Implementation of the Code of Conduct
16. Chapter 1: The company (continued)
Heineken began implementing its Code of Business
Conduct (CBC) in 2005 to help safeguard the
integrity of its business decisions. The Code outlines
specific rules on compliance with local laws, fraud
prevention, how to deal with corruption, conflicts of
interest and supply-chain responsibilities, which apply
globally and at every level of the organisation.
The Code provides a general framework that can
be adapted to meet local business conditions,
requirements, cultures, styles and languages.
In Italy, Heineken also used the implementation
process to also comply with a set of local
regulatory guidelines aimed at preventing
unethical corporate practices and encouraging
better internal control systems.
Implementation at Heineken Italia began in
January 2005. Internal audit manager, Milan-based
MassimilianoTurconi, was charged with coordinating
the implementation projects, defining areas of risk,
reviewing the work of external consultants and
following up with the project managers.
"These are all relatively new topics in Italy, so
while we've seen an enormous amount of interest
from our subsidiaries, there's also been a lot of
explaining to do," saysTurconi. "It has taken a little
time for everyone to understand how the new
systems work and why they're so important."
The Code had to be adopted at Heineken's 27
private Italian subsidiaries dotted around the
country, many of which had been operating in
nearly the same way for several years. The nine-
month project was kicked off in February for the
beer business (mainly Heineken Italia) and
subsidiaries for the wholesale business (Partesa)
with a cluster of six subsidiaries to start with and
later extended. After briefing senior managers
about the Code, systems were set in place, training
was provided to mitigate risks and responses were
defined for potential Code infringements.
"We mostly found our businesses were already
following the spirit of the Code, but this meant
they sometimes thought it wasn't relevant to them,"
he explains. "It has been a very healthy exercise
because everybody is now very clear about their
responsibilities and knows how to manage
The project's success has hinged on a strong
commitment from senior managers who have
helped raise employee awareness at all levels of
the organisation. In this sense, the Code of Business
Conduct requires a continuous information and
training process, which includes regular articles in
internal newsletters and dedicated training sessions
for all new employees starting in the years to come.
It is still too soon to measure the effectiveness of
the new Code's procedures, but the first round
of regular auditing work is already underway to
ensure the systems continue to work properly.
Looking ahead, Turconi believes this process will
only become easier.
"We are done with the hard part now," he says.
"Awareness of the Code is extremely high and most
of our employees, many of whom are quite young,
really buy into it. The end result is that it has added
a lot of value to being a Heineken employee."
Heineken N.V. - 2004/2005 Sustainability Report