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Sustainability
Governance

Sustainability
Governance

Sustainability Milestones

Sustainability Milestones
● Published 1st Environmental Policy
2002
Sustainability Milestones
● Ranked in the 1st place in Turkey’s
Accountability Rating

● Signed the United Nations Global Compact
(UNGC)

● Published 1st Sustainability Report
2009
Sustainability Milestones
● Externally assured for ISAE 3000 (for the 1st time)

● Became Charter Member of the Climate Change
Leaders Group

● Listed as Turkey’s 1st food and beverage company in
CDP Global Disclosure Leaders

● Signed to the “2°C Communiqué”
2011
Sustainability Milestones
● Listed among top two companies in
Turkey’s CDP Carbon Performance Leaders

● Completed the “Top 10 Energy-Saving
Challenge Program” of TCCC and the
WWF (World Wildlife Fund) with İzmir and
Mersin Plants in Turkey

● Represented Turkey in Rio+20 Conference
among the best Green Economy Projects
2012
Sustainability Milestones
● CCI Operations became the first multi-country operation in TCCS among all bottlers to complete the “Top 10 Energy-Saving Challenge Program”

● Became the 1st company from Turkey and within TCCS in the UNGC 100 Index

● Launched new “Code of Ethics”, “Workplace Rights Policy” and “Ethics Service”

● Received the 1st ISO 14064-3 Certificate in Turkey for its GHG inventory

● Listed among Carbon Disclosure and Performance Leaders in CDP Turkey 100 Climate Change Report

● Received “Gender Equality Certification” from KAGİDER in Turkey
2013
Sustainability Milestones
● Achieved the 2nd highest score in the disclosure
category of CDP Turkey Climate Leadership
Awards

● Became 1st company from Turkey in the CDP
Global Water Program

● Increased Corporate Governance Rating from 8.8
to 9.25
2014
Sustainability Milestones
● Announced “2025 Vision and Strategic Framework”

● Joined the “BIST 50 Sustainability Index”

● Joined the “Euronext Vigeo Emerging 70 Index”

● Signed “UN Women’s Empowerment Principles”

● Increased Corporate Governance Rating from 9.25 to 9.40
2015
Sustainability Milestones
● Joined the “BIST 100 Sustainability Index”

● Joined “MSCI Global Sustainability Index”

● Joined “FTSE4Good Emerging Index”

● Listed among “Turkey’s CDP Climate Change Leaders”
2016
Sustainability Milestones
● Joined “ECPI Emerging Markets ESG Equity index”

● Joined “Vigeo Eiris Best Emerging Markets Performers Ranking”

● Joined “30% Club’s Turkey Chapter”, initiated by Sabancı University’s Corporate Governance Forum and the Capital Markets Board of Turkey as part of the Independent Women Directors Project
2017
Sustainability Milestones
● Achieved a Corporate Governance Rating of 9.45

● Externally assured Turkey Operations’ waste data

● Updated “Workplace Rights Policy” as “Human Rights Policy”

● Received LEED Gold Certificate with CCI Dudullu HQ
2018
Sustainability Milestones
● Only company from Turkey and within TCCS in the UNGC 100 Index (Since 2013)

● Became a member of ERTA (Integrated Reporting Turkey Network)

● Joined “Business Initiative for Plastic” in Turkey

● Achieved a Corporate Governance Rating of 9.46
2019
2002
• Published 1st Environmental Policy
2009
• Ranked in the 1st place in Turkey’s Accountability Rating

• Signed the United Nations Global Compact (UNGC)

• Published 1st Sustainability Report
2011
• Externally assured for ISAE 3000 (for the 1st time)

• Became Charter Member of the Climate Change Leaders Group

• Listed as Turkey’s 1st food and beverage company in CDP Global Disclosure Leaders

•Signed to the “2°C Communiqué”
2013
• CCI Operations became the first multi-country operation in TCCS among all bottlers to complete the “Top 10 Energy-Saving Challenge Program”

• Became the 1st company from Turkey and within TCCS in the UNGC 100 Index

• Launched new “Code of Ethics”, “Workplace Rights Policy” and “Ethics Service”

• Received the 1st ISO 14064-3 Certificate in Turkey for its GHG inventory

• Listed among Carbon Disclosure and Performance Leaders in CDP Turkey 100 Climate Change Report

• Received “Gender Equality Certification” from KAGİDER in Turkey
2014
• Achieved the 2nd highest score in the disclosure category of CDP Turkey Climate Leadership Awards

• Became 1st company from Turkey in the CDP Global Water Program

• Increased Corporate Governance Rating from 8.8 to 9.25
2015
• Announced “2025 Vision and Strategic Framework”

• Joined the “BIST 50 Sustainability Index”

• Joined the “Euronext Vigeo Emerging 70 Index”

• Signed “UN Women’s Empowerment Principles”

• Increased Corporate Governance Rating from 9.25 to 9.40
2016
• Joined the “BIST 100 Sustainability Index”

• Joined “MSCI Global Sustainability Index”

• Joined “FTSE4Good Emerging Index”

• Listed among “Turkey’s CDP Climate Change Leaders”
2017
• Joined “ECPI Emerging Markets ESG Equity index”

• Joined “Vigeo Eiris Best Emerging Markets Performers Ranking”

• Joined “30% Club’s Turkey Chapter”, initiated by Sabancı University’s Corporate Governance Forum and the Capital Markets Board of Turkey as part of the Independent Women Directors Project
2018
• Achieved a Corporate Governance Rating of 9.45

• Externally assured Turkey Operations’ waste data

• Updated “Workplace Rights Policy” as “Human Rights Policy”

• Received LEED Gold Certificate with CCI Dudullu HQ
2019
• Only company from Turkey and within TCCS in the UNGC 100 Index (Since 2013)

• Became a member of ERTA (Integrated Reporting Turkey Network)

• Joined “Business Initiative for Plastic” in Turkey

• Achieved a Corporate Governance Rating of 9.46

Memberships and Cooperations

Our Memberships and Signed Initiatives

Membership
Memberships and Cooperations
Our Memberships and Signed Initiatives
Membership
  1. (Packaging Recovery Organization – Green Dot)
  2. (Turkish Industry and Business Association)
  3. (International Investors Association)
  4. (Beverage Industry Association)
  5. (Turkish Quality Association)
  6. (Foreign Economic Relations Board)
  7. (Bottled Water Manufacturers Association)
  8. (Turkish Fruit Juice Industry Association)
  1. (Turkish Ethics and Reputation Society)
  2. (Turkish Investor Relations Society)
  3. (Union of Chambers and Commodity Exchanges of Turkey)
  4. (Federation of Food and Drink Industry Associations of Turkey)
  5. (United Nations Global Compact Network Turkey)
  6. (Integrated Reporting Turkey Network)
  7. (Corporate Governance Association)
  8. (Global Reporting Initiative)
Signed Initiatives
  1. • CDP Climate Change Program
  2. • CDP Water Program
  3. • Equality at Work Platform
  4. • United Nations Global Compact (UNGC)
  5. • Turkish Climate Change Platform
  6. • United Nations Women’s Empowerment Principles (UNWEP)
  1. • Brand Protection Group
  2. • 30% Club Turkey Chapter (Growth Through Diversity)
  3. • Business Initiative for Plastic (TÜSIAD, UNGC, SKD)
  4. • Business against Domestic Violence - Sabancı University Corporate Governance Forum
External Recognition
Our sustainable business practices and communication of our sustainability vision
through transparent means paid off, and CCI is distinguished by national and global
sustainability indices.
  1. Since its launch by the United Nations Global Compact (UNGC) in 2013, CCI is still the only company in Turkey that was included in the UNGC 100 Index. Companies listed in the index are selected from among the eligible UNGC members around the world. The eligible members are required to demonstrate their executive commitment to 10 UNGC principles, and continuously improve and disclose their sustainability performance and maintain consistent base-line profitability.
  2. Based on the evaluation of our sustainability practice and performance in 2018-2019, CCI was included in Borsa Istanbul (BIST) Sustainability Index for the period between November 2019 and October 2020. In 2015, CCI became one of the first 29 companies to be included in the BIST Sustainability Index.
  3. Upon evaluation of our environmental, social and corporate governance performance for 2017-2018 by Morgan Stanley Capital International, CCI was included in the 2019 MSCI ESG Leaders Index with score BBB. CCI joined the MSCI Global Sustainability Index in 2016.
  4. In 2016, CCI joined FTSE4Good Emerging Index owing to its high performance in the environmental, social and corporate governance matters and sustained its position in the 2019 list as well. The FTSE4Good Emerging Index was launched in 2016 by FTSE Russell, a global leader in indices and data, globally used by investors.
  5. As of December 2017, CCI became a constituent of Emerging Markets ESG Equity index (ECPI). ECPI is a leading rating and index company dedicated to environmental, social and governance performance research.
  6. In June 2019, CCI was once again included in Vigeo Eiris Best Emerging Markets Performers Ranking, selected as one of the 100 most advanced companies within the Equities Emerging Markets Universe consisting of 813 companies from 31 countries. Companies included in this index achieve the highest scores, as determined by a review based on 38 criteria, divided into six key areas of corporate environmental, social and governance matters, assessed by Vigeo Eiris.
  7. CCI voluntarily participates in CDP Climate Change and Water Programs. CCI was honored with the Climate Leadership Award by CDP Turkey in performance and transparency categories three times. In 2019, CCI increased its score of Water Program from B- to B. CCI Climate Change Program score has not changed and stayed above all sectoral and regional averages.
Partnerships for Sustainability
  1. CCI is a member of Turkish Industry and Business Association (TUSIAD) and CCI Corporate Affairs Director is a Board Member of UNGC Turkey. In line with our commitment to the Sustainable Development Goals, CCI is an active participant of the Climate Change, Diversity & Inclusion and Gender Equality and WomenEmpowerment Workgroups and “Business Initiative for Plastic” by TUSIAD, UNGC and SKD.
  2. The Young Sustainable Development Goals (SDG) Innovators Program is designed to engage a company’s brightest talents in not only advancing sustainability efforts but driving innovation and delivering tangible solutions with potential market value for their company. Two talents from CCI participated the program in 2019.
  3. CCI responded the call of Turkish Industry and Business Association, Business Council for Sustainable Development Turkey and United Nations Global Compact Turkey to fight plastic pollution through “Business Initiative for Plastic”. By signing the declaration of commitments CCI has become one of the 26 pioneer companies of the initiative proving dedication on efforts of reducing plastic consumption levels until 2021 and disclosing the results publicly.
