Code of Business Conduct for Suppliers to The Coca-Cola Company
The Coca-Cola Company* expects all of its employees to comply with the law and act
ethically in all matters. We have the same expectations of our suppliers. Our Code
of Business Conduct sets the basic standards for employee conduct. This Code of
Business Conduct for Suppliers establishes related requirements for our suppliers.
Working together, we can achieve great success by doing the right thing.
Conflicts of Interest
Note: This Code contains general requirements applicable to all
suppliers to The Coca-Cola Company. Particular supplier contracts may contain more
specific provisions addressing some of these same issues. Nothing in this Code is
meant to supersede any more specific provision in a particular contract, and to
the extent there is any inconsistency between this Code and any other provision
of a particular contract, the other provision will control.
Employees of The Coca-Cola Company should act in the best interest of the Company.
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 The Coca-Cola Company. For example, suppliers should
not employ or otherwise make payments to any employee of The Coca-Cola Company 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
employee's business judgment. If a supplier employee is a family relation (spouse,
parent, sibling, grandparent, child, grandchild, mother- or father-in-law, or same
or opposite sex domestic partner) to an employee of The Coca-Cola Company, or if
a supplier has any other relationship with an employee of The Coca-Cola Company
that might represent a conflict of interest, the supplier should disclose this fact
to The Coca-Cola Company or ensure that the Coca-Cola employee does so.
Gifts, Meals and Entertainment
Employees of The Coca-Cola Company are prohibited from accepting anything more than
modest gifts, meals and entertainment from suppliers. Ordinary business meals and
small tokens of appreciation such as gift baskets at holiday time generally are
fine, but suppliers should avoid offering Coca-Cola employees travel, frequent meals
or expensive gifts. Gifts of cash or cash equivalents, such as gift cards, are never
Business and Financial Records
Both the supplier and The Coca-Cola Company must keep accurate records of all matters
related to the supplier's business with The Coca-Cola Company. This includes the
proper recording of all expenses and payments. If The Coca-Cola Company 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.
Suppliers acting on behalf of The Coca-Cola Company must comply with the U.S. Foreign
Corrupt Practices Act, as well as all local laws dealing with bribery of government
officials. In connection with any transaction as a supplier to The Coca-Cola Company,
or that otherwise involves The Coca-Cola Company, 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 The
Coca-Cola Company, or out of funds provided by The Coca-Cola Company. Suppliers
must furnish a copy of this accounting to The Coca-Cola Company upon request.
Suppliers should protect the confidential information of The Coca-Cola Company.
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 The Coca-Cola Company. Suppliers should not trade in securities, or
encourage others to do so, based on confidential information received from The Coca-Cola
Company. If a supplier believes it has been given access to The Coca-Cola Company's
confidential information in error, the supplier should immediately notify its contact
at the Company and refrain from further distribution of the information.
Reporting Potential Misconduct
Similarly, a supplier should not share with anyone at The Coca-Cola Company information
related to any other company if the supplier is under a contractual or legal obligation
not to share the information.
Suppliers who believe that an employee of The Coca-Cola Company, or anyone acting
on behalf of
The Coca-Cola Company, has engaged in illegal or otherwise improper conduct, should
report the matter to the Company. The supplier can contact the employee's manager
or The Coca-Cola Company Ethics & Compliance Office at +1-404-676-5579 or email@example.com,
or use the Company's EthicsLine reporting service at www.KOethics.com, or call toll-free using the access codes
that can be found on the EthicsLine website. A supplier's relationship with The
Coca-Cola Company will not be affected by an honest report of potential misconduct.
* This document is applicable to suppliers of The Coca-Cola Company and its majority-owned
subsidiaries. Use of the terms "The Coca-Cola Company" and "the Company" in this
document refers to The Coca-Cola Company or one or more of its subsidiaries, whichever
is relevant to the particular supplier relationship.
© 2008 The Coca-Cola Company