Our Code of Conduct
At the heart of our ethical culture is the Code of Business Conduct: A guide for Living Our Brew.
As we say at Molson Coors, we have a duty to ourselves, the communities we live in, the suppliers we work with, the customers we serve and the beer drinkers we seek to delight to always do the right thing. Our guide to doing the right thing is our Code of Business Conduct, Living Our Values. Together with our Values, the Code helps us to ensure our decisions and actions are consistent with the “right way.” All employees and the Board of Directors affirm the Code upon joining our company, and every two years after that.
Bringing the Code to Life
The Code is the cornerstone of our ethics and compliance program which includes communication, training, policies, and monitoring and auditing procedures on a variety of topics relevant to our business. These topics include, but are not limited to, accurate books and records, alcohol responsibility, anti-bribery and corruption, conflicts of interest, competition data privacy, discrimination and harassment, social media and speaking up. Communication and training elements focus on providing employees with an understanding of the compliance topic as well as tools to help them apply what they have learned to their area of responsibility. Our Ethics and Compliance intranet site puts ethics and compliance information and other resources into the hands of our employees wherever they reside. To ensure the company’s strong tone at the top spreads throughout leaders at all levels of the organization, we added resources in 2014 aimed specifically at middle management to better enable them to communicate about ethics and compliance issues and demonstrate “the right way” daily in their particular roles.
Under the Chief Ethics and Compliance Officer and our Executive Ethics and Compliance Committee, we work with partners in each or our regions to promote a consistent global approach to doing things the “right way” everywhere we do business.
Anti-bribery & Corruption
Molson Coors prohibits bribery and corruption by its employees or by anyone who is acting on behalf of the company. We expect our employees and business partners to “win the right way” through ethical and transparent business practices. Our anti-bribery and corruption program includes a global policy and training program, an intranet site with tools and other resources for employees, due diligence procedures and standard contract clauses for key business partners, and monitoring through internal/external audits and our Ethics and Compliance Helpline. Activities related to our anti-bribery and corruption program, along with our broader ethics and compliance program, are communicated to our executive leadership team and the Audit Committee of our board on a quarterly basis.
Ethics and Compliance Helpline
Our employees also have access to an Ethics and Compliance Helpline 24 hours a day. The helpline allows employees, or any stakeholder, to ask a question or raise a concern in their native language in a confidential and/or anonymous way. All questions and issues raised through this channel are responded to through the Ethics and Compliance Office at Molson Coors.
In 2015, we had 25 reports or inquiries through this channel. Of the 2015 reports where investigative action was necessary, approximately 50% were substantiated and resulted in corrective or disciplinary action. 37% of reports in 2015 were anonymous vs. 20% in 2014.
Reports were made in the following categories: