Economic Impact
Assessment performed
36
Impact on developing markets
Two reports on our approach to business ethics
and its effectiveness were submitted to the Audit
Committee of the Executive Board: a half-year
review in August 2007 and a full-year report
in February 2008. The latter contained a full
overview of cases filed locally and with the
Integrity Committee of Heineken Group, as well
as the results from the activities of Group Internal
Audit with respect to business ethics.
In 2007, two cases were reported to the Integrity
Committee through the international hotline.
Both cases were referred back to the operating
company, as they did not involve members of
a local Management Team or otherwise meet
the criteria for review by the Integrity Committee.
On a local level, 36 reports were filed with the
local Trusted Representatives of line management.
Of these 36 cases, 25 were substantiated. They
mainly concerned incidents of fraud or conflicts of
interests. The relevant disciplinary or other action
was taken in respect of all these infringements.
In the last quarter, Group Internal Audit conducted
a Group-wide review into the effectiveness of the
Code of Business Conduct and the Whistle-Blowing
Procedure. This review provided us with valuable
insights on how to further improve our approach.
The main conclusion was that the training of
employees in certain risk functions needed
improvement in a majority of the operations.
Also under the leadership of Group Internal Audit,
an employee perception survey was conducted
among nearly 1,000 employees in five different
operating companies. This survey showed that
familiarity with the provisions of the Code of
Business Conduct is relatively high as nearly
all employees who participated in the survey
indicated that they knew the content. Familiarity
with and trust in the Whistle-Blowing Procedure
scored much lower, underpinning the importance
of constant communication on the Whistle-Blowing
Procedure and how to access it.
Finally, in 2007 we continued our efforts to get a
better understanding of the cultural elements of
ethical behaviour. Group Corporate Relations and
Group Fluman resources have been jointly working
on the possible integration of certain questions
in our climate survey that are designed to allow
operating companies to better understand the
influence of the business culture on ethical
behaviour and to undertake interventions when
necessary. Our aim is to commence these kind
of measurements in the course of 2008.
Heineken N.V. Sustainability Report 2007
