Chapter 4: Our business integrity
We prohibit bribery and corruption
The Nestlé way
Nestlé has zero tolerance for bribery and corruption. We adhere to anti-bribery laws and our anti-corruption commitments under the UN Global Compact. We succeed based on our brand value, the quality of our products, our competitiveness and our sustainability performance, not by trying to obtain improper advantages.
We do not offer or promise to pay bribes, nor do we allow agents, intermediaries or other third parties to do so on our behalf. Similarly, we never accept anything of value in return for preferential treatment. Our business partners must comply with anti-bribery laws and submit to our due diligence procedures, as per the Nestlé Responsible Sourcing Core Requirements and our Corporate Business Principles.
No matter where we operate or what the situation is, we conduct business with the utmost integrity. Our zero tolerance for bribery and corruption applies even where local law is more lenient, and stricter local laws or procedures take precedence where they exist.
Our business partners must comply with anti-bribery laws and submit to our due diligence procedures.
How we live it, every day
- Be aware of bribery and corruption risks in your part of the business and stay alert to interactions which could look unethical to others.
- Never offer or promise any personal or improper advantage, financial or otherwise, to influence a decision from a third party, nor accept anything of value in return for an improper favor. This includes indirect kickbacks or payments to family members or other close associates.
- Ensure all business and financial transactions are properly recorded, classified, and documented. This includes gifts, entertainment, hospitality, scholarships, grants, sponsorships and charitable contributions.
- Be cautious when dealing with government officials or public sector employees. Facilitation payments to secure or ‘fast track’ routine administrative actions may also be bribes and are not acceptable.
Putting our Code to the test
Q. My department has hired a consultancy firm to provide ‘strategic advice’ on the regulatory environment in a new market we are entering. The services described in the contract are minimal and generic, with no specific deliverables or timeline, yet the success fees are substantial and to be paid irregularly. What do I do?
A. Vague consulting agreements can be used to disguise illicit payments. Without clear deliverables, it is difficult to measure the actual service provided, making it easier for unethical and illegal behavior to go undetected. Report your concerns to your people manager, Legal and Compliance or Speak Up.
Hear something? Say something
- “Let’s keep this between us.”
- “We can sort this out with a special arrangement.”
- “I’ll need something extra to expedite this process.”
- “A donation will put you at the top of the list.”
Secret commissions, financial favors, job offers, gifts or political donations all can be bribes in disguise. If it sounds like an improper favor, it probably is. Report it, immediately
Resources
Click for more information and internal resources.
Talk to your people manager, Human Resources or Legal and Compliance, or report your concerns through our Speak Up platform.
If you have questions about our Code, talk to your people manager or Legal and Compliance.
More to know
Q. Can we make political donations?
A. Election laws in many jurisdictions prohibit political contributions by corporations to political parties or candidates. Nestlé prohibits such contributions, except those made by the parent company in Switzerland. Any such contributions or deviations from this policy must be approved by the CEO and the Chairman.
Q. What about scholarships, non-commercial sponsorships, charitable contributions or grants?
A. From time to time, Nestlé may offer scholarships, grants, charitable contributions or non-commercial sponsorships to support science, nutrition, healthcare or other socially-beneficial purposes.
These must never be used to gain an improper advantage for Nestlé or be conditional on promoting our products. Appropriate review and approval procedures must be followed, including evaluating the recipient’s reputation, track record and suitability for the intended purpose as well as the social benefits.
Corporate Affairs must be involved in the review and selection process. Significant disbursements must be approved by the Market Head or other designated senior leader and documented in writing.
Q. How do we prevent others from behaving improperly on our behalf?
A. Nestlé will never use third parties to pay bribes or engage in corrupt practices. We require our suppliers, service providers, distributors and third parties acting on our behalf to act with integrity and in compliance with anti-bribery laws.
The decision to purchase from a certain supplier, to engage a service provider, or to appoint a commercial agent or distributor, must follow an appropriate due diligence process. If it becomes clear or appears likely that a third party is engaging in inappropriate or illicit practices on our behalf, inform the Legal and Compliance team immediately.
Q. What if our physical safety is at risk unless we pay a bribe?
A. In the unfortunate event that an employee or an affiliated third party faces threats or potential physical harm if they refuse to pay a bribe on behalf of Nestlé, the safety of our people is a priority. Legal and Compliance and Group Security must be informed as soon as possible to undertake appropriate remedial actions.
