Our health & wellness policy is set out below. It is owned and endorsed by the Corporate Social Responsibility Committee of the Board of Directors; responsibility for the successful implementation of this programme belongs with every Coca‑Cola Hellenic employee at each level and function in the organisation.

Coca‑Cola Hellenic cares about the health of its consumers. The Company offers an increasingly wide range of drinks, from traditional sparkling beverages, including regular and low calorie, to juices, waters and other still drinks. All of these can be enjoyed as part of a healthy diet.

Our range of drinks is suitable for a wide variety of drinking occasions from morning till night. In addition, the Company supports activities promoting fitness and physical exercise.

Coca‑Cola Hellenic is committed to satisfying consumer demand for:

A broad choice of beverages

• We will continue to expand our range to include traditional sparkling beverages, juices, waters, teas, coffees and functional beverages that are improved, enhanced, and fortified for better health
• We will continue to promote low and no calorie beverages. The average calorie content of the Company’s beverages has declined by nearly 20 percent since 2001
• We will provide an appropriate choice of portion sizes so as to help consumers manage their intake of calories

Increased consumer information

Coca‑Cola Hellenic is committed to responsible communication about its products and to promoting clear, user-friendly front-of-pack nutritional labelling, together with nutrition programmes and supporting materials, to help consumers make well-informed choices.

Coca‑Cola Hellenic uses back-of-pack labelling to provide detailed information about calories, sugar, fat, saturated fat and salt content per serving, and a proportion of a healthy diet. This enables consumers to make informed decisions about weight control. Additional information is provided in Company publications, its website and consumer response services.

Responsible sales and marketing

Coca‑Cola Hellenic does not market its soft drinks in primary schools or target media advertising to children under the age of 12, and is working with third-party distributors to adhere to the same commitments.

In schools where children are above 12 years of age, the Company discusses with educators, parents and other stakeholders what beverages they feel are most appropriate.

Comprehensive lifestyle programmes

Coca‑Cola Hellenic is a founding signatory of the UNESDA1 Commitments, a set of voluntary industry obligations that address consumer information and education, healthy lifestyles and physical activity, advertising, beverage choice and research in the European Union. The commitments support the European Union (EU) Platform for Action on Diet, Physical Activity and Health, the major multi-stakeholder partnership to combat obesity, and apply to all the Company operations within the EU.

Promoting sports and physical activity

Coca‑Cola Hellenic actively develops, participates in, and financially supports a wide variety of sporting events and other physical activities as a means of promoting overall fitness and, in particular, encouraging people to manage body weight and prevent obesity. The Company works with government agencies, sports and nutrition experts, and industry members in coordinating exercise initiatives and nutritional education programmes.

We encourage our employees to be fit and healthy, providing them with advice and information on nutrition, health and wellness as well as providing gym facilities in a number of locations.

1 European Beverages Association

Outline

Coca‑Cola Hellenic is fully committed to the well being of its employees. The Company recognises that its employees can be exposed to the risk of acquiring HIV/ AIDS and that the high incidence of HIV/AIDS in some countries is compounded by the absence of social or medical support systems to treat affected people.

This policy has been established to address these issues in two ways:

• To reduce the risk of infection to employees and their families through education programmes that create awareness to how HIV / AIDS is transmitted, and how infection can be prevented
• To ensure that by working closely with local governments, appropriate help organisations and The Coca‑Cola Company, Coca‑Cola Hellenic can contribute to the provision of antiretroviral drugs for affected staff and their families in countries where there is a high incidence of HIV/AIDS and where treatment is not readily available

This Policy has been formulated with reference to the Joint United Nations Programme on HIV/AIDS, ILO Code of Practice on HIV/AIDS and The Coca‑Cola Company Africa Corporate Guidelines.

