19. To enable operating companies to develop their own codes and implementation plans, a number of regional workshops were conducted, involving project principles and project managers from many different countries. These workshops took place during 2004 and 2005. To support the operating companies, a number of tools were developed. The Code of Business Conduct Management Primer was created to ensure that local managers interpret the Code's provisions in a uniform way. This is important because employees are encouraged to consult local management when they face a dilemma regarding one of the subjects covered in their code. The Primer was translated into a number of languages, including French, Italian and Russian. A detailed Implementation Manual was also published, outlining the steps any operating company must take when designing and introducing a country-specific code of conduct. A similar manual was introduced for the Code of Whistle Blowing, along with an electronic workbench that allows different operating companies to learn from each other. At the close of 2005, 91 per cent of our operating companies had submitted their local transposition of the Fleineken Code of Business Conduct for approval. In five operating companies, the introduction had not yet started. These were Curacao and Pago, Austria (where codes were delayed due to reorganisations) and in Panama, Kazakhstan and Belgium (where we identified other priorities). All these operations are set to finalise their codes in the course of 2006. In total 67 per cent of the operating companies had obtained approval for their transposition before 31 December 2005. Monitoring and control of implementation activities of local codes started in 2005 and will continue in the years to come. All operating companies are required to identify any functions considered to present an elevated risk when judged against the provisions of the Code, and ensure that proper training is provided in order to mitigate these risks. They must also keep all their employees fully informed about the Code. Operating companies are also required to define response strategies to meet infringements of the Code and to identify possible sanctions. Starting 2007, they must prepare annual reports explaining how the Code functions and is maintained. These reports will be subject to both internal and external audit, while implementation plans are subject to approval by the Business Conduct Review Committee. Heineken N.V. - 2004/2005 Sustainability Report

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Heineken - Milieuverslag | 2004 | | pagina 21