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The way we work,
every day, everywhere
The way we work,every day, everywhere
ur purpose and values define what is important in the way that we work together and perform as a business.
We are intent on constantly demonstrating our commitment to being one of the world’s most trusted and
respected companies. We ask our consumers, shareholders, governments and the communities in which we operate,
to trust that we understand our responsibility as the world’s leading premium drinks business and that we
behave accordingly.
Reputation is critical to Diageo’s commercial success, long-term sustainability and fulfilment of our purpose of
celebrating life every day, everywhere. We all have a responsibility to ensure we strive to do the right thing and in so
doing, protect that reputation. In today’s connected world our individual actions have the potential to impact Diageo
globally, both positively and negatively. All of us, including those acting on behalf of Diageo, have an obligation to
apply the Code of Business Conduct, Diageo policies, and all relevant laws, in everything we do.
In producing this update of the Code our aim has been to provide a clear and accessible document with practical
guidance on our individual responsibilities and how to access further sources of information. The Code is now
available in 18 languages, reflecting the geographical breadth and multi-cultural nature of our operations.
However, such a code cannot address every situation we may face and it is not a substitute for applying common
sense and good judgement, informed by our purpose and values and our commitment to being one of the most
trusted and respected companies in the world. When in doubt, seek advice; talk to your colleagues to get their
perspective. Talk to your line manager, our Global Compliance & Ethics Director or an expert from the
appropriate function.
If you are concerned about something that does not appear to support our purpose and values or contravenes the
law, the Code, or Diageo policies, you should speak up. There may be circumstances in which you may wish to use the
independent SpeakUp service, where you can raise an issue or concern confidentially.
We will not tolerate any retaliation against an individual for raising a concern or making a report in good faith.
We want Diageo to be recognised as a great place to work. Most of all, however, we want Diageo to become
a by-word for acting with integrity and responsibility; a business with values that are demonstrated every day and are
deeply embedded in the fabric of the organisation.
Please take the time to read and understand the Code. Please also personally commit to implementing it in all of
your actions and all of our business activities. We know that we have your full support for the values that have set
Diageo apart from the competition. Thank you.
Paul S Walsh
Chief Executive
Ron AndersonChief Customer Officer
Gilbert GhostineManaging Director, Continental Europe
Randy MillianManaging Director, Latin America and Caribbean
Nick C RoseChief Financial Officer
Nick B BlazquezManaging Director, Diageo Africa
David P GosnellManaging Director, Global Supplyand Global Procurement
Andrew MorganPresident, Diageo Europe
Larry SchwartzPresident, Diageo USA
Andrew J FennellChief Marketing Officer
Jim N GroverDirector, Global Business Support
John C PollaersPresident, Diageo Asia Pacific
Gareth WilliamsHuman Resources Director
Stuart R FletcherPresident, Diageo International
Ivan M MenezesPresident, Diageo North America and Chairman, Diageo Asia Pacific
Timothy D ProctorGeneral Counsel
Ian WrightCorporate Relations Director
O
Letter from the Executive Committee
INTRODUCTION
Our purpose & values 5
Code of Business Conduct 6
Getting help & advice 7
The way we work 9
OUR PRODUCTS
Marketing & innovation 11
Quality 12
International trade & free zone sales 13
PERSONAL INTEGRITY
Gifts & entertainment 15
Conflicts of interest 16
Insider trading 17
COMMERCIAL INTEGRITY
Bribery & improper payments 19
Competition & anti-trust 21
Money laundering 23
Accurate reporting & accounts 24
Data privacy 25
EMPLOYMENT
Health, safety & security 27
Discrimination & harassment 28
Responsible drinking 29
COMPANY ASSETS
Brand protection 31
Confidential information 32
Information security 33
Records management 34
EXTERNAL ACTIVITY
External communications 36
Political activity 37
Community & charitable activity 38
Human rights 39
Environment 40
CONTACTS
Contacts & links 42
SpeakUp 43
CONTENTS
INTRODUCTION
Contents
5
Contents
We are passionate about
consumers – our curiosity and
consumer insights drive our
growth. We cherish our brands;
we are creative and courageous
in pursuing their full potential.
We are innovative, constantly
searching for new ideas.
We give ourselves and each
other the freedom to succeed
– we trust each other, we are
open to and seek challenge,
and we respond quickly to
the opportunity this creates.
We are proud of what we
do – we behave responsibly
with the highest standards
of integrity and social
responsibility.
We strive to be the best – as
an organisation we are never
complacent. We are always
seeking to learn and improve.
We value each other – we
seek and benefit from diverse
people and perspectives.
We strive to create mutually
fulfilling relationships and
partnerships.
Our purpose, to celebrate life every day, everywhere, and our values lie at the heart of our business.
They define our approach to the way we work. They capture the essence of our passion, our
ambition, our responsibility and our pride in what we do.
Our values reflect our beliefs about what is important in the way that we work together and
with others outside of Diageo. We bring them to life in our business, every day, everywhere,
through the way we behave and the results we achieve. Our values should be our guide when
making decisions and deciding priorities.
To reinforce our behaviours we have established codes and policies, setting out the way we
work, our commitments and what is expected of each of us. These policies can be found on
the Diageo intranet and you have a responsibility to comply with them.
This document, our overall Code of Business Conduct, is designed to help translate our values
and principles into actions and guide our daily activities.
Each of us needs to take time to read and understand the Code and use it to help us apply
our values in everything we do.
Ou
r pu
rpo
se &
value
s
Our purpose & values
Our purpose and values are at the heart of everything we do – influencing the way we work, every day, everywhere
INT
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6
A
Q
A
Why do we need a Code
of Business Conduct?
The Code sets out
Diageo’s commitment
to conducting business in
accordance with our purpose
and values, all relevant laws
and regulations and industry
standards. It provides guidance
on what is expected of each of
us and references other Diageo
policies and guidelines.
Failure to comply with the
Code or any Diageo policy is
treated very seriously and may
result in disciplinary action,
including dismissal.
Does the Code apply
to everyone in Diageo?
The Code applies to
everyone working for
Diageo worldwide regardless
of location, role or level
of seniority.
It also applies to anyone
working on behalf of Diageo.
All agents and representatives,
consultants, contractors and
temporary employees are
required to comply with the
Code and to report any actual
or potential violations of
the Code or Diageo policies
through one of the routes
described in this document.
Every non-wholly-owned
subsidiary and joint venture
which Diageo controls should
adopt a code of business
conduct and policies aligned
with those of Diageo. 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.
We strive to demonstrate the highest standards of integrity in the way we behave towards each
other and to those outside of the company. Our actions and interactions with our consumers,
customers, employees, public officials, suppliers, shareholders and other stakeholders should
clearly reflect our commitment to doing the right thing. Reputation is critical to our commercial
success and can only be enhanced by behaviours of which we can all be proud.
The Code of Business Conduct provides information on key areas of our business activities and
outlines our individual responsibilities – the things we must all do. All employees and those
acting on behalf of Diageo must apply the Code and Diageo policies that relate to their role,
regardless of their location or nature of work. It is critical that we all familiarise ourselves with
the Code and policies and apply them to everything we do.
Breaching the Code or Diageo policies can have serious consequences for the company and
for each of us as individuals. Those who fail to follow the Code put themselves, their colleagues,
and Diageo at risk. This is taken very seriously and may result in disciplinary action up to and
including dismissal.
The Code cannot provide answers to every question we may have or tell us what to do in every
situation in which we may find ourselves. It does not serve as a substitute for our individual
responsibility for exercising good judgement and common sense. It is a resource to be used
to help guide our actions and provides details on where to go to for more information on
a particular subject, to ask questions, or to report a problem.
Responsibility for compliance & ethicsEach Diageo employee is responsible for compliance with the Code of Business Conduct
and Diageo policies in addition to all laws, regulations and industry standards. The company
places its trust in each of us to act in a way which is not only compliant but which supports our
values, purpose and business principles.
The Global Compliance & Ethics team manages the Diageo Compliance & Ethics programme
and is there to provide help and guidance on all issues relating to the Code and Diageo policies.
If you manage people, you are expected to adopt the Diageo Leadership Standard and be
a role model for others. You must ensure that the individuals who report to you receive the
guidance, resources and training they need to enable them to do their job in compliance
with the Code and Diageo policies. You must take personal accountability for creating an
environment of trust in which people feel able to ask questions, raise concerns and report
suspected violations without fear of reprisal. There will be disciplinary action for all levels
of management for lack of diligence, supervision or leadership with regard to the application
of the Code and Diageo policies.
All agents and representatives, consultants, contractors and temporary employees are required
to abide by the Code and Diageo policies. If you work with agents or representatives, or you
engage an individual on a non-permanent basis, it is your responsibility to ensure that they
have been provided with a copy of the Code and understand what is expected of them.
Co
de
of B
usin
ess C
on
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ct
Code of Business Conduct
Proud of what we do, proud of how we do it
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7
AQ
A
Does the Code contain
everything I need to
know in doing my job?
No, the Code cannot detail
everything you need to
know in doing your job or every
situation that you may encounter.
You are responsible for learning
about and conducting your
work in accordance with
Diageo’s values, the Code
and Diageo policies, and all
applicable laws.
Diageo operates across many
different countries each of
which has its own local legal
system. You need to ensure
you understand and comply
with local laws and regulations,
in addition to the Code and
Diageo policies.
Other Diageo policies and
guidelines, not specifically
referred to in the Code that
may be relevant to your
job can be found on the
Diageo intranet.
As a manager do I have
additional responsibilities?
Yes. If you are responsible
for managing people, you
must lead by example and act
as a role model for others. You
need to ensure that anyone
who reports to you receives
guidance and training and the
resources they need to protect
themselves and Diageo.
You are responsible for creating
an environment of trust that
encourages open discussion
about compliance or ethical
concerns and where people
feel able to report suspected
violations without fear
of reprisal.
If you are involved in retaining
third parties to act on behalf of
Diageo, you must ensure that
they are made aware of and act
in accordance with the Code
and Diageo policies.
Every day we face situations that may be unfamiliar to us or where we are unsure as to the best
course of action to take. We naturally turn to those we work with and trust to seek support
and guidance in doing our job. Applying the Code, Diageo policies, and laws and regulations
to our daily work is no different. No one is an expert in all matters or intuitively knows what to
do in every situation.
Whenever we are unsure about the areas raised in this Code or any other matter, it is the right
thing to do to ask questions and seek advice. In some instances it may simply be a case of
confirming that the action we intend to take is the right one and in line with Diageo’s purpose
and values. In others, it may be that we believe something to be taking place which is in
breach of the Code or Diageo policies or may even be illegal.