Purpose

• To create awareness on the issue of HIV/AIDS by educating staff, providing confidential counselling and advice to ensure that affected employees are treated with respect and dignity
• To provide guidance on such issues as testing, screening, confidentiality and nondiscrimination in employment

Confidentiality

The HIV status of any individual will be kept strictly confidential. Medical records of associates with HIV will be considered as confidential information.

Access to such information is strictly limited to medical personnel within the Company and may be disclosed only if legally required and with the consent of the employee concerned.

Voluntary disclosure

An employee who is infected with the HIV virus or suffers from AIDS is not obliged to inform the Company. If an employee discloses to his or her Manager or Human Resources representative information on their physical condition, such as HIV/AIDS, the Manager will be supportive and listen to the employee, noting key concerns. If the Human Resources representative is not aware of the situation, the Manager will contact the Human Resources representative for guidance and resources to help address the employee’s needs, only with the consent of the employee. Every instance will be handled on a case-by-case basis to balance the needs of the employee with the needs of the business.

Medical testing

The Company will not require new job applicants or Coca‑Cola Hellenic employees to disclose HIV/AIDS related personal information unless required by applicable law.

Employees who wish to determine their HIV/AIDS status may arrange to be tested voluntarily, subject to the completion of informed consent documentation and pre- and post-test counselling.

Counselling

Where counselling is not available, the Company will make available supplementary information and education programmes to all employees. Where possible and appropriate, this service and programmes will be extended to family members of associates.

We will also seek assistance from established community support and counselling groups. Information for these resources can be requested confidentially from the Human Resources Manager, or HR representative.

Reasonable accommodation and job security

Coca‑Cola Hellenic will take measures to extend reasonable accommodation to employees with HIV/AIDS related illnesses. This could include re-arrangement of working time, special equipment, opportunities for rest breaks, time off for medical appointments, flexible sick leave, part-time work and return to work arrangements.

Employees who are HIV positive, are free to continue to work and will be treated like any other employee with regard to training, promotion, transfer, discipline and other social welfare. Provisions under the existing Company policies and procedures regarding sick leave and impairment/disability will be applicable as instituted in instances of chronic ill health.

The Company will not dismiss an employee purely on the basis of his/her HIV/AIDS status.

Where an employee with an AIDS related condition is too ill to continue to work and where alternative working arrangements, including extended sick leave, have been exhausted, the employment relationship may cease in accordance with anti-discrimination, labour laws and Company policies and procedures.

Risk reduction and management

Coca‑Cola Hellenic will work to ensure a safe and healthy working environment, including the application of precautions and the provision and maintenance of protective equipment and first aid.

Non-discrimination grievance and disciplinary procedures

Where an employee perceives discrimination to be occurring as a result of his/her HIV/AIDS status, that individual shall have recourse to the Company’s internal grievance procedures.

Coca‑Cola Hellenic will take the corrective and disciplinary actions necessary against employees found to be involved in harassment or discrimination against employees directly or indirectly affected with HIV/AIDS.

Information sharing

In order to ensure the Company is in a good position to respond to the health needs of its workforce and to assist its efforts in future manpower planning, it may undertake means to obtain a realistic assessment of the HIV situation in the Company. Such assessment will be undertaken on a voluntary participation basis, and information will be kept confidential.

The Company ensures such information will not disclose the identity of individuals.

Policy review

This policy will be reviewed and updated as and when the need arises or when developments relating to it necessitate policy review.

We DELIVER SUSTAINABLY.

• We do what is right, not easy, and lead with integrity, always in line with our values.
• We act with purpose, considering the environment, communities, and the planet.
• Respect for human rights is fundamental to the sustainability of Coca-Cola HBC and the communities in which we operate.
• In our Company we are committed to ensuring that people are treated with dignity and respect.

Coca-Cola HBC's Human Rights Policy is committed to international human rights principles encompassed in the United Nations Universal Declaration of Human Rights, the International Labor Organization's Declaration on Fundamental Principles and Rights at Work, the United Nations Global Compact and the United Nations Guiding Principles on Business and Human Rights.

