Reporting a Violation Worldwide Code of Conduct PBG

Reporting a Violation

You should report an actual or potential violation of this Code to your Human Resources Manager, the PBG Business Ethics Line, the PBG Office of Compliance, or the designated person for your international location (see below).

Violations or concerns related to accounting, internal control, or auditing matters may be reported by calling the PBG Business Ethics Line or by writing to the PBG Office of Compliance. If you are located outside the U.S. and Canada, you may also contact your designated person: in the Russian Federation, the Organization Capabilities Manager; in Greece, the Chief Financial Officer; and in Spain, Turkey and Mexico, the Controller. You should try to provide enough information for PBG to investigate properly. While the report will be considered confidential, there may be instances when more information is required to complete an investigation. In those cases, you will be contacted, but again, the contact will be handled with discretion and confidentiality. Reports made to the PBG Business Ethics Line or the PBG Office of Compliance may be made anonymously.

Each employee, director, and officer is required to cooperate fully with internal investigations of actual or potential violations of the Code.

PBG will not tolerate retaliation against any employee who contacts the PBG Office of Compliance, the PBG Business Ethics Line, or his or her designated person with a concern or violation report in good faith. Open communication without fear of retribution is vital to the successful implementation of the Code.

QOne of my coworkers told me that she thinks her manager included personal meals on his Travel & Entertainment report as business expenses. Should I report this to someone?

AYes. You are obligated to report any potential violations of the Code of Conduct, Company policy or the law. You should report this information to your Human Resources Manager. If you are uncomfortable doing so, you should call the PBG Business Ethics Line to report this potential violation. You can make your report anonymously.

QWho answers the phone on the PBG Business Ethics Line?

AThe PBG Business Ethics Line is administered by an outside service provider. The information obtained during the call is communicated to the PBG Office of Compliance, which provides oversight to ensure that all reported concerns are investigated. Callers should provide detailed and specific information during the call so PBG can properly and thoroughly investigate the matter.

QWho investigates the concerns reported to the PBG Business Ethics Line?

AThe PBG Office of Compliance reviews the call summary and assigns the call to the appropriate PBG department for investigation and resolution. For example, employee relations matters are generally investigated by the Human Resources Department. Accounting, Internal Control or Auditing matters are generally investigated by Internal Audit.

QWhat if I want to stay anonymous?

AWhile it is helpful for PBG to be able to contact the caller for additional information, employees can report concerns anonymously. When making an anonymous report to the PBG Business Ethics Line, you should provide specific and detailed information about your concern. As an anonymous caller, you will be asked to call back on a future date in case PBG needs more information to complete its investigation.

QIf I report a concern, will it be held against me?

APBG will not tolerate retaliation against any employee who calls the PBG Business Ethics Line or contacts the PBG Office of Compliance or designated person in good faith with a concern or violation report.