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2013 European Compliance & Ethics Institute – London
Janice Piacente
Chief Compliance and Risk Officer
8 April 2013
Highly Confidential – Not for Distribution
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The Coca-Cola System
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MarketplaceExecution
Communityand Customer
Brand Marketing
Customer Focus
Customer Focus
Long-TermSustainable,
ProfitableGrowth
Production/Distribution
Marketplace Execution
Community and Customer Brand
Marketing
Franchise Leadership
Brand Development/Innovation
Brand Marketing
Consumer Focus
Consumer Focus
A Strong Partnership
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$8 billion revenue
Celebrating over 125 years
90+ years in Europe
40+ brands
13,000 employees
17 manufacturing facilities
165 million consumers
CCE Today
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Highly Confidential – Not for Distribution
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Coca‐Cola™Coca‐Cola™ Sparkling Flavors and EnergySparkling Flavors and Energy
StillsStills
Leading Brands
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To create a holistic, integrated, forward-looking and process-oriented approach that aligns strategy, processes, people, technology and knowledge.
CCE’s Approach to Risk Management
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• Proactively assesses and monitors risks, internal controls and compliance
• Valued business partner
• Senior Manager in each business unit; 15 FTEs
Compliance and Risk Organization
General CounselJanice PiacenteChief Complianceand Risk Officer
AuditCommittee
Assoc DirectorRotterdam
Assoc DirectorUxbridge
Assoc DirectorUxbridge
DirectorRotterdam
Ethics & Compliance Enterprise Risk Mgt Risk, Control & Compliance
• Executes cross-functionally with ERM working group and risk owners
• Strong collaboration with Internal Audit
• Executes cross-functionally with Legal, Security and HR – Employee Relations
• Training is planned and executed with HR – Learning and Development
• Strong collaboration with subject matter experts (SMEs)
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Accountable, Knowledgeable Oversight
Managing risk is the responsibility of management
Board of Directors reviews the significant risks and potential impact when evaluating strategies
Audit Committee has oversight responsibilities
Compliance and Risk:
Proactively drives collaboration and transparency
Ensures the right processes and procedures are followed
Evaluates program and compliance
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Enterprise Risk Council
BusinessLeadership
GlobalSupport
Functions
ExecutiveLeadership
BODAC
Internal Audit, Ethics & Compliance, ERMIndependent
Validation, Monitoring
Operational
Risk Management
Oversight
Comprehensive RiskManagement
Governance and Oversight Structure
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Oversight of Risk
EnterpriseRisk
Management
Governance
Internal Audit
Security / Fraud
Internal Controls
Risk Mgt Insurance
Strategic Planning
E&C
• Audit Committee• ELT• Risk Committee / Mgt
• SOX Compliance• Financial / Operational• Integrated with ERM
• Fraud Risk• Security• Investigations
• Monitoring• Business Partner• Field Controls / SOX
• Assets• Corporate
• Long-Range Plan (LRP)
• Annual Business Plan (ABP)
• Treasury & Commodity Risk Committee
• Ethical Culture• Training• Communication• Policy
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Compliance Risk Assessment
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Ethics and Compliance Framework
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Compliance Risk Assessment Approach
Compliance Risk
Assessment
Risk Owners
Management Oversight
ReportingAccountability Monitoring
Identify
Assess
Prioritize
Risk Coverage
Management Oversight
Dashboard
Risk Council / ELT / AC / BOD
Tools: Tools: Tools: Tools:
Internal Audits
Internal Controls
SOX testing
Periodic risk update
Ethics and Compliance Oversight
CCE Policies
Laws
Highly Confidential – Not for Distribution
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ERM: Ethics / ComplianceRISK REGISTER
− Corporate political activities (i.e., contributions and lobbying)
Ethics and Compliance Risk Register
Advocacy and Political
Activities
− Business laws relating to sales and commercial transactions (other than competition law)
Commercial Regulations
− Any law, regulations or policy relating to competition
− Requirements around private and public agreements and tenders
Contracts
− Bribery, facilitation payments− Excessive gifts or hospitality− Conflict of interest
Corruption
− Corporate confidentiality− Filing personal data (HR , Proc, S&M)
− Environmental laws and regulations− Water or air pollution and energy use− Waste water treatment
− Required financial and related disclosures or filing
− Occupational health − Work place safety
− IP laws; artistic and commercial creations of mind and trademarks, trade secrets, patents and licences
Intellectual Property
− Employment laws and regulations− Behaviour issues/trends− Corporate strategic plans
Labour
− SEC insider trading rules and regulationsInsider Trading
− Company filings, employee withholding, property, VAT
Environmental
− Due Diligence; knowing who we deal with
− UK Bribery Act compliance
− Laws and regulations related to transporting our products within and across international borders
− Filing, retention and management of any business information
− Food safety requirements − KO standards− Labelling, packaging, traceable
Health & Safety
Competition Law
Data protection & privacy
Fin. Reporting & Disclosure
Tax Reporting & Disclosure
Transport Logistics
Records Management
Product Quality
Third party
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Compliance Risks Linked to COBC
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Compliance Risk Dashboard Reporting
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Control Self-Assessment Program
ProcessesControlsPoliciesTraining
Develop detailed
risk analysis (bottom-
up)
Compliance Risk
Assessment Results (top-
down)
Define risk statements
Risk Ownership
Self-reporting & Validation
Leverage existing processes (SOX)
Control frequency
Control Self-Assessment Reporting
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Keys to Success
“Tone from the Top”
Executive management support
Culture of strong collaboration
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Contact Information
Janice PiacenteChief Compliance and Risk [email protected]: +44 (0) 1895 844 055mobile: +44 (0) 7976 976 902