The Human Rights Policy applies to Coca-Cola HBC, the entities that it owns, the entities in which it holds a majority interest, and the facilities that it manages. The Company is committed to upholding the principles in this Policy. Our Supplier Guiding Principles apply to our suppliers and are aligned with the expectations and commitments of this Policy.

At Coca‑Cola Hellenic we benefit greatly from the skills, experience and commitment of the diverse range of people who work with us. We recognise that that diversity is essential to us being able to best serve our customers and strive to ensure that no one is treated inappropriately or disrespectfully at our workplace. This is aligned with our Values to act with integrity and care for our people.

This policy sets out our approach to inclusion and diversity and the avoidance of discrimination at work.

Inclusion and diversity for the purposes of this policy means the creation of a respectful work environment in which people neither discriminate nor are discriminated against in any context on the basis of the following characteristics:

1. Age
2. Disability
3. Gender or gender reassignment
4. Sex or sexual orientation
5. Marital or civil partnership status
6. Family status including pregnancy, maternity, paternity or other carer status
7. Race including ethnic origin, nationality or colour
8. Religious, political or other beliefs
9. Full-time or part-time status
10. Any other characteristic in respect of which legal protection is afforded by local law

Discrimination for these purposes includes one of the above characteristics being a factor in someone not being treated as favourably as they would otherwise have been treated, even if that characteristic was not the only or the main factor related to the treatment.

Harassment includes any disrespectful actions or statements related to the above characteristics or any other form of behaviour that does not involve being treated with respect and dignity. It includes any verbal or physical conduct designed to threaten, intimidate or coerce, or verbal taunting that, in the employee's opinion, impairs his or her ability to perform his or her job. This applies in the workplace and outside the workplace (when dealing with customers, suppliers or other work-related contacts, and on work-related trips or events including social events).

Sexual harassment in any form is prohibited under this policy. Sexual harassment is defined as unwelcome sexual advances, requests for sexual favours, and other verbal or physical conduct of a sexual nature when submission to or rejection of such conduct is used as the basis for employment decisions, or when such conduct has the purpose or effect of creating an intimidating, hostile, or offensive working environment.

Application

This policy applies to all people who work for us (including our employees, contractors, consultants, advisors, temporary workers and agency workers) and applies throughout the course of their dealings with us, including when they apply to work for us and after they cease working for us. It covers all aspects of employment with us, including recruitment, pay and conditions, training, appraisal, promotion, conduct at work, disciplinary and grievance procedures, and termination of employment. The policy creates both rights to be enjoyed by people who work for us and responsibilities for those same people to behave in a similar manner to ensure that others enjoy those same rights.

Leaders and managers within our business should assume particular responsibility to give effect to inclusion and diversity and robustly and promptly address any conduct that breaches this policy of which they become aware.

Complaints

Incidents of non-compliance with this policy or of any other conduct that affects inclusivity and diversity should ordinarily be reported to line managers in the first instance. Such incidents may alternatively be reported to a line manager’s line manager or to a member of Human Resources. We are committed to dealing promptly and thoroughly (and with as much confidentiality and sensitivity as is possible) with any such complaints.

We do not tolerate any form of victimisation relating to any complaint made in good faith. Victimisation includes not only conduct directed at the complainant but also conduct directed at any other person involved in any related investigation.

Sanctions

We may commence disciplinary or other applicable proceedings under our Code of Business Conduct against any person who we consider may have breached this policy. Such proceedings may lead to the imposition of appropriate disciplinary sanctions up to and including dismissal.

Policy status

We reserve the right to review and amend this policy to ensure that we are adequately promoting inclusion and diversity.

Our occupational health & safety programme is set out below. It is owned and endorsed by the CSR committee of the Board of Directors; responsibility for the successful implementation of this programme belongs to every Coca‑Cola Hellenic employee at each level and function in the organisation.

