ECONOMIC SUS TA INABILITY The effectiveness with which these policy measures are implemented at local level is monitored centrally by analysing beer samples and conducting organoleptic tests in the laboratory and checking the 'best before' dates on samples of products on sale, thus ensuring that the product delivered to the con sumer is safe and fresh. Consumer complaints are recorded and dealt with in accordance with our com plaints procedure. A recall is ordered if, despite all our efforts, a defective product finds its way to the market. To encourage our breweries to make an extra effort to give the consumer an excellent product, our breweries take part in an internal Quality Awards programme, under which the quality of the beer and packaging on the market is assessed by an independ ent external body. Principles In no circumstances will corruption and fraud be tolerated by Heineken, which considers that corrup tion must be eliminated from society and has pro grammes in place to prevent it. In the case of gifts and conflicts of interest, however, it is not always possible to lay down hard and fast rules, one reason being that society's perception of the value and significance of a business gift varies widely from country to country. Heineken has formulated princi ples of ethical conduct at a central level which are implemented locally. These prevent employees allowing business and personal interests to conflict or accepting or making personal gifts which might impair ethical business relations or jeopardise deci sions. 2.7 Code of conduct Heineken's policies on ethical business practices, in particular with regard to corruption, gifts, fraud and conflicts of interest, has been reviewed in the past few years. When a survey revealed that not all operat ing companies had addressed these issues with equal rigour, a programme was set up to establish more consistent standards of business ethics and to formu late a code of business conduct which would be implemented worldwide. One of the principal aims was to explain to employees more clearly what is expected of them in a given situation. Heineken/BBAG integration Heineken/Brau Union HR combines the best of both worlds The integration of BBAG following its acquisition by Heineken was a massive task that demanded a new approach. The first step was to define a set of principles, to protect the interests of customers, employees and other stakeholders, before teams from the two companies met to draw up a plan for the integration process, based on respect for each other's culture. Thanks to this new approach, cultural differences have caused no problems so far. Integ Act KURT HERLER Results Heineken's anti-corruption policy, which prohibits employees from committing any corrupt act on behalf of the company, was adopted worldwide in 2002. In addition to this central policy, many of Heineken's operating companies are developing activities to promote ethical conduct. 61 per cent of the employees of our operating companies are aware of their responsibilities regarding the giving and receiving of gifts and a slightly larger proportion, 75 per cent, are aware that purchases on behalf of the company must not be made from suppliers with which they have a personal relationship or from which they expect a personal reward. 81 per cent of the operat ing companies have introduced anti-fraud measures. While the absence of a local policy does not, of course, imply that the operating companies in ques tion perform poorly in terms of ethical conduct, it is necessary to reinforce the initiatives undertaken to promote ethical conduct in order to minimise the risks to the company. Internal dialogue Because it is important that the international code of conduct we have formulated is consistent with local standards and values, the business conduct program me largely takes the form of a local internal dialogue in which the operating companies define the rules HEINEKEN N.V. SUSTA INABILITY REPORT 2 00 2-200 3 22

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Heineken - Milieuverslag | 2002 | | pagina 24