In any of these instances we should speak up. Where we believe there to be a violation
of the Code, Diageo policies, or the law, we have an obligation to report the matter promptly
through one of the routes described in this document. This is the case even where we do not
necessarily have all the facts, as long as the report is made in good faith.
Guidance is given throughout the Code as to who you can ask for further information or advice
on particular subjects. On all matters you can go to your line manager to ask for help, raise an issue,
or check on the right course of action.
There may be occasions where you would prefer to speak to someone else in the first instance.
In such situations, you can contact the Global Compliance & Ethics team, Legal or HR teams.
The Global Compliance & Ethics team is there to answer your questions and can provide
advice on who to contact regarding a particular subject. You can also contact them directly to
report matters about which you are concerned. The team work closely with all other Diageo
functions and will know who to inform or consult further on any matter you raise. They can be
contacted on [email protected].
INT
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Getting help & advice
None of us knows the answer to every question or what to do in every situation – we all need help and advice
Q
Contents
8
A
Q
A
I don’t want to bother
my line manager with lots
of questions. What things do I
really need to talk to him about?
Your line manager is there
to help you with any matter
related to the Code and Diageo
policies on which you would
appreciate advice or if you are
unsure about the right thing
to do.
Where you believe that a law,
regulation or policy is or may
be being broken you must
report this. Your line manager
is generally your first point of
contact in such cases. However,
there are other channels
available to you – the Global
Compliance & Ethics team,
Legal or HR teams, or SpeakUp
– if circumstances are such that
you would prefer to speak to
someone else.
I’m thinking of contacting
SpeakUp about something
happening in my team but I’m
worried my line manager will
find out it was me who made
the report. Will he be told?
Each report made
through SpeakUp is
handled confidentially. When
you make a report you are
given the option to remain
anonymous. However,
disclosing your name is likely
to make it easier to conduct a
thorough investigation. Your
name will be kept confidential
unless we are required to
disclose it as a result of legal
proceedings or a government
investigation.
Diageo will not tolerate any
retaliation against an individual
for raising a concern, making
a report or assisting in an
investigation.
Ge
tting
he
lp &
advice
SpeakUp is a resource for all of us to use to raise areas of concern about compliance and
ethics matters, or to make a report when we think a policy or law is being broken, or when
something doesn’t feel right.
SpeakUp is managed by an external company, independent from Diageo, with staff who
are trained to deal with your call, and translators who are immediately available to assist
if required.
Issues to report can include knowledge of, or reasonable suspicion of, violations of legal,
accounting or regulatory requirements, breaches of the Code or Diageo policies, or any
questionable conduct or practice.
Telephone numbers for SpeakUp and details of alternative ways of contacting the service can
be found in the Contacts section of this document and on the Diageo intranet.
If you feel more comfortable doing so, you can call anonymously. If you give your name,
it will be kept confidential unless required to disclose it as a result of legal proceedings
or a government investigation.
When you contact SpeakUp, the external company will promptly send a confidential report
to Diageo’s Global Compliance & Ethics Director who will follow up and ensure the issue
is appropriately investigated. You will be given a unique report number which you can use
to check on the action being taken in response to your report. Dependent on the nature
of the issue, a formal investigation may be initiated.
Diageo will not tolerate any reprisal for reporting a problem or assisting in an investigation.
Anyone found to be involved in retaliation against an individual who has raised a concern
will be subject to disciplinary action.
The important thing is to speak up.
We are all expected to:• Speak up if we are unsure what to do in a situation and ask for help and guidance from
our line manager or relevant Diageo team.
• Always report promptly anything which we believe to be unlawful or in breach of the
Code or Diageo policies.
• Forward reports which we receive of potential or actual breaches to the Global Compliance
& Ethics team who will provide guidance and support and initiate an appropriate response.
Getting help & advice (continued)
Diageo SpeakUp
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How should I handle
situations not covered
by the Code?
You may face situations
which are not explicitly
covered by the Code and
you are unsure of the correct
course of action to take. In such
situations it can be helpful to
ask yourself some questions:
• Is the action legal?
• Does it support
Diageo’s values?
• Could it expose Diageo
to unacceptable risk?
• Does it comply with the
spirit of the Code and
Diageo policies?
• How would it appear to
others – your line manager,
colleagues or family?
• Would you be comfortable
if it was reported in
a newspaper?
• Does it feel right?
If you still have concerns,
seek guidance – from your line
manager, Global Compliance &
Ethics team, Legal or HR teams
or contact SpeakUp.
Q
A
Our purpose and values drive the way we work and define our business principles which are
inherent in everything we do, every day, everywhere. We are committed to:
• conducting our business in accordance
with all relevant laws, regulations and
industry standards
• complying with all laws and regulations
governing the import and export of
our products, including those related to
customs, tax, duty free sales, embargoes
and anti-boycott requirements
• conducting business in a manner which
is honest, sincere and trustworthy
• acting in a truthful and co-operative manner
in all government or legal investigations
or those conducted internally
• monitoring and reporting on our
compliance with all relevant laws,
regulations and industry standards
• ensuring every non-wholly-owned
subsidiary and joint venture which
Diageo controls adopts a code of business
conduct and policies aligned with
those of Diageo
• encouraging our partners in the joint
ventures that we do not control to meet
the requirements of the Code in both the
joint venture and their own operations
• expecting our agents, representatives and
consultants to comply with the Code and
Diageo policies and report any violations
• actively encouraging our suppliers to
meet the requirements of the Code and
Diageo policies in their own operations.
We are all expected to:• Learn about and comply with the laws, regulations and Diageo policies which apply to our job.
• Always seek advice and guidance if we are unsure about the course of action to take
and encourage others to do the same.
• Be alert to and report any issues or potential violations to our line manager, Global
Compliance & Ethics team, Legal or HR teams or contact SpeakUp.
• Never judge or retaliate against an individual who raises an issue, reports a violation
or participates in an investigation.
Th
e w
ay we
wo
rk
The way we work
Embrace Diageo’s values; be proud of what we do and act with integrity
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OUR PRODUCTS
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Q
You can get further advice and support regarding marketing and promotional activities from your line manager,
Marketing team, Corporate Relations team or Global Compliance & Ethics team.
The Diageo Marketing Code and the Digital Code of Practice contain further information and guidance
on this subject.
Don’t forget, you can always discuss concerns or make a confidential report using SpeakUp.
Q
A
A
I’ve been working on a marketing campaign for a new product. I’m concerned that some of the things we are saying are not entirely accurate. Should I raise the issue or not worry about it?
You should express
your concerns to your line
manager. No matter how small
or insignificant the inaccuracy
may appear it could be very
damaging to Diageo’s reputation.
We have a responsibility to our
consumers to ensure that our
marketing is always truthful
and accurate.
I have received a small
number of complaints both
internally and from the public
that a recent local advertising
campaign is culturally insensitive.
I don’t agree. Should I just
ignore them?
No, notify your line manager
and your Corporate
Relations team who will help to
determine the best course of
action. In addition, as a matter
of course, any Diageo business
that receives criticism of its
marketing activities should
inform the Diageo Corporate
Relations team in London
immediately.
Digital media, such as websites, email and mobile phones provide us with new and dynamic
ways to market to our consumers. The core principles of the Diageo Marketing Code apply
equally to digital marketing and more traditional methods. To provide further guidance, the
Digital Code of Practice has been developed to address specific standards for all of Diageo’s
digital and promotional marketing activities.
We are all expected to:• Apply the Diageo Marketing Code and Digital Code of Practice to all marketing and
promotional activities.
• Ensure all marketing activities are in keeping with both the letter and the spirit of all
applicable national laws.
• Follow the approval process for all marketing activities as specified by our Diageo business
unit and as detailed in the Diageo Marketing Code.
• Pay special attention to applying both the Diageo Marketing Code and Digital Code
of Practice to digital advertising and promotional activities.
• do not target consumers under legal
purchase age
• do not depict alcohol consumption in
unsafe situations or before/during any
activity that requires concentration
• do not encourage or condone excessive
or irresponsible consumption
• do not use high alcoholic content as a
dominant theme
• do not associate our products with violence,
anti-social behaviour or offensive themes
• do not promote alcohol as a medicine, or
suggest that it enhances performance or
sexual attractiveness, or is a requirement
for social acceptance or success.
We are proud that our brands bring pleasure to millions of adults every day, all over the world,
playing a unique part in the social lives and celebrations of many cultures.
We are also passionate about our consumers and we recognise that alcohol beverages may be
consumed irresponsibly, creating problems for the individual and for society. We must ensure
that our brands are advertised and marketed responsibly.
The Diageo Marketing Code applies to all of our activities that communicate about and market
our brands. Central to it are that we:
Marke
ting
& in
no
vation
OU
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Marketing & innovation
We want Diageo’s marketing and promotionalactivities to be recognised as the best in the world
Contents
12
Q
You can get further advice and support regarding quality matters from your line manager or the Global
Compliance & Ethics team.
The Diageo Quality Policy contains further information and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confidential report using SpeakUp.
A
Q
A
We have received a
report from a supplier
that contamination may
have occurred in a recent
shipment of ingredients. The
products which contained the
ingredients have already been
shipped to the customer. We
have no definite evidence of
contamination. Do we need
to recall the products?
We have a duty to respond
promptly to any concerns
about product quality or safety,
even if that requires the recall
of products. You should raise
the issue immediately with
your line manager who will
determine the appropriate
course of action.
I work on the production
line and I’ve noticed
some defective finished goods
that are not within our normal
tolerance levels. I’ve mentioned
it to my line manager but he
has told me not to worry as the
defect is minor. Is he right?
No, he is not right.
We strive to achieve the
highest standards in everything
we do. We want our customers
to enjoy the best products we
can produce and even a small
defect could compromise this
and potentially do damage
to our reputation. You should
contact the Global Compliance
& Ethics team directly or
call SpeakUp to report your
concerns.
We want to be the best and are passionate about ensuring our products are consistently
of the highest quality. Our consumers should be able to trust in the quality, safety and purity
of our beverages.
The Diageo Quality Policy applies to all Diageo brands and associated products and covers
all aspects of the supply chain from vendors to consumers.
The standards set out in the policy apply to all Diageo businesses and joint ventures
and should also be referred to when dealing with third party contractors and suppliers.
All our vendors must meet our Quality Risk Management Standards. We mark our products
to allow traceability throughout their storage and distribution.