Coca‑Cola Hellenic is committed to developing and applying effective occupational health and safety (OH&S) systems, standards and practices appropriate to risks associated with its business activities. The Company delivers its OH&S programme through structured implementation of the Occupational Health and Safety Assessment Series standard OHSAS 18001. This is enhanced by The Coca‑Cola Company and Coca‑Cola Hellenic specific occupational health and safety standards. This programme aims to provide and maintain a healthy, safe working environment and to minimise the risks to employees, contractors, visitors and others who may be affected by the activities of the company, while fulfilling consumer and customer expectations of high quality, safe products.

The commitment to providing a healthy and safe working environment supports the following health and safety principles:

1. Provide an environment where work-related health and safety risks are controlled to prevent injuries and occupational ill health
2. Comply with all national government and regulatory OH&S requirements in all Coca‑Cola Hellenic territories and to conform to relevant international standards by implementing continuous improvement programmes
3. Implement an effective OH&S management programme integral to ongoing business activities, which will:
   • Identify, assess and control risks from known causes of occupational injuries and ill health associated with workplace processes and working environments
   • Ensure that all employees, at every level of the organisation, understand and commit to implementation of the Coca‑Cola Hellenic OH&S policies and practices
   • Develop employee OH&S competency through effective training and leadership at all levels within the organisation
   • Subject OH&S systems, procedures and performance to internal and external audit and validation
   • Investigate the causes of work-related injuries and ill health and take action to prevent recurrence
   • Align the requirements of OH&S with all other business disciplines and ensure that they are subject to performance measurement and continuous improvement programmes
   • Include health and safety strategies in the annual business planning process to ensure that the subject remains an integral part of operations
   • Set annual measurable OH&S objectives for all operations, and at group level, to ensure continuous improvement and compliance with all standards

Coca‑Cola Hellenic reports its OH&S performance in its annual Integrated Report as part of its commitment to achieving excellence in OH&S performance.

Our post-consumer packaging waste management policy is set out below. It is owned and endorsed by the Corporate Social Responsibility Committee of the Board of Directors. Responsibility for the successful implementation of this programme belongs with every Coca‑Cola Hellenic employee at each level and function in the organisation.

Coca‑Cola Hellenic is committed to continually improving its environmental performance in the area of packaging and packaging waste. All Coca‑Cola Hellenic territories are committed to continuous improvement, which is measured and evaluated for effectiveness.

The Company supports the implementation of post-consumer packaging schemes in all countries. The objectives are to:

• Co-own the country packaging management scheme (recovery organisation)
• Participate as an active member of the Management Board of Recovery Organisations with the appropriate participation at a senior level
• Own and take responsibility for collected material as members of authorised recovery organisations
• Implement efficient recovery organisation schemes at the lowest sustainable costs
• Develop and execute Business Plans according to the highest standards

To achieve these objectives, Coca‑Cola Hellenic:

• Enhances post-consumer packaging collection schemes and supports the education and awareness of consumers
• Engages in public awareness campaigns, selective waste collection education and anti-littering campaigns
• Works with government and industry to create a legal framework in which economic progress, diversion of material from landfill and emissions reductions can be achieved simultaneously
• Supports the view that public policy and regulatory interventions must encourage the development and implementation of appropriate technological solutions and enable the amendment of market mechanisms
• Promotes the development and expansion of organised collections of post-consumer packaging materials at public events to avoid littering
• Works to close the packaging loop in a sustainable manner
• Is committed to invest in Bottle-to-Bottle Recycling Plants in all countries with sustainable resources, i.e. cost-effective and efficient post-consumer PET collection schemes
• Includes packaging and packaging waste strategies in the annual business planning process to ensure that the subject remains an integral part of operations
• Sets annual measurable food safety and quality objectives for all operations, and at group level, to ensure continuous improvement and compliance with all standards

Coca‑Cola Hellenic will endeavour to:

