Chapter 4: Our business integrity
We avoid and disclose conflicts of interest
The Nestlé way
Nestlé is a company full of motivated and vibrant people with relationships and engagements outside our work lives.
However, if our personal interests compete with the interests of Nestlé, conflicts of interest may occur. In those situations, it can be difficult to fulfill our responsibility to act fully in the best interest of Nestlé. Even the appearance of a conflict may damage Nestlé’s reputation and compromise others’ confidence in our company.
Even the appearance of a conflict may damage Nestlé’s reputation and compromise others’ confidence in our company.
How we live it, every day
- Be transparent and honest about conflict-of-interest situations. Where conflicts exist, appear to exist, or where they may develop, disclose them promptly to your people manager or Legal and Compliance following local procedures so the conflicts can be managed.
- Do not let your decisions at Nestlé be influenced by personal considerations, such as outside activities, financial interests or personal relationships. Withdraw from any decision-making process if you think your judgment may be compromised.
- Pursue outside activities only if they do not interfere with your responsibilities at Nestlé or create risk for the company.
Putting our Code to the test
Q. A vacancy has opened up in Nestlé and my cousin is ideally qualified for it. May I recommend them for the role?
A. If your cousin has the qualifications, skills, and experience for the role, then yes, you may suggest them for the position. Make sure to disclose your relationship to avoid any appearance of a conflict and ensure you are not involved in the hiring process. If they get the position, you should also ensure that you don’t have a direct or indirect reporting relationship. If it’s an indirect reporting relationship, appropriate mitigation measures might be required.
More to know
There are many situations which can present potential conflicts of interests. Learn to recognize conflicts so you can avoid them and if they occur, disclose them promptly through the conflict-of-interest procedure.
Outside directorships or external positions: This may include serving other organizations as a board member, advisory member, officer, employee, partner or consultant.
These may be acceptable as long as they don’t interfere with our responsibilities nor create risks for Nestlé’s reputation and interests, and with prior authorization from your Market Head or Head of GMB/functional unit. Board memberships on publicly listed companies need prior approval from the CEO. Executive Board members must seek prior approval from the CEO, Chairman and the Nomination Committee of the Board.
Families and close associates: Families and close associates: This may include hiring or promoting family members, partners or close associates within Nestlé. It could also include engaging, or wishing to engage, with a business partner in which any of these works or has a financial interest. It could also occur when any of these works for a direct competitor.
We must declare all these situations and withdraw from any decisions involving such relationships. The declarations will be assessed, and managed through appropriate mitigation measures.
Direct reporting relationship between family members, partners and close associates is not allowed. Indirect reporting lines must be declared and assessed on a case-by case basis.
Every decision we make at Nestlé should be fair and transparent, following approved procedures with no preferential treatment given based on personal interests, including the interests of family members, partners or close associates.
Business opportunities: This may include pursuing paid work with a competitor, customer, supplier or business partner or taking personal advantage of business opportunities with Nestlé or other ventures discovered during employment.
Each of us must be fully committed to advancing Nestlé’s business. In no instance should we engage in ventures which compete with the company, directly or indirectly. A new business opportunity discovered in the course of your work with Nestlé must be informed to your people manager. You may be authorized to pursue it independently if Nestlé waives its right to do so and if doing so will not conflict with your existing responsibilities or compete with Nestlé. You must also inform your people manager if you wish to be considered as a supplier to Nestlé through a separate personal business.
Financial interests: This may include having a substantial financial interest in a competitor, supplier or other Nestlé business partner. Before taking any financial interest of this kind, declare it and request approval.
Other outside activities: This may include receiving payments or fees from suppliers, customers, business partners or other third parties for providing information, or participating in events or speaking engagements.
Our expertise, know-how and experience are among our most valuable assets at Nestlé. While participation in events and speaking engagements can have a positive effect on Nestlé’s reputation and allows us to engage with others on important issues, avoid accepting fees or payment for such appearances when you are participating as a representative of Nestlé. If you are participating in a business-related event in a personal capacity, notify your people manager and ensure your participation does not create reputational risks for Nestlé. Never share proprietary information.
Ask yourself
Ask yourself these questions if you’re unsure about whether you are in a potential conflict-of-interest situation:
- Will I, family members or close associates receive any unearned benefit or advantage from this situation?
- Could it look like a conflict of interest to someone else?
- Could this situation affect my judgment in any way?
- Would I feel uncomfortable if my colleagues, my manager or the public knew about this situation?