To ensure that we can properly respond to consumer enquiries and concerns, all Diageo
businesses must have a consumer contact system and procedures to facilitate recall
of products from consumers and resellers if necessary.
All our sites are expected to drive improvements in quality performance, reduce quality
risks and ensure regulatory compliance through the application of the Diageo Quality
Policy and standards.
We are all expected to:• Adhere to the Quality Risk Management Standards where they apply to our work.
• Always strive to ensure that our brands and associated products are safe for our employees,
customers and consumers.
• Ensure that business partners, including vendors and third party producers are managed
according to the Diageo Quality Policy.
• Follow the quality management system as implemented within our business unit or location.
• Demonstrate our commitment to our core values, ‘Be the Best’ and ‘Passionate about
Consumers’ through an unremitting focus on quality in everything we do.
Quality
We are committed to enhancing and protecting our brands through application of the highest quality standards
Qu
alityO
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Q
You can get further advice and support regarding international trade & free zone sales from the Legal team
or Global Compliance & Ethics team.
The Diageo Customer Management Guidelines contain further information and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
A
Q
A
There is parallel product
in my market (sometimes
called grey market product –
product that has not been sold
in the market by the in-market
Diageo company or a local
Diageo distributor). Can I tell
customers where they can
buy some?
No, our employees and
agents must not be
involved in the delivery
or sale of parallel product.
We have a lot of parallel
product in our market. I
would like to instruct Diageo’s
free trade zone distributors
not to sell to customers who
might end up re-exporting
the product to my market.
Our free zone distributors
are required to comply
with all applicable laws and
to adhere to the terms of their
contracts with Diageo. As long
as they abide by all legal and
contractual requirements,
Diageo employees should
not instruct our free zone
distributors where our
products should or should
not go.
We comply with all laws and regulations governing the import and export of our products,
including those related to customs, tax, duty-free sales, embargoes, and anti-boycott
requirements. Likewise, Diageo requires our free trade zone distributors, who sell our products
for general re-export out of the country where their free zone is located, to comply with all
applicable laws and regulations.
Diageo products – like those of many other consumer goods companies – are sometimes
smuggled into markets by third parties without full payment of duties. Our people must not
manage, promote, or otherwise allow themselves to become involved in this trade.
You can get further advice and support regarding international trade and free zone sales from
the Legal team or the Global Compliance & Ethics team.
The Diageo Customer Management Guidelines contain further information and guidance
on this subject.
We are all expected to:• Comply with all laws and regulations governing the import and export of our products.
• Never manage, promote, or otherwise allow ourselves to become involved in the
smuggling trade.
• Seek guidance from the Legal team if in any doubt as to our commitments in regard to
international trade & free zone sales.
International trade & free zone sales
Sales to Diageo customers must be in full compliance with applicable laws
Inte
rnatio
nal trad
e &
free
zon
e sale
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PERSONAL INTEGRITY
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Gifts & entertainment
The gifts & entertainment we give or receive should never create improper influence or give the impression of doing so
A
Q
A
You can get further advice and support regarding the giving and receiving of gifts and entertainment from your
line manager, Legal team or the Global Compliance & Ethics team.
A Gifts & Entertainment Register template can be downloaded from the Diageo intranet or is available
from the Global Compliance & Ethics team.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
I would like to buy a gift
for a supplier. I think it
will be difficult and time-
consuming to organise the
purchase through Diageo. Is it
okay if I buy the gift using my
own money and then claim it
back on expenses?
Any gifts or entertainment
given or received must
not only be recorded in your
Gifts & Entertainment Register
but also properly accounted
for within the appropriate
company records. Even if you
choose to buy the gift at your
own expense and not claim
this back, you are still offering
the gift in your capacity as a
representative of Diageo. You
must therefore ensure that you
seek the prior approval of your
line manager if required and
that the expense is properly
recorded.
I have been invited to
the wedding of the
daughter of a local government
official. In my culture it is
expected that guests will give
cash gifts at the wedding.
Given the circumstances is
a cash gift acceptable?
Diageo is a global company
and we will encounter
cultural differences to which
we have to be sensitive.
However, providing cash gifts
is prohibited regardless of the
circumstances. It exposes the
company and our employees
to unacceptable risk. Offering
an appropriate non-cash gift
may be acceptable in these
circumstances but you must
discuss the matter with the
Legal team and get their prior
written approval before giving
any gift.
The giving and receiving of gifts and entertainment have a role to play in building business
relationships and generating goodwill. However, they should never create improper influence
or obligate the recipient. We should not provide or accept excessive or inappropriate
entertainment and must only ever offer or accept gifts of modest value.
Reasonable business-related entertainment that is conducted in the interests of Diageo can be
provided or accepted if it is modest and occasional. You should seek your line manager’s prior
approval before accepting or offering any entertainment which could be regarded as excessive.
We must never offer or accept gifts of cash or cash equivalents such as gift certificates, loans,
stock, or stock options.
Gifts that we give should be of nominal value and preferably display a Diageo brand. Diageo
discourages the acceptance of gifts by employees, except where this is clearly related to
a business purpose. You must inform your line manager if in any 12 month period, you intend
to give or receive:
• gifts exceeding a value of £100* to or from any one entity or
• gifts exceeding a value of £250* in total.
Particular caution should be applied in any dealings with government officials. No gifts or
entertainment may be given to, or paid for on behalf of, any government or military official,
without the prior approval in writing of the Legal team.
We each have a responsibility to keep a record of the gifts and entertainment which we
give or receive. This does not include nominal value items, such as promotional items or
working meals. Local policy will determine the cost threshold for recording items. A Gifts &
Entertainment Register template can be downloaded from the Diageo intranet or is available
from the Global Compliance & Ethics team. Registers will be regularly reviewed to ensure they
are up to date and accurate.
* Or a lower value as specified by the Diageo Regional President as being appropriate for a particular country.
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We are all expected to:• Ensure details of all gifts and entertainment that we either give or receive are recorded
on a Gifts & Entertainment Register.
• Report to our line manager any gifts or entertainment offered to us that exceed the values
specified above, or lower values applicable in our country.
• Always consider whether the gifts or hospitality being given or received could lead to
or imply any obligation.
• Consider the customer’s, supplier’s or other third party’s policies regarding the acceptance
of gifts or entertainment before offering them.
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I have built up a good
relationship over the
years with one of our suppliers
and I’ve been asked if I’d be
interested in investing in the
company. I think it would be
a good investment as I’ve
been impressed by their high
standards. Is there any conflict
of interest here?
This may be a conflict of
interest depending upon
the nature of your role and the
level of influence you have in
selecting suppliers. You should
discuss the situation with
your line manager or Global
Compliance & Ethics team
before committing to
any investment.
My nephew is looking
to move jobs and there
is an open position within my
team for which I think he would
be perfectly suited. I’m worried
about suggesting him though,
given our relationship. What
should I do?
If you feel that your
nephew is well qualified
for the position and would
be a good addition to
the department you are
encouraged to mention this to
the hiring manager or relevant
HR contact. However, you
should have no involvement
in the recruitment process and
the position should not be one
which you directly supervise.
We all owe a duty of loyalty to Diageo. Where our personal, social, financial or political activities
interfere or could interfere with our loyalty to the company, a conflict of interest may exist.
Even the appearance of a conflict of interest can be damaging.
Conflicts of interest can arise in many ways and we should always consider carefully situations
in which our loyalty may be divided.
The activities of family members or close relatives can cause conflicts. If a relative works for
a customer, supplier or competitor, you must disclose this to your line manager. You should
never be in a situation where you are able to hire, supervise, or affect the terms and conditions
of a close relative.
Outside employment and affiliations can result in conflicts of interest, for example, serving as
an officer or director, or acquiring or maintaining an ownership interest in a customer, supplier
or competitor of Diageo.
Improper use of company assets can also be regarded as a conflict of interest. This may
occur when an individual deliberately uses Diageo property or information for personal
benefit or for the benefit of family or friends. Equally, using Diageo property or technology
irresponsibly or for more than incidental personal use is in conflict with the interests
of the company.
Many actual or potential conflicts of interest can be resolved in an acceptable way for both
the individual and the company. The important thing is to highlight the potential conflict to
your line manager, Global Compliance & Ethics team or the Legal team so that an appropriate
course of action can be agreed.
We are all expected to:• Avoid situations where our personal interests may conflict with those of Diageo.
• Always disclose any conflicts of interest or potential conflicts of interest to our line manager.
• Never use our position within Diageo for personal benefit or to benefit a family member.
• Safeguard and use Diageo assets appropriately.
Conflicts of interest
We must not allow personal or family interests to lead us to do anything which is against the best interests of Diageo
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You can get further advice and support regarding confl icts of interest from your line manager, Legal team,
or the Global Compliance & Ethics team.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
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I am PA to one of the
directors within the
company and as such I have
access to quite a lot of
confidential information,
although I don’t tend to read
any of it in detail. I’d like to sell
some of my Diageo shares
but one of my colleagues
suggested that I might not be
able to because I have access
to ‘inside information’.
Is this true?
If you have information
which is not generally
available to the public and
which could affect the
share price or influence an
investor, you may have inside
information. However, it is not
always the case that non-public
information would be regarded
as inside information. You
should ask your line manager,
Company Secretarial or Legal
team for advice.
I know that I am
in possession of inside
information and therefore am
at times restricted in buying or
selling Diageo shares. However,
my brother has mentioned that
he’d like to buy some shares
in Diageo. I never talk to him
about my work so is this okay?
You should be cautious
in this situation and
be clear that there is no
information you have ever
disclosed to your brother
which could be viewed as
inside information. You should
discuss the situation further
with Company Secretarial or
the Legal team.
Trading on the basis of ‘inside information’, often known as ‘insider trading’ or ‘tipping’
is a criminal offence in the UK, US and many other countries.
Information about any listed company which is not generally available to the public and which
could affect the market price of the securities of that company is inside information. Equally,
anything to which a reasonable investor would attach importance in deciding whether to buy,
sell or retain such securities, is also inside information, if it is not publicly known.
It is each individual’s responsibility to ensure that they do not breach insider trading rules.
The Diageo Dealing in Securities Code exists to help ‘insiders’ in this.
You must not buy or sell Diageo securities (stock or bonds) or those of any other listed company
if you are in possession of inside information. Nor should you ask another person to do so on
your behalf or advise others to do so on the basis of such information.
In addition, you should never be involved in spreading false information or engaging in activities
designed to manipulate the price of publicly listed securities, known as ‘market abuse’.
If you have what may be inside information and are considering trading in a Diageo security
you should contact Company Secretarial or the Legal team for advice.