• Influence policy, regulation and innovation by working to develop structured stakeholder dialogue, supporting the creation of equitable closed-loop packaging solutions, encouraging market mechanisms and promoting technological sorting innovations
• Activate cross-sector packaging associations to support solutions for dealing with the environmental impact of used packaging and packaging materials
• Ensure Coca‑Cola Hellenic consumers enjoy variety and freedom of choice in products and packaging options
• Enhance the efficiency and effectiveness of established post-consumer packaging waste management organisations
• Continue to drive light-weighting efforts for primary packaging and encourage the use of reusable and more efficient packaging design
• Continue to increase the recycled content of beverage packaging with emphasis on PET beverage bottles

Introduction

The Coca‑Cola HBC Premium Spirits Responsible Marketing Policy is intended to provide clear and consistent guidance to all employees about our standards for responsible marketing, advertising and promotion of the premium spirits products the company distributes and sells on behalf of its business partners.

The Policy is to be strictly adhered to in the same manner as the codes, policies and commitments regarding Coca‑Cola HBC operations and activities in respect of the non-alcoholic beverages we produce and distribute in order to reflect the company’s high standards, core values and social responsibility commitments.

Scope

The Coca‑Cola HBC Responsible Marketing Policy for Premium Spirits applies to all marketing activities including but not limited to selling activities, merchandising, sales and brand advertising, on-and offpremise promotional activities and related materials, brand innovation activities, experiential marketing, consumer planning and market research, relationship marketing, consumer public relations, the development and content of brand web sites, electronic communications and digital media, product placements and sponsorships, and labeling and packaging.

Compliance with Law and Regulation/ Regulatory Framework

All marketing activities must be in accordance with the applicable laws of the countries where Coca‑Cola HBC sells and distributes premium spirits. Commercial communication for premium spirits, regardless of the media used (print, electronic/digital media, posters, packaging, promotions, sponsorships and other promotional activities) must also comply with the applicable provisions of industry- agreed guidelines for each country. For Europe-wide, industry common marketing standards, please refer to the documents and materials which can be found at www.marketresponsibly.eu, provided by Spirits Europe, of which our premium spirits partners or their industry associations are members.

Any complaints or criticism by any person relating to the marketing and promotion of premium spirits products by Coca‑Cola HBC should be reported immediately to the local PA&C and Legal Departments to proceed with any appropriate or necessary actions.

Education

Coca‑Cola HBC countries selling and distributing premium spirits must establish regular training programmes for all staff involved in the sales, merchandising, consumer marketing, trade marketing, customer planning, R&D and PA&C of premium spirits brands.

If you wish to receive more information relating to this Policy or compliance with its provisions, please contact your local premium spirits manager or PA&C and Legal departments.

Last updated: April, 2015.

Our quality & food safety policy is set out below. It is owned and endorsed by the Corporate Social Responsibility Committee of the Board of Directors; responsibility for the successful implementation of this programme belongs with every Coca‑Cola Hellenic employee at each level and function in the organisation.

Coca‑Cola Hellenic believes that success depends on the supply of high quality products, packages and services that meet or exceed customer and consumer expectations of premium brand products. Fundamental to this belief is the responsibility to ensure the food safety of all products that the Company manufactures.

The Company is committed to continually enhance the reputation of the brands it produces and maintain consumer confidence in its products through the development and implementation of quality and food safety systems, standards and practices. All Coca‑Cola Hellenic operations commit to continuous improvement, which is measured, evaluated and validated for effectiveness through internal and external audits.

The Company believes that the responsibility for achieving quality commitments lies with each Coca‑Cola Hellenic employee in the execution of their jobs and their relationship with stakeholders. Food safety is the responsibility of all employees that have direct influence on ingredients, packaging, manufacturing, storage and the transport of products.

