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
Heineken N.V. - 2004/2005 Sustainability Report