We are all expected to:• Never buy, sell or engage in any other dealings in Diageo securities while being in
possession of inside information. This applies even after leaving Diageo’s employment.
• Never engage in any dealings involving any other company while in possession of inside
information or confidential information about that company.
• Never engage in market abuse by spreading false information or engaging in other activities
designed to manipulate the price of publicly listed securities.
• Refer to the Diageo Dealing in Securities Code and seek guidance from Company
Secretarial or the Legal team before trading in Diageo securities, if there is a possibility
of being in possession of inside information.
Insider trading
We must not trade Diageo or any other securities on the basis of ‘inside information’
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You can get further advice and support regarding insider trading issues from your line manager, Company Secretarial,
the Legal team or the Global Compliance & Ethics team.
The Diageo Dealing in Securities Code contains further information and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
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You can get further advice and support regarding issues of bribery and improper payments from your line
manager, the Legal team or the Global Compliance & Ethics team.
The Diageo Anti-bribery & Corruption Guidelines contain further information and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confidential report using SpeakUp.
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I was told I have to pay
a gratuity to a minor
government official to get
our products cleared through
customs. We are under
pressure to get the delivery
to the customer as soon as
possible and it’s not against
the law in my country.
What should I do?
Diageo must not provide
gratuities to officials to
ensure execution of official
duties. The UK Anti-terrorism,
Crime & Security Act makes
it illegal to pay ‘facilitating’
or ‘grease’ payments for UK
companies. Even in countries
where these payments are not
against the law, Diageo strictly
prohibits them. Seek the advice
of your line manager or the
Legal team to determine legally
acceptable alternatives to
secure the release of the goods.
I’ve been told that the
best way to get the
permits I need from a foreign
government is to hire a
consultant to take care of it for
me. I’ve met him and he’s asked
for $50,000 as a retainer. Do I
need to worry about what he
does with it, as long as we get
the permits?
Yes, you have a
responsibility to ensure
that anyone acting on Diageo’s
behalf is not engaging in
bribery or making improper
payments. You must be able to
account for the monies being
spent and ensure that they are
being used for legitimate and
legal purposes.
Diageo will not condone, under any conditions, the offering or receiving of bribes or any other
form of improper payments, including what are known as ‘facilitating payments’. Even the
appearance of a breach of anti-bribery or anti-corruption laws could do significant damage to
Diageo’s reputation. You should exercise particular care in dealings with government officials
to ensure there can be no suggestion of impropriety.
You should not give or promise anything, for example, money, services, gifts, excessive
entertainment or loans that are or could be construed as intending to influence the decision
of customers, suppliers, government officials or political representatives. In addition, Diageo
will not permit the use of intermediaries, agents, subsidiaries or joint venture companies
to give, or promise to give anything to such people on behalf of Diageo or yourself.
No payments, gifts or entertainment may be given to, or paid for on behalf of, any government
or military personnel or other official without the prior approval in writing of the Legal team.
We must never offer gifts of cash or cash equivalents, such as gift certificates, loans, stock,
or stock options to anyone.
Most countries have laws which make it illegal to engage in bribery and corruption. Diageo is
listed on the UK and US stock exchanges and consequently, all of our operations, regardless
of their location, are subject to certain UK and US legislation, in addition to any local laws and
regulations. A breach of any of these laws is a serious offence which can result in fines for the
company and imprisonment for individuals.
US authorities apply the US Foreign Corrupt Practices Act (FCPA) to non-US firms, such as
Diageo, that issue publicly traded securities in the US. The law prohibits the bribery of foreign
officials and Diageo employees must comply with the provisions of the FCPA in all countries
in which Diageo operates. Contravention of the Act can result in severe penalties for the
company and for individuals.
Diageo companies across the world are also subject to the UK Anti-terrorism, Crime & Security
Act which makes it illegal to pay ‘facilitating’ or ‘grease’ payments. These are small payments
or gifts given to a government official in order to get the official to do something legal, for
example, release a cargo shipment where all the paperwork is in order and there is no legal
reason for the official to delay the release.
It is important to recognise that any improper activity or suggestion of improper activity in any
country in which Diageo operates can have implications for Diageo globally. If you are in any
doubt as to the appropriateness of a payment, or transfer of anything of value, which you are
considering making or authorising you should contact the Legal team or Global Compliance
& Ethics team before acting.
Bribery & improper payments
We must never offer or accept money or anything of value to induce or reward favourable treatment for Diageo
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You can get further advice and support regarding issues of bribery and improper payments from your line
manager, the Legal team or the Global Compliance & Ethics team.
The Diageo Anti-bribery & Corruption Guidelines contain further information and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confidential report using SpeakUp.
Brib
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imp
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We are all expected to:• Never offer or accept bribes, including ‘facilitating payments’ or any other form of
improper payments.
• Never make, offer or promise to make a payment or transfer anything of value, including
the provision of any service, gift or entertainment, to government, military personnel or
other officials, without the prior written approval of the Legal team.
• Never solicit or accept any gift, payment or other advantage from any person
in return for providing any improper business or other advantage.
• Never do anything to induce or facilitate someone else to breach these standards and
always report any violations or suspected violations.
Bribery & improper payments (continued)
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I bumped into the
Marketing Director of a
competitor at a conference and
we got talking. He asked me
how we were finding the market
and whether we thought we
could increase prices this year.
What should I do?
You have to be very clear
with the individual that
you are not prepared to discuss
pricing or anything else of a
confidential commercial nature.
In negotiations with a
large customer they made
it clear that they will not accept
any price increase from us until
they know when they will see
retail price increases on the
shelves in other retailers.
What should I do?
Explain that you will not
discuss the confidential
terms or pricing plans of their
competitors and that to do
so would be illegal. If the
customer persists, you should
contact the Legal team who
can help to resolve the issue.
Diageo operates within the laws and regulations of each country in which we operate. This means
that we must comply with all anti-trust and competition laws which apply to our business.
These laws which regulate dealings with competitors, customers, distributors and other third
parties are different around the world. Depending on where you work, the laws that apply to
you may vary.
It is important to be aware that these laws can cover conduct outside the country. For
example, some competition laws, such as the US and EU anti-trust laws, can apply even when
the conduct occurs outside the borders of the relevant country or countries.
The penalties for breaching competition and anti-trust laws can be severe with large fines
and potentially prison sentences for those convicted of anti-competitive behaviour.
You must familiarise yourself with and always follow the guidelines on competition and
anti-trust laws for your particular market.
In addition, we should always deal honestly and fairly with all our consumers, suppliers,
employees, competitors and other stakeholders. We should not misrepresent material facts
or use deceptive practices to gain unfairly.
CompetitorsCompetition laws around the world prohibit agreements with or soliciting of agreements
with a competitor to fix prices, set any terms of sale, production levels, divide up markets,
customers or territories, or to boycott any customer. Such communication with competitors
through intermediaries (customers, suppliers or consultants) is also prohibited.
Contact with competitors in the context of social engagements, trade associations or industry
advertising codes must not involve discussion of the areas highlighted above.
Trade associations must never be used as a forum to agree a common approach to a customer or
devise an ‘industry solution’ to a commercial issue such as pricing, discounts or promotions.
In gathering competitive information, always follow the Diageo Know the Competition
Guidelines and always comply with applicable laws. Do not seek or accept confidential
information from competitors. You must not use deception, misrepresentation, or inducement
to encourage customers, suppliers or former employees of competitors to provide information
that they should keep confidential.
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Competition & anti-trust
We must adhere to all laws intended to protect and promote free and fair competition around the world
You can get further advice and support regarding competition and anti-trust issues from your Legal team,
Procurement team or the Global Compliance & Ethics team.
The Diageo Competition & Anti-trust Guidelines contain further information and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confidential report using SpeakUp.
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CustomersMany countries prohibit any attempt to agree resale prices, fix a minimum price or incentivise
customers to follow pricing recommendations. In addition, certain countries prohibit or limit
a supplier from imposing conditions of sale that can exclude competitive products or limit
a customer’s scope of resale.
Diageo purchases goods and services from suppliers who may also be customers of the
business. This is normal business practice but we must never pressure suppliers to buy our
products in order to become or remain a supplier.
You must follow your local guidelines and the advice of your Legal and Procurement teams
to ensure you understand what practices are acceptable.
We are all expected to:• Familiarise ourselves with and always follow the Competition and Anti-trust Guidelines
for our particular market.
• Never talk with or share information, directly or indirectly, with competitors to fix prices or
other terms of sale, set production levels, divide up markets, customers or territories, or to
boycott any customer.
• Never discuss with competitors details of pricing, costs, profits, margins, trading terms,
marketing and distribution plans or new product launches.
• Always report to the Legal team any instance where a competitor has raised with you any
of the subjects described above, either formally or informally.
Competition & anti-trust (continued)
You can get further advice and support regarding competition and anti-trust issues from your line manager,
Legal team, Procurement team or the Global Compliance & Ethics team.
The Diageo Competition & Anti-trust Guidelines contain further information and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confidential report using SpeakUp.
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One of our customers has
asked if he can pay through
a mix of different accounts
using a combination of cash
and cheques. Is this okay?
You should be especially
careful with these sorts
of transactions as it could
indicate money laundering.
Remember that Diageo cannot
accept cash in excess of £5,000
(UK)/$10,000 (US) for any one
sales transaction or series of
related sales transactions, nor
can we accept third party
cheques. Inform your line
manager or Legal team before
responding to the customer.
We have a customer
we know well and have
been dealing with for many
years without any problem.
I recently asked them to
update their information but
it hasn’t been forthcoming.
Should I be concerned?
Yes. Although there
may be an innocent
explanation, you cannot be
certain. We need to keep
our customer data current
to avoid opening Diageo up
to involvement in any illegal
activity. Notify your Legal and
Finance teams if you are not
able to verify a customer’s data
at least once every six months.
Mo
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Money laundering is the criminal practice of filtering money which has come from illegal
activities through a series of transactions in order to ‘clean’ it and give it the appearance of
being from legitimate sources.
Each Diageo business unit must have ‘Know your Customer’ procedures to determine the
identity and legitimate operations of customers, and maintain procedures to prevent
acceptance of suspicious payments. This specifically includes payments with currency
in excess of £5,000 (UK)/$10,000 (US) for any one sales transaction or series of related sales
transactions, money orders, travellers cheques, or payments from accounts in the names
of third parties, i.e. from anyone other than the invoiced customer.
It is the responsibility of local management to ensure that Diageo conducts business in accordance
with all local legal requirements, including compliance with any currency reporting requirements.