The following food safety and quality principles are the foundation of the Coca‑Cola Hellenic commitment to quality:

• Manufacture and deliver products that meet the highest food safety and quality standards.
• Meet or exceed all statutory and regulatory requirements for quality and food safety.
• Ensure sustainable food safety and quality performance through implementation and certification of effective quality management systems compliant with ISO 9001:2008, ISO 22000:2005, FSSC 22000 and The Coca‑Cola Management System standards in all operations and PAS 223:2011 where applicable.
• Validate the effectiveness of the food safety and quality management systems through internal and external audit processes recognised by the International Standards Organisation and The Coca‑Cola Company.
• Build food safety and quality capability through structured programmes that develop technical skills, increase awareness, manage risk and drive increasing levels of excellence.
• Continually review food safety policies, standards and procedures to effectively manage food safety risks associated with changes in products, processes and technologies.
• Include food safety and quality strategies in the annual business planning process to ensure that food safety and quality remains an integral part of operations.
• Set annual measurable food safety and quality objectives for all operations, and at group level, to ensure continuous improvement and compliance with all standards.
• Ensure that suppliers and contractors embrace the same food safety and quality commitments, and monitor the materials and services they supply through audits and incoming goods inspections.
• Communicate food safety requirements to suppliers, contractors, customers and consumers by establishing specifications for ingredients and packaging materials, product storage and consumer guidelines.
• Communicate food safety and quality aspects, strategies and performance to associates, consumers, customers and principal stakeholders that have an impact on, or are affected by the Company’s food safety and quality management systems.

We look to develop relationships with suppliers that share similar values to us and conduct business in an ethical manner. We strive to treat our suppliers in the same manner we expect to be treated.

As an ethical business organisation, Coca‑Cola HBC AG and its subsidiaries (collectively, “Coca‑Cola Hellenic” or the “Company”) takes responsibility to ensure that its business operations do not contribute directly or indirectly to human rights abuses. We use our influence internally to ensure that our employees fully understand the company’s commitment to human rights and their own rights and responsibilities.

Those who do business with us across the countries, in which we operate, know we are committed to managing our business with a consistent set of values that represent the highest standards of quality, integrity and excellence. We respect the unique customs and cultures in communities where we operate. In pursuing this policy, we seek to develop relationships with suppliers that share similar values and conduct business in an ethical manner. We strive to treat our suppliers in the same manner we expect to be treated.

As part of ongoing effort to develop and strengthen our relationships with suppliers, we have adopted these Supplier Guiding Principles for use with our direct suppliers. These Principles are based on the belief that good corporate citizenship is essential to our long-term business success and must be reflected in our relationships and actions in the marketplace, the workplace, the environment and the community.

We are pleased to work with suppliers to ensure an understanding of and compliance with the requirements set forth in our Supplier Guiding Principles.

Workplace practices

At Coca‑Cola Hellenic, we support fair employment practices consistent with our commitment to human rights in our workplace. We seek to:

1. Establish a strong and direct relationship with our employees through open and honest communications
2. Treat our employees with fairness, dignity, and respect
3. Abide by applicable local labour laws, including those that address working hours, compensation, discrimination, and third party representation
4. Value diversity in its broadest sense
5. Hold each other accountable for performance at the highest levels
6. Reward our employees commensurate with performance
7. Provide opportunities for employees to develop personally and professionally
8. Ensure, with our employees, the safety of the workplace. We expect our suppliers to follow applicable laws, and similar standards and principles in the countries in which they operate

Work environment

We expect our suppliers to judge their employees and contractors based upon their ability to do their jobs and not upon their physical and/or personal characteristics or beliefs, affirming the principle of no discrimination based on race, colour, gender, religion, political opinion, national origin or sexual orientation.

Health and safety

We expect our suppliers to provide a safe workplace with policies and practices in place to minimise the risk of accidents, injury, and exposure to health risks.

Child and forced labour; abuse of labour

We expect our suppliers neither to employ anyone under the legal working age nor to condone physical or other unlawful abuse or harassment, or the use of forced or other compulsory labour in any of their operations.