  4. CCI is a founding member of CEVKO and CCI Corporate Affairs Manager is a Board Member. By means of our strategic cooperation with CEVKO, we achieve a steadily increasing rate of post- consumer packaging waste collection as well as raising consumer awareness on recycling.
  5. Women empowerment is a priority topic in CCI’s sustainability strategy. Coca- Cola Turkey cooperated with Habitat Association for “My Sister” Project. The project aims to empower women, by equipping them with the necessary information and knowledge to take active role in the regional economic development, to improve their economic and social position and participate in economy.
  6. CCI invests in community projects to tackle waste pollution and recycling. Since 2018, in cooperation with UNDP, a recycling program in the Mediterranean District of Turkey continues with the goal of enhancing the waste management capacity for recycling.
  7. The project on Technical Assistance for Improving Social Dialogue in Working Life, run by the ILO Office in Turkey, prioritizes increasing the capacity of social partners, relevant public institutions and awareness-raising on social dialogue at all levels through a holistic approach. CCI contributed to the project along with other FMCG companies.
  8. CCI Corporate Affairs Manager is selected as the President of the Board of MEDER, which was established in 1994 with the aim of supporting the growth of beverage sector, increasing the contributions of the sector on the Turkish economy and leading the sustainability efforts in the industry.
  1. TUSIAD - UNGC
    CCI is a member of Turkish Industry and Business Association (TUSIAD) and CCI Corporate Affairs Director is a Board Member of UNGC Turkey. In line with our
    commitment to the Sustainable Development Goals, CCI is an active participant of the Climate Change, Diversity & Inclusion and Gender Equality and WomenEmpowerment Workgroups and “Business Initiative for Plastic” by TUSIAD, UNGC and SKD.
  2. TUSIAD - UNGC
    The Young Sustainable Development Goals (SDG) Innovators Program is designed to engage a company’s brightest talents in not only advancing sustainability efforts but driving innovation and delivering tangible solutions with potential market value for their company. Two talents from CCI participated the program in 2019.
  3. TUSIAD - UNGC -  SKD (Business Initiative for Plastic)
    CCI responded the call of Turkish Industry and Business Association, Business Council for Sustainable Development Turkey and United Nations Global Compact Turkey to fight plastic pollution through “Business Initiative for Plastic”. By signing the declaration of commitments CCI has become one of the 26 pioneer companies of the initiative proving dedication on efforts of reducing plastic consumption levels until 2021 and disclosing the results publicly.
  4. CEVKO (Green Dot)
    CCI is a founding member of CEVKO and CCI Corporate Affairs Manager is a Board Member. By means of our strategic cooperation with CEVKO, we achieve a steadily increasing rate of post- consumer packaging waste collection as well as raising consumer awareness on recycling.
  5. Habitat Association
    Women empowerment is a priority topic in CCI’s sustainability strategy. Coca- Cola Turkey cooperated with Habitat Association for “My Sister” Project. The project aims to empower women, by equipping them with the necessary information and knowledge to take active role in the regional economic development, to improve their economic and social position and participate in economy.
  6. United Nations Development Program (UNDP)
    CCI invests in community projects to tackle waste pollution and recycling. Since 2018, in cooperation with UNDP, a recycling program in the Mediterranean District of Turkey continues with the goal of enhancing the waste management capacity for recycling.
  7. International Labor Organization (ILO)
    The project on Technical Assistance for Improving Social Dialogue in Working Life, run by the ILO Office in Turkey, prioritizes increasing the capacity of social partners, relevant public institutions and awareness-raising on social dialogue at all levels through a holistic approach. CCI contributed to the project along with other FMCG companies.
  8. MEDER (Beverage Industry Association)
    CCI Corporate Affairs Manager is selected as the President of the Board of MEDER, which was established in 1994 with the aim of supporting the growth of beverage sector, increasing the contributions of the sector on the Turkish economy and leading the sustainability efforts in the industry.
The Business Against Domestic Violence Project is carried out by the Corporate Governance Forum of the Sabancı University in cooperation with TUSIAD and with the main support of the United Nations Population Fund (UNFPA) and the Sabancı Foundation. It has the objective to establish support mechanisms in workplaces in case of employees being the subjects of violence in their close relationships. Three representatives of CCI attended BADV training. CCI’s objective is to share its management and organizational capabilities in order to spread best practices, tools and methods which lead to the decrease of domestic violence of the business world. In December, CCI Executive Committee and Turkey Leadership Team attended Gender Equality Awareness Training
Sabancı University Corporate Governance Forum (Business against Domestic Violence)