The Legal team can give you further advice on our Anti-Money Laundering Policy.
Knowing your customer is a continual process and, as a minimum, customer data must be
reviewed every six months.
We all need to be vigilant of circumstances that may indicate improper transactions, for
example, a customer who is unwilling to provide personal or business background information
or a customer who wishes to pay with large amounts of cash or appears unconcerned with
price, or other terms and conditions of purchase.
We are all expected to:• Ensure we follow the ‘Know your Customer’ processes detailed in the Diageo Anti-Money
Laundering Policy.
• Bring to the attention of the Legal team any suspicious transaction that may contravene
Diageo’s Anti-Money Laundering Policy.
• Be alert to any changes in customer details, circumstances and profiles and notify these
to the Finance team.
• Conduct business in accordance with any local legal requirements, including any currency
reporting requirements.
Money laundering
We comply with money laundering prevention laws and do not condone, facilitate or support the laundering of ‘dirty money’
You can get further advice and support regarding anti-money laundering from your line manager, Legal team
or the Global Compliance & Ethics team.
The Diageo Anti-Money Laundering Policy contains further information and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
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I’ve been travelling a lot
with work recently and
I’ve lost some of my receipts.
I’ve heard of colleagues in the
same position adding a few
fictitious receipts of the same
value to make sure they don’t
end up out of pocket. I’m sure
this is okay, isn’t it?
No, it’s not okay. It means
that the expense reports
are inaccurate which ultimately
results in inaccurate accounts.
The fact that you are aware
of others acting in this way
does not make it acceptable.
You should talk to your line
manager to discuss a resolution
to your current situation and
also highlight your concern
that this may be common
practice. In future, take care
to ensure you keep your
receipts safe.
We are approaching
the end of our reporting
period and my line manager
has asked me to offer to pay a
couple of our customers to buy
product now rather than in the
next period. I don’t think it will
have any negative impact on
the customer to bring these
purchases forward. Is this okay?
No. Using aggressive
marketing to increase
sales in a period is okay but
practices that effectively
shift the next period’s sales
to the current period for the
purpose of meeting targets
is not acceptable. There may
be legitimate reasons for both
Diageo and our customers to
wish to increase levels of stock
outside of normal trade but
such activity must always
be driven by clear
commercial reasons.
We must ensure that any data, information or records which we create or for which we are
responsible are correct and accurate. Such information can take many forms, ranging from the
Diageo Annual Report to our personal travel and expense claims.
Honest, accurate and objective recording and reporting of information, financial and non-
financial, is required not only to meet legal and regulatory requirements but to fulfill our
responsibilities to our shareholders and the public and to enable us to make informed decisions
about our business.
We must comply with all laws and external accounting standards and ensure that the
information we supply to Diageo’s auditors, regulatory agencies, and government
bodies is accurate, complete and provides a true and fair view of the financially reported
period. All transactions and contracts must be properly authorised and accurately and
completely recorded.
Accurate reporting of Diageo’s financial information includes appropriate recognition of sales
and profit. Any activity aimed at artificially inflating or shifting sales or profit between reporting
periods may result in a misrepresentation of our position and is unacceptable.
We must ensure that we act with complete integrity in our travel and expense claim submissions.
Claims must be compliant with the relevant local policy, relate to legitimate business expense
and be accurate. Any falsification of expense claims will be treated extremely seriously.
We must never make a false or misleading entry into any report, record or expense claim.
Falsifying records and accounts or misrepresenting facts may constitute fraud and in addition
to disciplinary action, could result in civil and criminal penalties for the individual and Diageo.
We are all expected to:• Create and maintain complete and accurate accounts, data and records.
• Be vigilant in identifying and reporting any potential misrepresentation of Diageo accounts,
data or records or any incidence of potential fraud or deception.
• Demonstrate integrity and diligence in submitting our travel and expense claims
and in approving those of others.
• Ensure that any contractual commitments which we make on behalf of Diageo are within
the scope of our delegated authority.
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Accurate reporting & accounts
The financial and non-financial information we create and maintain must be true, complete and accurate
You can get further advice and support regarding accurate reporting & accounts from your line manager, Finance team or
the Global Compliance & Ethics team.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
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I found some documents
left in a meeting room
that contained the salary details
of my colleagues. I don’t want
to get anyone into trouble but
I think people need to be more
careful with information like
this. What should I do?
If it is clear where the
documents came from
you should return them as
soon as possible to the relevant
owner by confidential means
or, if not possible, to HR. You
also have a duty not to disclose
any confidential information you
may have inadvertently read.
It will be my colleague’s
50th birthday next week
and I’d like to send her a
surprise gift. I asked HR for her
home address as I wanted to
get it delivered rather than
carry it into work. I was told
that wasn’t possible due to
data privacy laws. Is this right?
Yes, it is. Diageo has an
obligation to protect the
privacy of all employees and
although it may be that your
colleague would have no
objection to you obtaining her
home address for this purpose,
the HR team cannot make this
judgement on her behalf and
as a result must decline
your request.
You can get further advice and support regarding data privacy from your line manager, Legal or IS teams or the
Global Compliance & Ethics team.
The Diageo Global Data Privacy Policy contains further information and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
• fairly and lawfully obtained and managed
• processed only for limited or stated
purposes
• accurate, relevant and not excessive
• not held for longer than is necessary
• processed in line with an individual’s rights
• securely stored
• not transferred to other countries without
adequate protection.
We are all expected to:• Only use personal data to which we have access for Diageo business related reasons
and ensure its use is fair and lawful.
• Ensure we comply with all applicable local data privacy laws and other requirements
referred to above in addition to the Diageo Global Data Privacy Policy.
• Ensure that individuals who provide personal data are made appropriately aware of who
will have access to the data and for what purpose.
• Refer to the Legal team all formal statutory or regulatory requests or complaints by
individuals to access personal information relating to them.
• Ensure that any copying or distribution of personal data (e.g. to third parties) is necessary.
Do not initiate significant data processing activities (such as direct marketing) without
considering data privacy implications.
• Make use of training materials and advice and participate in privacy compliance checks
as required from time to time.
Diageo holds personal data about employees, customers and suppliers, consumers and other
individuals, including prospective and former employees. In particular, this information is held
in email systems, HR and marketing databases. We must respect the confidential nature of any
personal data we gather and we have a responsibility to keep it secure.
Each Diageo business unit and third party that collects and processes personal data on
Diageo’s behalf must comply with our Global Data Privacy Policy and all other relevant policies,
guidelines, binding rules and procedures. In some countries, compliance with data privacy
regulations is required by law and any failure to do so can result in financial and criminal penalties
for the individual and Diageo. We may implement additional policies or guidelines in order
to satisfy local data privacy laws and regulations.
Personal data which we hold must only ever be used for Diageo business purposes and we
must ensure it is:
Data p
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Data privacy
We apply the highest standards in protecting the personal information that we collect in our business activities
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EMPLOYMENT
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27
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I’m organising a meeting
for our team at an out of
office venue and I’m currently
developing the agenda. I’ve
been told that I need to go
through the emergency
procedure information at the
beginning of the meeting.
It doesn’t sound like a very
exciting way to start. Is it
really necessary?
Yes, it is. We have a
responsibility to ensure
safe and secure working
conditions for all our
employees when on Diageo
business even if this business is
conducted outside of Diageo
premises. Spending a few
moments outlining the fire
and evacuation procedures for
the venue will help to protect
your colleagues should an
emergency occur.
I recently tripped on some
loose floor covering. I
didn’t hurt myself but someone
told me I should report it
anyway. However, I don’t want
to jeopardise our safety record.
What should I do?
You should always bring
to the attention of your
line manager, Occupational
Health & Safety Officer or
local Facilities team, any near
misses or hazards that could
have caused an accident. By so
doing, we can rectify problems
before they can cause serious
accidents and ensure a safe
working environment for all.
You can get further advice and support regarding health, safety and security from your line manager, Occupational
Health & Safety Offi cer or local Facilities team.
The Diageo Occupational Health & Safety Policy and Diageo Physical Security Policy contain further information
and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
We are all expected to adopt a proactive, co-operative attitude towards the health, safety
and security of Diageo employees, customers and suppliers, and others working at or visiting
Diageo property. It is our intention that everyone goes home safe, every day, everywhere.
All our operations must be conducted in compliance with applicable health and safety laws
and regulations, company standards and best practice in workplace health, safety and security.
We take all reasonable and practical steps to ensure that the premises where our employees
operate are secure and provide a zero harm working environment.
Each of us should be aware of applicable Diageo safety programmes and safety and health
regulations and be appropriately trained for our role, in order to conduct our activities in a safe,
healthy and responsible manner.
We will act to mitigate risks which arise from deliberate or accidental breaches in our physical
security or threats to our people.
We are committed to continual improvement in our Occupational Health & Safety Policy
management and performance and we monitor our progress against health and safety
objectives, targets and best practice to ensure this.
We are all expected to:• Follow the Diageo Occupational Health & Safety Policy and Diageo Physical Security Policy,
as applied to our location and type of work.
• Challenge unsafe behaviours of others in a timely manner to demonstrate that unsafe
behaviours are unacceptable.
• Promptly report accidents, incidents, near misses, non-compliance with regulations or
anything else posing a risk to health, safety and security.
• Understand the hazards associated with our own job and those associated with our
colleagues’ jobs. Manage the risks responsibly and ensure any required health and safety
training has been completed.
• Integrate health, safety and security considerations into our day-to-day working activities.
• Make sure we know what to do if an emergency occurs at our place of work.
Health, safety & security
Each of us should behave in a manner that promotes a positive safety culture and openly challenge unsafe behaviour
He
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I’ve been asked to
undertake interviews
for a role within my team. In
my mind I’m clear that the
job could not be done by a
young female as it involves
travel to countries where the
environment is challenging.
However, two of the candidates
are young females. Should
I turn them down without
interview?
By doing so you would
be not only breaching
Diageo’s Global Resourcing
Policy but potentially also
breaking the law. If the young
female candidates have the
ability and are qualified to
perform the role, you must
not discriminate against them
and should interview them
and consider them for the role
without regard to their age
or gender.
My line manager can
be very intimidating and
sometimes even personally
insulting to people in my team.
I know he has high standards
and wants us to perform well
but it is impacting the morale
of the team and a couple of
people are talking about leaving.
I’m worried that if I report it, I
might just make the situation
worse. What should I do?
