A N T I C O R R U P T I O N POLICY

Transcription

1 ANTI CORRUPTION POLICY

2 ANTI CORRUPTION POLICY Our Anti-Corruption Policy is in compliance with our Code of Business Conduct and covers important topics as follows: Giving gifts and corporate hospitality Acceptance of gifts and hospitality Touch point vendors Charitable contributions Political Contributions Facilitating payments Record keeping CLICK HERE TO ACCESS ABI ANTI CORRUPTION POLICY AND CODE OF BUSINESS CONDUCT

3 Giving gifts and corporate hospitality AB Inbev and its employees/directors are forbidden from providing gifts, meals, entertainment and travel expenses to anyone in exchange for an improper benefit or advantage to the company. However, if there is no improper benefit or advantage for the company, we are allowed to provide gifts, meals, entertainment or travel expenses under specific conditions, as described in the following slides. Remember to consult the Legal Department if you have questions before making a decision!.

4 Policy Public Officials GIFTS MEALS ENTERTAINMENT TRAVEL Limit is 100 USD per person; No more than 2 times/12-month period; Spouses are not allowed to receive; Always requires Legal Department pre-approval Limit is 100 USD per person; No more than 2 times/12- month period; Spouses are not allowed to receive; Requires Legal Department pre-approval when above the limits. Limit is 200 USD per person; No more than 2 times/12- month period; Spouses are not allowed to receive; Always requires Legal Department pre-approval Always requires Legal Department pre-approval Regarding each topic, remember: Everything except meals under USD$100 per person requires preapproval from Legal department. Any exceptions must be submitted to the Legal Department for approval by the Labatt Business Practices Committee

5 Policy Commercial Counterparties GIFTS Limited to USD 100 per person; No more than twice per 12-month period; Spouses are not allowed to receive; Requires Legal Department pre-approval when above the limits. MEALS Limited to USD 100 per person; No more than twice per 12-month period; Spouses are not allowed to receive; Requires Legal Department pre-approval when above the limits. ENTERTAINMENT Limited to USD 200 per person; No more than twice per 12-month period; Spouses are not allowed to receive; Requires Legal Department pre-approval when above the limits. TRAVEL Always requires Legal Department pre-approval. NOTE THAT EXPENSES ASSOCIATED WITH MEALS, TRAVEL AND ENTERTAINMENT FOR ACTUAL OR POTENTIAL CUSTOMERS/CLIENTS OF LABATT ARE GOVERNED BY THE LABATT COMMERCIAL EXPENSE POLICY. If the corporate gift/meal/entertainment/hospitality is provided to the commercial counterparty in the context of a commercial arrangement or sales incentive program, the limits and procedures are not applicable.

6 Giving gifts and corporate hospitality - Wrap up Ab-Inbev may not offer, promise, pay, give, or authorize an improper or unlawful payment, benefit, advantage or reward, even if doing so results in the loss of business opportunities for AB InBev. Even if there is no improper advantage or reward to the company you must consult the Legal Department to seek approval and to log the gifts in accordance with our policies. All expenses must be supported by receipts and accurately recorded in the company s books and records.

7 ANTI CORRUPTION POLICY Giving gifts and corporate hospitality Acceptance of gifts and hospitality Touch point vendors Charitable contributions Political Contributions Facilitating payments Record keeping CLICK HERE TO ACCESS ABI ANTI CORRUPTION POLICY AND CODE OF BUSINESS CONDUCT

8 Acceptance of gifts and hospitality Ab Inbev employees are not allowed to accept anything of value including gifts, entertainment, travel or meals from an actual or potential supplier, customer, public official or other third party. if you receive a gift in these circumstances, it should be turned over to Ab Inbev to be auctioned or donated. Remember to consult the Legal Department if you have questions before making a decision!

9 Acceptance of gifts and hospitality Please Note An invitation to an event that has a valid business purpose (i.e. directly or indirectly tied to revenue generation) can be accepted, provided that (i) the employee s line manager has validated and approved the business purpose; (ii) the employee s spouse or guest is not included in the benefit; and (iii) approval from the legal department is obtained. Note that a simple meeting over a meal would not constitute an event for these purposes and therefore in that situation the ABI employee should pay for his or her own meal. Business related conferences and networking events, including incidental meals, refreshments and entertainment are also allowed, provided that (i) the employee s line manager has validated and approved the business purpose; (ii) the employee s spouse or guest is not included in the benefit; and (iii) approval from the legal department is obtained. It is also permissible to accept refreshments while conducting business at a customer or supplier s premises, when individual payment is not available. Remember to consult the Legal Department if you have questions before making a decision!