The Business Against Domestic Violence Project is carried out by the Corporate Governance Forum of the Sabancı University in cooperation with TUSIAD and with the main support of the United Nations Population Fund (UNFPA) and the Sabancı Foundation. It has the objective to establish support mechanisms in workplaces in case of employees being the subjects of violence in their close relationships. Three representatives of CCI attended BADV training. CCI’s objective is to share its management and organizational capabilities in order to spread best practices, tools and methods which lead to the decrease of domestic violence of the business world. In December, CCI Executive Committee and Turkey Leadership Team attended Gender Equality Awareness Training
Sustainability Reporting
For our objective to make CCI the leader of sustainability, accountability and transparency, CCI’s Sustainability Report is the most significant communication tool to share our sustainability performance with our stakeholders. As our sustainability reporting evolved, we have been included in global sustainability indices, developed positive relationships with stakeholder groups who appreciate transparency on environmental and social matters, and enhanced our corporate reputation.
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Since 2017, CCI’s Sustainability Reports are reviewed by BSCD Turkey within the framework of “Reporting Matters” program of World Business Council for Sustainable Development (WBCSD). As part of the program, member companies’ sustainability reports are analyzed on 18 comprehensive indicators in three main categories named principles, content and experience. CCI Sustainability Reports are regarded as best practices in the Balanced Content category, emphasizing our success in transparent communication of achievements as well as improvement areas. After two reviews in 2017 and 2018, CCI raised its reporting score by 14 points.
Corporate Governance
Corporate Governance
CCI’s strong corporate governance structure plays a vital role in achieving our strategic goals. CCI conducts all its operations within the framework of established regulations in the operating countries and of the Corporate Governance Principles monitored by Turkey’s Capital Markets Board. We annually publish our Corporate Governance Principles Compliance Report in order to transparently inform our stakeholders on our performance. Corporate governance performance is managed by CCI Board of Directors, with the cooperation of Corporate Governance, Audit, and Risk Detection Committees which are involved under the Board. Corporate Governance Committee exercises the functions of Nomination and Remuneration Committees
Sustainability Organization
Sustainability Organization
CCI Board of Directors is actively engaged with the CCI’s sustainability strategy and its commitment to integrate sustainability into the business strategy. Corporate Governance Committee has the ultimate responsibility in determining and implementing the sustainability strategy. This responsibility is undertaken by the CCI Executive Committee, which is comprised of representative from senior management and steered by the CEO. Environmental and Social Sustainability Committee, Health and Safety Steering Committee, Diversity and Inclusion Advisory Board and, Ethics & Compliance Committee work separately to achieve the targets set for each of the strategic sustainability issues, together with the related working groups, and reporting to the Executive Committee.
Since 2015, CCI Corporate Affairs Director has also been serving as the Deputy Chairman of UNGC Turkey Network. CCI Corporate Affairs Department is responsible for the disclosure, reporting and communication of sustainability targets and performance results. CCI employees also play significant roles to integrate our sustainability strategy into our overall business processes.
CCI Board of Directors is actively engaged with the CCI’s sustainability strategy and its commitment to integrate sustainability into the business strategy. Corporate Governance Committee has the ultimate responsibility in determining and implementing the sustainability strategy. This responsibility is undertaken by the CCI Executive Committee, which is comprised of representative from senior management and steered by the CEO. Environmental and Social Sustainability Committee, Health and Safety Steering Committee, Diversity and Inclusion Advisory Board and, Ethics & Compliance Committee work separately to achieve the targets set for each of the strategic sustainability issues, together with the related working groups, and reporting to the Executive Committee.
Since 2015, CCI Corporate Affairs Director has also been serving as the Deputy Chairman of UNGC Turkey Network. CCI Corporate Affairs Department is responsible for the disclosure, reporting and communication of sustainability targets and performance results. CCI employees also play significant roles to integrate our sustainability strategy into our overall business processes.