Wages and benefits

We expect our suppliers to compensate their employees fairly and competitively relative to their industry, in full compliance with applicable local and national wage and hour laws, and to offer opportunities for employees to develop their skills and capabilities.

Third parties

In the event their employees have lawfully chosen to be represented by third parties, we expect our suppliers to recognise such parties in good faith and not to retaliate against employees for their lawful participation in labour organisation activities.

Environmental practices

We expect our suppliers to conduct business in ways that protect and preserve the environment. At a minimum, we expect our suppliers to meet applicable environmental laws, rules and regulations in their operations in the countries in which they do business.

Conflicts of interest

Coca‑Cola Hellenic employees are expected to always select and deal with suppliers who are doing, or seeking to do, business with the Company in a completely straightforward, honest manner, based upon the merits of such persons and their products and services and without any special considerations given back to them or their friends or families. Accordingly, employees should have no relationship, financial or otherwise, with any supplier that might conflict, or appear to conflict, with the employee's obligation to act in the best interest of Coca‑Cola Hellenic. For example, suppliers should not employ or otherwise make payments to any employee of Coca‑Cola Hellenic during the course of any transaction between the supplier and the Company. Friendships outside of the course of business are inevitable and acceptable, but suppliers should take care that any personal relationship is not used to influence the Coca‑Cola Hellenic employee's business judgment. If a supplier employee is a family relation (spouse, parent, sibling, grandparent, child, grandchild, mother- or father-in-law, or domestic partner) to an employee of Coca‑Cola Hellenic, or if a supplier has any other relationship with an employee of Coca‑Cola Hellenic that might represent a conflict of interest, the supplier should disclose this fact to Coca‑Cola Hellenic or ensure that the Coca‑Cola Hellenic employee does so.

Gifts, meals and entertainment

Employees of Coca‑Cola Hellenic are prohibited from accepting anything more than normal business hospitality from suppliers that is reasonable and appropriate under the circumstances. Ordinary business meals and small tokens of appreciation generally are fine, but suppliers should not offer Coca‑Cola Hellenic employees excessive or lavish gifts, meals or entertainment that may give the appearance of undue influence. Gifts of cash or cash equivalents, such as gift cards, are never allowed. Gifts and entertainment for suppliers must support the legitimate business interests of the Company and should be reasonable and appropriate under the circumstances. Our employees should always be sensitive to our suppliers’ own rules on receiving gifts and entertainment.

Business and financial records

Both the supplier and Coca‑Cola Hellenic must keep accurate records of all matters related to the supplier's business with Coca‑Cola Hellenic. This includes the proper recording of all expenses and payments. If Coca‑Cola Hellenic is being charged for a supplier employee's time, time records must be complete and accurate. Suppliers should not delay sending an invoice or otherwise enable the shifting of an expense to a different accounting period.

Bribery

Suppliers acting on behalf of Coca‑Cola Hellenic must comply with all applicable laws dealing with bribery of government officials. In connection with any transaction as a supplier to Coca‑Cola Hellenic, or that otherwise involves Coca‑Cola Hellenic, the supplier must not transfer anything of value, directly or indirectly, to any government official, employee of a government-controlled company, or political party, in order to obtain any improper benefit or advantage. Suppliers must keep a written accounting of all payments (including any gifts, meals, entertainment or anything else of value) made on behalf of Coca‑Cola Hellenic, or out of funds provided by Coca‑Cola Hellenic. Suppliers must furnish a copy of this accounting to Coca‑Cola Hellenic upon request.

Protecting information

Suppliers should protect the confidential information of Coca‑Cola Hellenic. Suppliers who have been given access to confidential information as part of the business relationship should not share this information with anyone unless authorized to do so by Coca‑Cola Hellenic. Suppliers should not trade in securities, or encourage others to do so, based on confidential information received from Coca‑Cola Hellenic. If a supplier believes it has been given access to Coca‑Cola Hellenic's confidential information in error, the supplier should immediately notify its contact at the Company and refrain from further distribution of the information.