10 ANTI CORRUPTION POLICY Giving gifts and corporate hospitality Acceptance of gifts and hospitality Touch point vendors Charitable contributions Political Contributions Facilitating payments Record keeping CLICK HERE TO ACCESS ABI ANTI CORRUPTION POLICY AND CODE OF BUSINESS CONDUCT

11 Touchpoint Vendors: Risk of Corruption Touch Point vendors are certain Third Parties that may interact with Public Officials while providing goods or services to the Company such as: Consultants Agents for Permits Distributors Promoters Event organizers Marketing Agencies Customs brokers Freight forwarders Lessors Constructors

12 Working with Touch Point Vendors: Due Diligence Before you engage/pay a Touch Point Vendor, make sure you consult with the Legal team! They will conduct a background check on the vendor to assess any corruption/reputational risks of retaining its services.

13 Working with Touch Point Vendors: Due Diligence - Wrap up We cannot pay/engage a touch point vendor before obtaining clearance from the Legal Department. Make sure that all payments to touch point vendors are correctly booked and supported by proper documents that describe the services provided. Consult the Compliance Channel if you have questions.

14 ANTI CORRUPTION POLICY Giving gifts and corporate hospitality Acceptance of gifts and hospitality Touch point vendors Charitable contributions Political Contributions Facilitating payments Record keeping CLICK HERE TO ACCESS ABI ANTI CORRUPTION POLICY AND CODE OF BUSINESS CONDUCT

15 Charitable Donations: Charitable Contributions Charitable donations to public/private entities made (such as: municipalities, police battalions, etc) at the request of a Public Official must always be submitted for approval through the Legal Department and they must also: Not be paid in cash Not be made as part of an exchange of favours with a Public Official Not be paid to a private account or individual, or to a for-profit organization Not amount to a political contribution Be transparent regarding the identity of the recipient, the amount and the purpose for which it is intended.

16 ANTI CORRUPTION POLICY Giving gifts and corporate hospitality Acceptance of gifts and hospitality Touch point vendors Charitable contributions Political Contributions Facilitating payments Record keeping CLICK HERE TO ACCESS ABI ANTI CORRUPTION POLICY AND CODE OF BUSINESS CONDUCT

17 Political Contributions Political contributions can only be made if approved by the Board of Directors and in accordance with local legislation. Remember to consult the Legal Department if you have questions before making a decision!

18 ANTI CORRUPTION POLICY Giving gifts and corporate hospitality Acceptance of gifts and hospitality Touch point vendors Charitable contributions Political Contributions Facilitating payments Record keeping CLICK HERE TO ACCESS ABI ANTI CORRUPTION POLICY AND CODE OF BUSINESS CONDUCT

19 Facilitating Payments Facilitation or grease payments usually are small payments to a low-level government employee to expedite or secure performance of a routine, nondiscretionary governmental action, such as obtaining utility services or clearing customs. They are unlawful in most countries and are strictly prohibited under AB InBev s Anti- Corruption Policy. Remember to consult the Legal Department if you have questions before making a decision!

20 ANTI CORRUPTION POLICY Giving gifts and corporate hospitality Acceptance of gifts and hospitality Touch point vendors Charitable contributions Political Contributions Facilitating payments Record keeping CLICK HERE TO ACCESS ABI ANTI CORRUPTION POLICY AND CODE OF BUSINESS CONDUCT

21 Record Keeping: Guidelines We must ensure accuracy of our books, records, inventories, expense reports, entertainment, travel and gifts reports. Before making payments or giving gifts, always make sure that: transactions are accurately recorded in the correct package supporting documentation is kept, such as invoices with the services provided, contracts, etc. there are no undisclosed or unrecorded funds or assets

22 THE COMPLIANCE HELPLINE

23 The Compliance Helpline If you see or suspect a violation of our Code of Business Conduct, the law, our policies or if a violation is reported to you you should act. Make a confidential report online at or Call The online reporting site and hotline are operated by an independent company that operates 24 hours a day 7 days a week. If you wish, your report can be made anonymously. You can easily access the Helpline site from our Compliance Channel.

24 PLEASE REMEMBER THAT INTEGRITY IS THE FOUNDATION OF AB INBEV S LONG-TERM SUCCESS. We are the owners of our culture and principles and we need to protect them.

25 THANK YOU! If you have any questions, please contact the Legal Department