CCI Board of Directors is actively engaged with the CCI’s sustainability strategy and its commitment to integrate sustainability into the business strategy. Corporate Governance Committee has the ultimate responsibility in determining and implementing the sustainability strategy. This responsibility is undertaken by the CCI Executive Committee, which is comprised of representative from senior management and steered by the CEO. Environmental and Social Sustainability Committee, Health and Safety Steering Committee, Diversity and Inclusion Advisory Board and, Ethics & Compliance Committee work separately to achieve the targets set for each of the strategic sustainability issues, together with the related working groups, and reporting to the Executive Committee.
Since 2015, CCI Corporate Affairs Director has also been serving as the Deputy Chairman of UNGC Turkey Network. CCI Corporate Affairs Department is responsible for the disclosure, reporting and communication of sustainability targets and performance results. CCI employees also play significant roles to integrate our sustainability strategy into our overall business processes.
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Risk Management
Risk Management Governance Structure
Risk Management
Risk Management Governance Structure
Risk Detection Committee reporting to the Board oversees the risk management at CCI. Enterprise Risk Management (ERM) Team, which directly reports to the CEO and the Risk Detection Committee, acts as the facilitator and conducts risk assessments. ERM team members are the CEO, the Strategy and Business Development Director, and the Regional Directors.ERM conducts risk assessment on country and group levels using the input from the World Economic Forum, global surveys and The Coca Cola System. The risks are prioritized based on their general likelihood, and the probability of occurrence in the short-term and impact.
Country Operation Managers of CCI are responsible for risk management and mitigation. They identify the critical threats and opportunities based on the risk assessment results, integrate them into their Strategic Business Plans and prepare the mitigation action plans. High-priority risks are reported to the Board’s Risk Detection Committee along with mitigation action plans. Internal audits are performed to track the risk mitigation plans and the results are reported to the Audit Committee.
Actions of 2019
Our consolidated risks were categorized into seven groups parallel with the global risk ERM approach. Focus was on the financial reflections of economic and political risks in our geography and talent management in addition to detailed individual risks for operating countries and as common risk areas for all operations. Videoconferencing was utilized instead of travelling to each country of operation, as a tool for some internal audits to save time and be more environmentally friendly.
Risk Management Trainings
CCI employees are regularly trained on risk management and informed via the ERM website, that is accessible through the CCI internal portal. The website provides an ERM tool along with guidelines, leading articles, useful links and an awareness training presentation on ERM
Risk Detection Committee reporting to the Board oversees the risk management at CCI. Enterprise Risk Management (ERM) Team, which directly reports to the CEO and the Risk Detection Committee, acts as the facilitator and conducts risk assessments. ERM team members are the CEO, the Strategy and Business Development Director, and the Regional Directors.ERM conducts risk assessment on country and group levels using the input from the World Economic Forum, global surveys and The Coca Cola System. The risks are prioritized based on their general likelihood, and the probability of occurrence in the short-term and impact.
Country General Managers of CCI are responsible for risk management and mitigation. They identify the critical threats and opportunities based on the risk assessment results, integrate them into their Strategic Business Plans and prepare the mitigation action plans. High-priority risks are reported to the Board’s Risk Detection Committee along with mitigation action plans. Internal audits are performed to track the risk mitigation plans and the results are reported to the Audit Committee.
Actions of 2019
Our consolidated risks were categorized into seven groups parallel with the global risk ERM approach. Focus was on the financial reflections of economic and political risks in our geography and talent management in addition to detailed individual risks for operating countries and as common risk areas for all operations. Videoconferencing was utilized instead of travelling to each country of operation, as a tool for some internal audits to save time and be more environmentally friendly.
Risk Management Trainings
CCI employees are regularly trained on risk management and informed via the ERM website, that is accessible through the CCI internal portal. The website provides an ERM tool along with guidelines, leading articles, useful links and an awareness training presentation on ERM
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Global Risks Landscape 2019
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In Terms of
Likelihood
In Terms of
Impact
Top Risks for CCI’s in 2019
Top Risks for CCI’s in
2019
Economic
Change in consumer preferences has always been the risk against continuous growth that we mitigated through diversified product portfolio where operational challenges appear.
Outlook for 2020
Outlook for 2020