Behaving in a bullying
and intimidating way
is unacceptable, regardless
of the circumstances or an
individual’s position within the
organisation. You should raise
the matter with your team’s HR
contact, the Global Compliance
& Ethics team or you can use
SpeakUp to make a report.
Diageo will not tolerate any
reprisal against an individual
for raising an issue or making
a report in such situations.
You can get further advice and support regarding discrimination or harassment issues from your line manager,
HR team or the Global Compliance & Ethics team.
The Diageo Global Resourcing Policy and the Diageo Human Rights Policy contain further information
and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
As Diageo employees we all have the right to expect that our dignity and human rights will be
respected and that we will be treated fairly in carrying out our work.
In all aspects of employment, we will treat individuals justly, solely according to their abilities
to meet the requirements and standards of their job. We must do so without regard to factors
such as race, religion, colour, ethnic or national origin, disability, sexual orientation, gender, age
or marital status. We will make reasonable job-related accommodation for any employee with
a disability when notified that this is required.
We will not tolerate employees being subjected to physical, sexual, racial, psychological, verbal,
or any other form of harassment or abuse. Diageo will ensure procedures are in place to detect
failures to live up to this standard and to deal with them swiftly and effectively.
We recognise the diverse skills and contributions of our workforce and will ensure that
individuals are justly and fairly remunerated for their contributions to the company.
We acknowledge and promote a healthy balance between employees’ working and home life
and respect the commitments they have outside of the work environment.
We are all expected to:• Ensure we do not discriminate against any individual or group based on factors which
are irrelevant to their ability to do their job.
• Never engage in any form of harassment or abuse, or any behaviour that could be viewed
as offensive, intimidating, malicious or insulting.
• Support and promote Diageo’s commitment to diversity, individual contribution and
a fair and harassment-free workplace.
• Ensure that consumers, suppliers and other business partners are aware of Diageo’s
commitment to diversity and equal opportunity.
Discrimination & harassment
We value diversity and are committed to a respectful and fair working environment for all
Discrim
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We recently went away
as a team and stayed at
a hotel. After dinner in the bar
one of my colleagues drank too
much and started behaving
rudely towards the hotel staff.
I was embarrassed as were
others who were with me. Her
line manager had left earlier
and so didn’t witness the
incident. Should I just
keep quiet about it?
No, you should not. As
employees of Diageo
we have a duty to be role
models for the responsible
use of alcohol. Inappropriate
behaviour of this kind could be
highly damaging to Diageo’s
reputation and is treated
extremely seriously. You should
report the matter to your
line manager or HR team, or
alternatively contact SpeakUp.
One of my colleagues is
regularly calling in sick,
disappearing and is making
mistakes in his work. He insists
everything is fine but I have
reason to suspect he may have
an alcohol problem. I want to
help but am worried that it’s
none of my business. What
should I do?
Such situations can be
uncomfortable and it
often feels easier to ignore
the situation and hope it
improves. However, this is
probably not in the best
interest of the individual or
Diageo. Discuss your concerns
with your line manager if you
feel comfortable doing so or
contact SpeakUp.
You can get further advice and support regarding responsible drinking from your line manager, Corporate
Relations team or the Global Compliance & Ethics team.
The Diageo Employee Alcohol Policy contains further information and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
Celebrating life, every day, everywhere, is at the heart of Diageo. We believe that our brands
can play a positive role in society when enjoyed responsibly and Diageo is at the forefront
of industry efforts to promote responsible drinking. Our approach is based on the following
key principles:
• to set world-class standards for responsible marketing and innovation
• to combat alcohol misuse, working with others on initiatives to reduce alcohol-related harm
• to seek to promote a shared understanding of what it means to drink responsibly.
We collaborate with other leading drinks companies and industry-funded organisations
around the world to help remind consumers to drink responsibly at all times.
We are committed to ensuring that as employees we understand the nature and effects of
alcohol. We are ambassadors for our brands and can enhance Diageo’s reputation by showing
a responsible attitude to drinking. In contrast, if we drink irresponsibly or commit offences
related to the misuse of alcohol, we put Diageo’s reputation at risk.
We have a global programme for all employees on the enjoyment and responsibility of
drinking, which is called DRINKiQ. DRINKiQ.com is Diageo’s global resource to help combat
alcohol misuse and promote information on responsible drinking through the sharing of best
practice tools, information and initiatives. These two initiatives are part of Diageo’s intention to
raise our collective drink intelligence.
The Diageo Employee Alcohol Policy defines appropriate behaviour and covers topics such
as alcohol and the workplace, drinking and driving, enforcement and problem drinking.
We are all expected to:• Behave in a way that enhances our corporate reputation. We are proud of our products
and of the way we carry out our business. We need to be mindful of this reputation and
show a responsible attitude to drinking.
• Ensure that our performance at work and judgement are never impaired by alcohol.
• Always obey the drink-drive legislation in our market and never put ourselves or others
at risk by drinking and driving.
• Seek medical advice or counselling from an occupational health centre or from an external
agency, if dealing with an alcohol related problem.
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Responsible drinking
We are committed to ensuring our consumers and employees understand the nature and effects of alcohol
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COMPANY ASSETS
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I was recently on holiday
and saw in a local shop
a product which looked so
similar to a Diageo one that I
initially mistook it for being our
brand. I think people who don’t
know our brands as well as me
could be confused. Should I do
anything about it?
Yes, protecting our brands
is critical to maintaining
our reputation and the
goodwill of our customers. If
possible, you should buy the
product and pass this and
other relevant details to the
Legal team immediately on
your return. However, you
should not compromise your
safety and security in any way
and should never identify
yourself as a Diageo employee
in such a situation.
A couple of my friends
had one of our products
in a bar recently and both
thought it didn’t taste right.
Should I report this?
Yes, you should report
the matter through
Operation Copycat or
contact the Legal team or
Global Corporate Security
team directly so that they
can investigate further.
Infringements of our products
can take many forms and it is
possible that the product may
have been tampered with or
could have been a counterfeit.
We have an obligation to
protect both our consumers
and our brands.
You can get further advice and support regarding brand protection from your line manager, the Legal team
or the Global Compliance & Ethics team.
The Operation Copycat intranet site contains further information and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
Intellectual property laws protect Diageo’s valuable assets – our trademarks, copyrights,
patents, trade secrets, domain names, and related rights. These assets assure our consumers
that the Diageo products they buy are genuine.
Trademark and related laws protect our brands. Copyrights protect our communications,
unique advertising messages and designs. Our trade secrets, such as recipes, distilling
processes, price lists and customer lists, enable us to offer consumers unique products and
provide a competitive advantage in the marketplace. Our patents protect our inventions, such
as our unique technologies and production methods.
Infringing products are products that lead consumers to mistakenly confuse them with, or
falsely link them to, Diageo products. These can range from similarly named and/or designed
alcoholic beverages, to unrelated products using similar names, logos, packaging shapes,
trade dress, colours or designs. Counterfeit products are products that claim, falsely, to be
one of our products. They often re-use (refill) or copy our packaging. The contents of these
products are often inferior and can sometimes even be dangerous.
We all need to be alert to and report any suspected counterfeit or product infringements
promptly so that we can take action and limit any potential negative impact on Diageo.
The Operation Copycat intranet site provides further information on reporting suspected
counterfeit or product infringements.
If you are involved in developing products, advertising or promotion campaigns you should
contact the Legal team before any details are published or any samples or products are shown
to the public or to suppliers.
As we expect our intellectual property rights to be respected, we must respect the intellectual
property of other organisations.
We are all expected to:• Report any potential infringements through the Operation Copycat intranet site
or directly to the Legal team.
• Always consult the Legal team regarding securing Diageo’s rights when working
with suppliers to create intellectual property on our behalf.
• Ensure we do not use any names, designs or other materials that a consumer might
associate with another organisation or their brands without first seeking the advice
of the Legal team and obtaining permission if required.
• Never download, copy, distribute, post on a website or use any materials covered by
another person’s or organisation’s copyright without obtaining permission.
Brand protection
We must protect Diageo’s brands and intellectual property rights and avoid infringing the rights of others
Bran
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I’ve recently started
working for Diageo.
My uncle works in the same
industry and is keen to talk
about the differences and
similarities between our two
companies. I’m excited about
working for the company and
want to talk about it but how
much can I say?
You should be cautious
even with a close member
of your family. We want you
to talk about Diageo and
be an ambassador for the
company but you can do that
without revealing confidential
information. Ask yourself
whether the information you
are sharing is available to the
general public through the
media, our websites or our
marketing and promotional
information. If not, you should
not discuss it with anyone
outside of Diageo.
I’ve just joined Diageo
from a competitor
and brought with me lots
of information which I think
would be useful to the
company. Given that it relates
to work with which I was
involved personally, is it okay
to share it with my new team?
Not if the information
is of a confidential nature.
Even after you have left the
company the information
remains confidential if it is not
publicly available. You have
been hired on the basis of your
experience and expertise not
for the confidential information
to which you have access.
You can get further advice and support regarding the treatment of confi dential information from your line manager,
the Legal team, the Global IS team or the Global Compliance & Ethics team.
The Diageo Global Information Security Policy contains further information and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
Many of us have access to confidential information through the work we do. This could
include business plans, financial data, details of innovation, marketing or sales programmes,
new products, merger or acquisition activity, senior management changes or a range
of other information.
We should never share Diageo’s confidential information with non-Diageo employees, unless
those third parties are bound by confidentiality obligations. This applies even if we leave
Diageo and for as long as the information is not generally available to the public. Internally,
we should consider carefully with whom we share confidential information, restricting it to
those that need to know in order to carry out their work. In this way we can avoid inadvertent
disclosures outside the company.
Diageo classifies its information in accordance with the information’s sensitivity and value. The
four classifications of information are Diageo Public, Diageo Internal, Diageo Confidential and
Diageo Top Secret. All information that is not in the public domain must be labelled as Diageo
Internal, Diageo Confidential or Diageo Top Secret.
We must also respect the confidential information of others. We should never seek to obtain
or disclose the confidential information of other companies, whether it comes to us directly
or from third parties.
We are all expected to:• Never discuss confidential information with non-Diageo employees, unless those third
parties are bound by confidentiality obligations.
• Be mindful of the unintentional disclosure of confidential information through conversation
or the use of documents in public places.
• Notify the Legal team immediately if we become the recipient of the confidential
information of another company.
• Never accept, solicit or divulge confidential information from or about any third party,
including customers.
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Confidential information
Proper protection of our confidential information is vital to protecting Diageo’s brands, reputation and business
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I am going on holiday
and someone will
temporarily cover my role.