Similarly, a supplier should not share with anyone at Coca‑Cola Hellenic information related to any other company if the supplier is under a contractual or legal obligation not to share the information.

Reporting potential misconduct

Suppliers who believe that an employee of Coca‑Cola Hellenic, or anyone acting on behalf of Coca‑Cola Hellenic, has engaged in illegal or otherwise improper conduct, should report the matter to the Company. We would also like you, as our suppliers, to feel able to freely raise any issues of compliance or ethics you come across in our company and feel confident that your concerns will be taken seriously and handled appropriately by Coca‑Cola Hellenic. Concerns should be raised initially with your contact in Coca‑Cola Hellenic, however, if you feel it is inappropriate in a specific circumstances, you can use our SpeakUp! Line at [email protected]. Coca‑Cola Hellenic will not tolerate a reprisal by any of our employees against suppliers for reporting a concern in good faith or assisting with an investigation.

Compliance with applicable laws and standards

At a minimum, suppliers to Coca‑Cola Hellenic will be required to meet the following standards with respect to their operations as a whole:

• Laws and regulations Supplier will comply with all applicable laws, rules, regulations and requirements in the manufacture and distribution of products and supplies and in providing services to Coca‑Cola Hellenic
• Child labour Supplier will not use child labour as defined by local law. Forced Labour Supplier will not use forced or compulsory labour
• Abuse of labour Supplier will not abuse labour, physically or otherwise
• Third parties Supplier will respect employees' rights to choose whether to be represented by third parties and to bargain collectively in accordance with applicable laws
• Wages and benefits Wages and benefits will comply with applicable laws
• Working hours & overtime Working hours and overtime will comply with applicable laws
• Health and safety Working conditions will comply with applicable laws
• Environment Supplier will comply with applicable environmental laws
• Conflicts of interest Coca‑Cola Hellenic employees and our suppliers should avoid situations where a conflict of interest may occur
• Business and financial records Supplier will comply with all applicable laws concerning financial recordkeeping and reporting
• Bribery Supplier will comply with all applicable anti-bribery laws and will not use bribes or fraudulent practices
• Protecting information Supplier will safeguard Coca‑Cola Hellenic’s and other third party non-public information disclosed to supplier

Our water stewardship policy is set out below. It is owned and endorsed by the Corporate Social Responsibility Committee of the Board of Directors; responsibility for the successful implementation of this programme belongs with every Coca‑Cola Hellenic employee at each level and function in the organisation.

Water is vital to human and community development. Coca‑Cola Hellenic strives to limit its impacts on watersheds and promote water stewardship activities in the communities where it operates. We will ensure that our use of water respects the needs of our communities.

We believe that industry has a key role to play in finding sustainable solutions to today’s water challenges. We recognise that human development and climate change will profoundly influence water availability and will work to mitigate changes and adapt to them.

The direct water impacts of Coca‑Cola Hellenic operations result mostly from the use of water in bottling plants. Indirect impacts result from the virtual water embedded in its ingredients and, to a lesser extent, from its packaging.

In accordance with our environmental policy, we commit to: 

• Minimise the impact from operations, by decreasing water use and ensuring that wastewater is fully treated to levels that sustain aquatic life
• Assess future water availability and reduce environmental and social risks linked to our use of water
• Work with suppliers to understand the water footprint of raw materials, in particular agricultural products such as sugar and fruit
• Engage communities to increase awareness and protection of water resources, through local and international partnership programmes
• Provide emergency supplies of water to communities in the aftermath of disasters
• Contribute to the development of water standards and policies, locally and internationally, in partnership with key stakeholders
• Work with organisations and initiatives such the UN Global Compact Water
• Share and promote water stewardship practices

We report comprehensively and transparently on our water impacts and activities, under the guidance of key stakeholders.