Adjusting operational business processes, increase operational efficiencies, accelerated portfolio diversification to align with changing consumer preferences.
Legal
Regulatory changes in Turkey and Pakistan regarding plastics, sugar and water consumption created financial and operational challenges.
Outlook for 2020
Anticipating and planning for geopolitical and regulatory changes and collaborating with the industry and state authorities.
Technological
Cyber-attacks that we considered require innovative and agile approaches.
Outlook for 2020
Addressing impact of digitization and technological development on strategy, business models and cybersecurity.
Human
Retention and management of talents is another risk where we aimed to recreate a training system to develop the skills needed in our human resources.
Outlook for 2020
Overseeing the culture and talent in an era of innovation and transformation.
Social
Key stakeholders’ expectations and concerns around sustainability impacts grow more rapidly than in previous years. Responding them in their specific areas of concern is challenging.
Outlook for 2020
Engaging with the stakeholders on long-term governance, environmental and social issues
Environmental
The principal environmental risks we assessed are climate change (and energy management), post-consumer packaging and water scarcity.
Outlook for 2020
Continuing to invest in energy and water efficient equipment within mitigation actions.
Outlook 2020
  1. • Adjusting operational business processes, increase operational efficiencies, accelerated portfolio diversification to align with changing consumer preferences.
  2. • Anticipating and planning for geopolitical and regulatory changes and collaborating with the industry and state authorities.
  3. • Addressing impact of digitization and technological development on strategy, business models and cybersecurity.
  4. • Overseeing the culture and talent in an era of innovation and transformation.
  5. • Engaging with the stakeholders on long-term governance, environmental and social issues.
  6. • Continuing to invest in energy and water efficient equipment within mitigation actions.
CCI country management uses the pillars in
the company’s strategic business plan to evaluate business risks.
CCI’s principal risks and key mitigations are given below:
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Business Continuity
  1. CCI implements TCCC’s Incident Management and Crisis Resolution (IMCR) program, which is designed to create and maintain an efficient, integrated structure for preventing and managing incidents. Implementation of the IMCR program is a key management activity and is everyone’s responsibility at CCI. To ensure that we prevent or reduce the impact of incidents on our business, we have incident management teams in all countries of operation.
  1. Each team joins our annual training sessions, and collectively work on simulations of complex incidents. As part of the IMCR program, each country conducts the IMCR Validation Program every three years, which aims to create readiness for crisis situations, build awareness, identify gaps and develop action plans for improvements. In 2019, conducted the IMCR Validation Program in Azerbaijan, Kazakhstan, Kyrgyzstan and Pakistan. In 2020, we will continue to train and validate the crisis teams in Jordan and Iraq.
Data Security and Privacy
According to the Global Risk Report of the World Economic Forum; cyber risks are among the five top global risks. To address this challenge and mitigate risks, CCI owns a robust information security and privacy program with the following key elements to secure its information assets.
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Information Security Governance
CCI runs company-wide information security governance structure that enables the effective management of potential risks and incorporates security and privacy controls into our information systems and services. Information Security Steering Committee, which consists of the Executive Committee and the security management team, acts as the governing body since 2009. CCI has implemented a comprehensive Information Security Management System (ISMS) based on the ISO 27001 ISMS standard to achieve its security objectives. CCI complies and was certified with ISO 27001 standards in 2016 and completed the surveillance audit in 2017, 2018 and 2019.
Security Awareness
CCI has been running a mandatory cybersecurity awareness program for all employees since 2014, thereby promoting cybersecurity awareness across the company. The awareness program reports are submitted to top management to inform them of any risk. This awareness program includes online and offline trainings, awareness posters on displays at CCI workplaces, corporate social network groups as well as e-mail notifications on diverse topics such as phishing, travel security, URL security, e-mail security, physical security. Also, we are performing the cybersecurity contests with the prizes for most active employees.
Privacy and Data Protection
CCI takes precautionary measures to secure the personal information of its employees and customers. Our IT environment, security measures, policies and cyber security awareness program support compliance with the privacy and data protection requirements. CCI fully complies with Turkish Personal Data Protection Law requirements and has been registered to the VERBIS system. In order to follow recent regulatory developments and sustain overall compliance, Data Protection and Digital Privacy Committee meets regularly and conducts on-spot audits to remain data protection awareness, reports result of on-spot audits to top management.