As it is only for two weeks it
doesn’t seem worth getting
her a network user ID and
password as she can just use
mine. Is this okay?
No, you should never
share your user name
and password even if it seems
that this would be the most
efficient thing to do. Not
only does it breach Diageo
policy, but it potentially puts
you at risk if someone acts
inappropriately while using
your username and password.
Plan ahead and ask your IS
team to create a new user
name for the individual before
you go on holiday.
I am going to be travelling
a lot over the next few
weeks and don’t really want
to have to take my laptop. I
know I’ll be able to get access
to my personal email over
the internet so can I just set
up a rule in my Diageo inbox
to forward all my email to my
personal address?
No, you should not
forward Diageo emails to
a personal address when you
do not know the content. Emails
could contain confidential
information normally protected
by the Diageo digital security
systems, which would not be
the case with your personal
email account.
You can get further advice and support regarding information systems usage and security issues from your line
manager, the Global IS team or the Global Compliance & Ethics team.
The Diageo Global Information Security Policy contains further information and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
Information security
We must be diligent in protecting the security of Diageo’s information systems and the information stored on them
Info
rmatio
n se
curity
Lack of diligence by an individual can lead to a breach of our information security affecting
the whole company. Everyone who uses the Diageo digital systems – employees, contractors,
consultants and other people with temporary access – must ensure that these resources are
used appropriately and in line with our Global Information Security Policy.
Diageo’s digital resources, including systems, software, office equipment, telephone and email
services are intended to be used for conducting Diageo’s business. Incidental or occasional
personal use of such assets is acceptable so long as it does not interfere with you performing
your job.
However, you should not expect privacy if you conduct personal business using company
resources. Diageo may monitor the use of its telephones, computers and email systems and
see the information that you create or exchange with others.
We must all follow the guidance provided in the Global Information Security Policy related
to computer usage, password and access codes, security measures and information handling.
We are all expected to:• Never share our username or password.
• Ensure we do not access, download, create or forward email, documents or images
that may cause offence or distress to other persons.
• Ensure we do not install or use, hardware or software on any Diageo system that has
not been specifically approved by the IS team.
• Ensure we do not send confidential information to a non-Diageo email system without
additional protection as specified in the Global Information Security Policy.
• Always save important data on the network based drives for reasons of data security
and data recovery.
• Ensure that all our personal data maintained in Diageo’s systems, such as the Global
Directory and Diageo One is current and accurate.
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My email inbox is full and
I can’t send or receive
any more mail. I don’t have
the time to go through each
email and I’ve got documents
I need to send urgently. I’ve
decided to delete all the emails
with attachments as these are
taking up the most space. This
is the best solution, isn’t it?
No, you need to review
what you retain and what
you delete against the records
retention schedule relevant for
you. In future, try and manage
your email more effectively.
File documents as you receive
them and regularly review what
can safely be deleted based on
your retention schedule.
I’ve inherited documents
and emails from my
predecessor which could have
been destroyed as their normal
retention period has expired.
Now I’ve heard there might
be a legal case and I’m not
sure they’d be helpful so I’m
thinking of destroying them
before it starts. Is this okay?
No, it is not. Whether
or not the legal case
has started or you have been
contacted by our lawyers, you
must preserve information
that could be relevant, even if
in normal circumstances, you
could have destroyed it, in
accordance with our policies.
In this situation, destroying or
altering records can have very
serious consequences. Consult
the Legal team for further advice.
You can get further advice and support regarding records management from your line manager, Legal team,
the Records & Information Management Compliance team (contact [email protected]) or the
Global Compliance & Ethics team.
The Diageo Global Records Retention Policy, individual business units’ policies and the Diageo Communication
and Document Production Guidelines contain further information and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
Records management
Our records must be correctly managed to satisfy legal and regulatory requirements and protect Diageo’s interests
Re
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Our records contain valuable information for use by the business and to provide evidence of
our actions, decisions and obligations. Records can be documents and data in many formats
and media, including paper, film and electronic, and may be held within IT systems and
computers as well as in offices and stores. We must ensure that the records for which we are
responsible are correctly managed, from creation to disposal, including those held for us by
third parties.
Whenever we create, collaborate on or communicate data and records we must exercise care,
and follow the Diageo Communication and Document Production Guidelines and appropriate
confidentiality, privacy and security requirements.
We are required by laws, regulations and business requirements to retain records for certain
periods of time depending on their nature. The Diageo Global Records Retention Policy and
individual policies, procedures and schedules applicable to each business unit explain the
legal and business requirements relating to the retention of our records.
It is very important that records (including email) relating to pending litigation or a regulatory
investigation are not destroyed, even if they would be normally. Our Legal and Tax teams will
notify relevant employees when this happens and their instructions must be followed carefully.
We are all expected to:• Ensure that we maintain complete and accurate records for the business activities for
which we are responsible.
• Understand and follow the Records Retention Policy, procedures and schedules relevant to
our records, including the Diageo Communication and Document Production Guidelines.
• File records correctly (both paper and electronic), transfer them to storage if and when
appropriate, and review them regularly to identify those due for disposal in
accordance with policy.
• Comply fully and immediately with any legal requirement to suspend normal disposal of
records (and other information sources) because of litigation or a regulatory investigation.
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EXTERNALACTIVITY
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I have just received
an invite to speak at an
industry conference. I think it
would be a great marketing
opportunity for Diageo. I’d like
to accept. Do I need to check
with anyone first?
Yes, you should discuss
the invitation with your
line manager and Corporate
Relations team before accepting.
You should always be careful to
seek the appropriate approvals
when you are representing
or seen to be acting as a
spokesperson for Diageo.
I read an article in a
newspaper the other day
which stated certain things
about Diageo‘s business that
I know are wrong. Should I
contact the newspaper to
correct them?
No. You should always
be alert to reporting
about the company which is
incorrect or misleading, but it is
not your responsibility to seek
to correct such inaccuracies.
You should raise the matter
with your line manager or
contact the Corporate
Relations team directly.
You can get further advice and support regarding external communications from your line manager, Corporate
Relations and Investor Relations teams or the Global Compliance & Ethics team.
The Diageo Global Communications and Media Guidelines contain further information and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
Everything we do, everything we say, and everything our key stakeholders say about us defines
Diageo’s business reputation. Our stakeholders are identified as our employees, investors,
consumers, the media, our communities, government and commercial partners – including
suppliers and customers.
Each of us has regular contact with one or more of these stakeholder groups in undertaking
our daily work. However, it is important that in doing so the Diageo Communications and
Media Guidelines are followed and the advice of the Corporate Relations team or the Investor
Relations team is sought where appropriate.
Management of Diageo’s day-to-day relations with the media are managed by the Corporate
Relations team – globally and in the markets – which owns and manages contacts with
government, media, employee and community stakeholders. Investor interaction is managed
by the Investor Relations team. We must direct all media and investor enquiries to these teams.
The Diageo Global Communications and Media Guidelines provide further information on our
approach to managing communications with our stakeholders.
We are all expected to:• Refer all media enquiries to the appropriate authorised person or Corporate Relations team.
• Avoid speaking to the media unless specifically authorised to do so.
• Avoid acting as a spokesperson for Diageo, its people, brands or performance, without first
consulting a member of the Corporate Relations team.
• Ensure all media announcements and press releases are approved in advance by an
appropriate member of the Corporate Relations team.
• Refer any approach by an investor or financial analyst to the Investor Relations team.
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External communications
It is crucial that our communications with stakeholders are managed according to Diageo communications and media guidelines
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A former colleague is
standing as a candidate
for local government and is
having a fundraising dinner.
He’s asked if some of my
colleagues and I would like
to take a table at the event.
Is this okay?
Diageo respects the
right of its employees to
personally support political or
charitable activities as long as
this activity is not associated
with Diageo. You are at liberty
to attend the dinner in a
personal capacity. However,
if a group of employees
attend the event it could be
misinterpreted that Diageo is
supporting the candidate and
so it would be best to avoid
such a situation.
I’ve been contacted by a
government committee
and asked to attend a hearing
as an expert witness. What
should I do?
You should notify your
line manager and contact
the Corporate Relations team
promptly who will advise you
how to respond. If you do
attend, the Corporate Relations
and Legal teams will support
you in preparing for the hearing.
You can get further advice and support regarding political activity from your line manager, Corporate Relations team
or the Global Compliance & Ethics team.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
As part of doing business, Diageo engages with governments, public interest groups, industry
associations and a broad range of other similar bodies around the world. In doing so, we must
ensure we comply with all laws governing political activity.
We must not engage in lobbying or have contact with legislators, political candidates,
regulators, government employees or public-interest groups without the direction of the
Corporate Relations team and where appropriate the Legal team.
None of us should make payments on Diageo’s behalf to political candidates or parties or
to support political activities, except in very special circumstances and with the prior approval
of the Global Corporate Relations Director and the Global Compliance & Ethics Director. Always
seek guidance from the Corporate Relations team.
Diageo recognises each employee’s right to participate as an individual in political activities.
However, these activities must be kept separate from the workplace. Diageo funds or resources
must not be used to support such activities without the prior approval of the Global Corporate
Relations Director and the Global Compliance & Ethics Director.
In particular, Diageo disassociates itself from any political or religious activity that incites
extremism or undermines our commitment to cultural diversity and equal opportunity.
We are all expected to:• Talk to the Corporate Relations team or Legal team before engaging in contact with
government, regulators, legislators or lobby groups on Diageo’s behalf.
• Never make payments to political parties or candidates on Diageo’s behalf without prior
approval from the Global Corporate Relations Director and the Global Compliance
& Ethics Director.
• Keep personal political activities separate from work activities and do not use company
time or resources to support them.
• Consider if any personal political activity could be open to the misinterpretation that
it is undertaken on Diageo’s behalf.
Political activity
We should not engage in contact with government orpolitical organisations or individuals on Diageo’s behalf without approval
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A customer has asked if
Diageo would be prepared
to offer some office space
to host an event they are
organising for a charity as their
premises are not sufficiently
large. Can I agree?
You should speak to
your line manager and
business unit head before
making any commitment.
Diageo encourages the
support of community and
charitable activities but it is
important to ensure alignment
with Diageo criteria particularly
given that the request has
come via a customer.
I’m involved with a
programme to support
local schools in helping children
to improve their reading. They
are currently looking for new
volunteers and I am thinking of
asking my colleagues whether
they would like to get involved.
Is this okay?
We want to encourage
employees to pursue
issues which are important to
them and their communities.
In everything we do we must
take care that our actions
are not misinterpreted as
an attempt to market our
products to those under legal
purchase age. If you are in any
doubt consult your local
Corporate Relations Director.