Regulatory Compliance
CCI designed and implemented many initiatives aimed at ensuring compliance with the requirements of:
• Turkish Personal Data Protection Law no. 6698 (KVKK)
• Communiques published by Capital Markets Board of Turkey
• Authorized Economic Operator program of Turkish Ministry of Customs and Trade
Ethics Management
Integrity and honesty are fundamental virtues for CCI. It is our whole- hearted obligation to protect our most valuable asset; the Coca- Cola brand and CCI. The CCI Code of Ethics guides our employees to live by our values and “do the right thing”. The scope applies to all CCI operating countries. CCI also developed the mechanisms for stakeholders to report any illegal or unethical practice within the company to the CCI Ethics and Compliance Officer.
Governance of Ethics
CCI’s Corporate Governance Committee ensures full implementation and enforcement of the Code of Ethics. Implementation of the Code is under the responsibility of the CCI Ethics and Compliance Manager and the Local Ethics and Compliance Managers. CCI Ethics and Compliance Committee, consists of the CFO, the Human Resources Director, the General Counsel, the Corporate Affairs Director and the Chief Audit Executive.
CCI Ethics and Compliance Manager keep records of all incidents across CCI and monitors the review processes and ensures they are completed. CCI Internal Audit Department handles investigations concerning Code of Ethics violations and the CCI Ethics and Compliance Committee makes decisions based on the findings of the investigations. Certain categories of decision-making authority may be delegated to Local Ethics and Compliance Committees in accordance with the Guidelines for Handling Code of Ethics Matters
We impose disciplinary measures that fit the nature and circumstances of each violation. Letters of reprimand are issued for less significant, first-time offenses. Violations of a more serious nature may result in suspension without pay, loss of progress payments and bonuses or termination of employment.
For details on Bribery and Corruption management, please see Section 3 - Supplementary Disclosures for BIST.
Channels available for our employees to express their concerns on ethical issues:
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Actions in 2019
In 2019, we updated policies regarding third party relationships, gift and entertainment, conflict of interest. In 2020, we aim to ensure the enforcement of these policies and to provide unity of implementation for all countries.
We also established an integrity risk management program for CCI’s distributors to mitigate 3rd party risks, in cooperation with EBRD.
1st phase of the Program on ethics and compliance management is completed for beneficiary distributors. In 2020, we aim to complete the 2nd phase of the Program and enhance this initiative as a certificate program for the purpose of ensuring sustainable businesses.
During the reporting period, there were no legal actions against CCI for anti-competitive behavior, anti-trust or monopoly practices.
Training on Ethics
We continued to train all employees on Code of Ethics and anti-bribery rules in all CCI countries by using digital boards, internal social media platform to raise awareness; continued to review and update Code of Ethics and anti-bribery policy in line with TCCC practices. In 2019, we provided 1,840 human-hours of training to 1,776 employees. In 2020, we would like to sustain the awareness level through trainings and launch online trainings in the languages operating countries to ensure that all new employees start work with the integrated knowledge of Code of Ethics.
Awareness Raising on Ethics
Since 2013, our employees are trained on the revised Code of Ethics, the Code of Ethics Handbook and procedural provisions. The Code of Ethics Handbook and Guidelines for Handling Code of Ethics Matters are shared with our employees. All newly recruited employees are obliged to sign an acknowledgement form confirming that they have read the Code of Ethics and agree to abide by its provisions. All employees are required to periodically make this acknowledgement. Representatives and consultants assigned by CCI and third parties doing work on behalf of CCI may also obtain a copy of the Code and learn their obligations. In 2018, CCI celebrated Global Ethics Day.
CCI Integrity Risk Management Program (IRM)
IRM, launched in 2019 focuses on supporting SMEs in CCI’s supply chain on an individual basis in order to ensure that CCI distributors adopt internationally recognized practices in compliance and continue to improve their corporate governance skills. The Program is supporting the SME beneficiaries to become even more integrated in the supply chain, to adopt internationally recognized practices in compliance, to set up a compliance program, to conduct trainings and awareness programs on Code of Ethics and be compliant with CCI’s Code of Ethics. CCI intends to enlarge the Program in order to more distributors to benefit from this program.
Operating Context and Value Creation
Sustainability Focus