You can get further advice and support regarding community & charitable activity from your line manager,
Corporate Citizenship team, local Corporate Relations team or Global Compliance & Ethics team.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
Diageo’s business activities directly affect the lives of millions of people around the world.
This brings a responsibility to ensure that all those with a stake in Diageo can benefit from
the relationship. Being socially responsible and investing in our communities is at the heart
of being ‘proud of what we do’.
Inherent in our Code is the belief that countries and communities in which we operate should
benefit from our presence. We believe that by being active and caring about the communities
where we operate we can best meet our social responsibilities and bring about positive change.
Diageo is committed to investing in community programmes. However, we should not make
charitable or community contributions on Diageo’s behalf without the approval of the Global
Corporate Relations Director. Appropriate criteria must be used to select the charity and
decide the amount of the donation. In addition, care must be taken to ensure compliance
with accounting and tax requirements.
The Diageo Corporate Citizenship team provide expertise and support to our business units
on Diageo’s community investment programme, including focus areas and funding criteria.
While financial contributions are important, active involvement can often achieve much more
in our communities, whether through the time and skills of our people or supplying surplus
products and other ‘in-kind’ resources.
We encourage the involvement of all employees in community initiatives because it not
only benefits each project but also fosters team spirit and enhances individuals’ capabilities
and experience.
We are all expected to:• Reflect Diageo’s care for and commitment to the communities in which we operate in
undertaking our work.
• Seek the prior approval of the Global Corporate Relations Director before making
charitable contributions on Diageo’s behalf.
• Take particular care when considering making charitable or community donations
at the request of customers or business partners.
Community & charitable activity
We are committed to playing an active and positive role in our communities and we encourage employees to do the same
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I heard informally that
one of our suppliers is
under investigation for using
forced labour. We haven’t heard
this from the supplier and I’m
not aware of any previous
problems. Should I ignore
the rumours?
No, Diageo will investigate
the matter further even
though the rumours may turn
out to be wrong. Talk to your
line manager, Procurement
team, Global Compliance &
Ethics team or Legal team
who will advise on the
appropriate action.
We are considering
working with a supplier
but we are concerned that
the wages they pay to their
employees, are below the
normal level for the industry.
The supplier has agreed to
address this if they are awarded
the contract. Given this
commitment, is it okay to
go ahead?
Diageo expects its
suppliers to pay fair
wages in line with the norms
for the industry and market
and not to require anyone
to work excessive hours,
particularly where this might
impact personal health or
safety. You should raise the
issue with your line manager
and seek guidance from
the Procurement team or
Corporate Citizenship team on
the appropriate action to take.
You can get further advice and support regarding human rights issues from your line manager, Procurement team,
the Corporate Citizenship team, local Corporate Relations team or Global Compliance & Ethics team.
The Diageo Human Rights Policy and Diageo standards on Partnering with Suppliers contain further information
and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
Diageo recognises its responsibility under the Universal Declaration of Human Rights to use
our influence to promote and protect human rights and to ensure that our business operations
do not contribute directly or indirectly to human rights abuses.
The Diageo Human Rights Policy sets out the principles and standards we apply to our
employees, consumers of our products and the communities within which we operate. We also
recognise international labour standards as set out in the International Labour Organization’s
(ILO) conventions and recommendations.
We seek to establish and adhere to clear ethical standards for ourselves and expect similar
standards in all third parties who act with us or on our behalf. In particular, we expect our
suppliers to meet all applicable legislation and ratified ILO conventions and recommendations,
and the requirements set out in the Diageo standards on Partnering with Suppliers.
Diageo does not make use of forced or compulsory labour. We will employ people under
the age of 18 only in compliance with local law and UN Global Compact guidelines. For any
Diageo employee under the age of 18, we will pay particular attention to their vocational
training and development needs.
We respect the right of employees to join or not to join trade unions, and generally to join
together for the purpose of promoting common goals.
We are all expected to:• Always respect the human rights of those with whom we work and come into contact
as Diageo employees.
• Encourage partners, suppliers and other third parties to adopt similar standards with
respect to human rights.
Hu
man
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ts
Human rights
We have a responsibility to promote and protect human rights and freedoms in everything we do
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I am passionate about
environmental issues and
I question why we don’t do
more to reuse and refill bottles
in the market in which I work.
Why is this?
Diageo recognises that
waste occurs when
consumers dispose of our
bottles, cans and other
containers. Our marketing
teams and agencies follow
guidelines intended to
balance the functionality of
our packaging with a need to
minimise its environmental
impact. Refillable glass bottles
may be environmentally the
best solution in some cases,
for example, for beer which
is consumed near where it
is brewed. However, they
may not be economically
sustainable for spirits shipped
between countries or at risk
from counterfeiters.
My business unit has
instigated an initiative
to encourage us to only print
documents when necessary. I
prefer to look at things in hard
copy rather than on the screen
so won’t be following this
approach. Is this okay?
Diageo respects the
environment and seeks
through a range of initiatives
to minimise its environmental
impact. Reducing our usage
and waste of materials is one
of the ways of doing this.
Although you may prefer to
operate in a certain way, we all
have a responsibility to try to
change our behaviours where
required to support Diageo’s
environmental strategy.
You can get further advice and support regarding environmental matters from your line manager,
Corporate Citizenship team, local Corporate Relations team or Global Compliance & Ethics team.
The Diageo Environmental Policy and Diageo standards on Partnering with Suppliers contain further
information and guidance on this subject.
Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.
We aim to achieve continuous improvement in environmental performance, concentrating our
efforts on areas of greatest impact at our manufacturing, distribution and large office sites.
We seek to comply with the spirit as well as the letter of applicable environmental laws and
regulations with regards to the environment. Where none exist, we set ourselves appropriately
high standards.
Throughout our operations, we will consider the environmental implications of every major
business decision that we make. In doing so, we seek to support environmental sustainability
and biodiversity.
We are committed to driving down the environmental impact of our operations through the
efficient use of resources, transport planning, the reduction of waste and emissions and the
careful handling of hazardous substances.
We will educate and motivate our employees to conduct activities in an environmentally
responsible manner and we encourage our business partners, suppliers and contractors to
do the same.
We engage our key stakeholders, including employees and communities, in dialogue on our
environmental programmes and monitor our performance against best practice to ensure
continuous improvement.
Our environmental standards apply to all locations and aspects of our business.
We are all expected to:• Demonstrate a commitment to the environmental standards as outlined in the Diageo
Environmental Policy and the Diageo Annual Corporate Citizenship Report.
• Support local environmental sustainability initiatives such as energy saving
or waste reduction programmes and challenge unsustainable activities if they occur.
• Work with our suppliers to develop appropriate environmental management systems
which reflect Diageo’s commitment to reducing the environmental impact of the supply
chains of which we are a part.
Enviro
nm
en
t
Environment
We are committed to operating in an environmentally responsible way to protect and enhance our people, brands and the communities in which we work and live
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Contacts & links
Co
ntacts &
links
Guidance is given throughout the Code as to who you can ask for further information or advice
on a particular subject. On all matters you can go to your line manager to ask for help or raise
an issue.
You can contact the Global Compliance & Ethics team to ask for advice on who to speak
to regarding a particular issue. You can also report to the team matters about which you
are concerned.
Global Compliance & Ethics team8 Henrietta Place
London W1G ONB
United Kingdom
Tel: +44 (0) 20 7927 5200
Email: [email protected]
The Code & Diageo policiesThe Code of Business Conduct is available in the following languages, copies of which
can be downloaded from the Diageo intranet or are available from the Global Compliance
& Ethics team:
CO
NTA
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• French
• Spanish
• Italian
• Portuguese
• Hungarian
• Polish
• Dutch
• German
• Russian
• Greek
• Turkish
• Thai
• Japanese
• Chinese (Traditional)
• Chinese (Simplified)
• Korean
• Vietnamese
All the policies referred to in the Code and other Diageo policies and guidelines, which may
be relevant to your job, can be found on the Diageo intranet.
43
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SpeakUp
Global number: +44 (0)1249 661792
Email: [email protected]
Internet: www.expolink.co.uk/whistleblowing-hotline/for-employees.htm
CO
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If there is not a freephone
number listed for your
country, please use the
reverse charges global
number provided at the
top of this page.
Local freephone numbers:
Argentina: 0800 666 2603
Australia: 1800 121 889
Austria: 0800 281700
Belgium: 0800 71025
Brazil: 0800 891 8807
Bulgaria: 008001104474
Canada: 1888 268 5816
Chile: 12300200412
China: 00 800 3838 3000
Colombia: 01800 944 4796
Croatia: 0800 222 845
Cyprus: 800 95207
Czech Republic: 800 142428
Denmark: 8088 4368
Eire: 1800 567 014
Egypt: 0800 000 00 23
Estonia: 8000044265
Finland: 0800 116773
France: 0800 900 240
Germany: 0800 182 3246
Greece: 00800 441 31422
Hawaii: 1866 293 2604
Hong Kong: 800 930770
Hungary: 06800 14863
Iceland: 8008279
India: 000 8004401286
Indonesia: 001 803 0441 1201
Israel: 180 944 6487
Italy: 800 783776
Japan: 00531 78 0023
Korea (South): 00308 442074
Latvia: 80002670
Lithuania: 880030444
Luxembourg: 8002 4450
Malaysia: 1800 807055
Malta: 800 62404
Mexico: 01800 123 0193
Netherlands: 0800 022 9026
New Zealand: 0800 443 816
Norway: 800 14870
Philippines: 1800 1442 0076
Poland: 00800 441 2392
Portugal: 800 880 374
Puerto Rico: 1866 293 1804
Romania: 08008 94440
Russia: 10 800 2058 2044
(restricted coverage)
Singapore: 800 4411 140
Slovakia: 0800 004461
Slovenia: 0800 80886
South Africa: 0800 990520
Spain: 900 944401
Sri Lanka: 011 244 5413
(omit 011 if dialling from Colombo)
Sweden: 0200 285415
Switzerland: 0800 563823
0800 563012
Taiwan: 0080 104 4202
Thailand: 001 800 442 078
Turkey: 00800 4463 2066
UK: 0800 374199
United Arab Emirates: 80004413873
USA: 1877 533 5310
Venezuela: 0800 100 3199
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44
Diageo plc
8 Henrietta Place
London W1G 0NB
United Kingdom
Tel +44 (0) 20 7927 5200
Tel +44 (0) 20 7927 4600
www.diageo.com
Registered in England
No. 23307