This Code contains general requirements applicable to all suppliers to Gifts, Meals and Entertainment

The Coca-Cola Company. Particular supplier contracts may contain more

Employees of The Coca-Cola Company are prohibited from accepting anything
specific provisions addressing some of these same issues. Nothing in this
more than modest gifts, meals and entertainment from suppliers. Ordinary
Code is meant to supersede any more specific provision in a particular
business meals and small tokens of appreciation such as gift baskets at
contract, and to the extent there is any inconsistency between this Code and
holiday time generally are fine, but suppliers should avoid offering Coca-Cola
any other provision of a particular contract, the other provision will control.
employees travel, frequent meals or expensive gifts. Gifts of cash or cash
equivalents, such as gift cards, are never allowed. When providing services
to the Company or otherwise when acting on the Company’s behalf, supplier’s
Conflicts of Interest
employees are subject to the same limits described in this section when
Employees of The Coca-Cola Company should act in the best interest of offered gifts, meals or entertainment by Company’s customers, suppliers,
the Company. Accordingly, employees should have no relationship, or other business partners.
financial or otherwise, with any supplier that might conflict, or appear
to conflict, with the employee’s obligation to act in the best interest of
The Coca-Cola Company. For example, suppliers should not employ or Protecting Information
otherwise make payments to any employee of The Coca-Cola Company
Suppliers should protect the confidential information of The Coca-Cola
during the course of any transaction between the supplier and the
Company. Suppliers who have been given access to confidential information
Company. Friendships outside of the course of business are inevitable and
as part of the business relationship should not share this information with
acceptable, but suppliers should take care that any personal relationship
anyone unless authorized to do so by The Coca-Cola Company. Suppliers
is not used to influence the Coca-Cola employee’s business judgment.
should not trade in securities, or encourage others to do so, based on
If a supplier’s employee is a family relation (spouse, parent, sibling,
confidential information received in the course of providing services to or
grandparent, child, grandchild, in-law, or same or opposite sex domestic
acting on behalf of The Coca-Cola Company. If a supplier believes it has
partner) to an employee of The Coca-Cola Company, or if a supplier has
been given access to The Coca-Cola Company’s or any other third party’s
any other relationship with an employee of The Coca-Cola Company that
confidential information in error, the supplier should immediately notify its
might represent a conflict of interest, the supplier should disclose this fact
contact at the Company and refrain from further distribution of the information.
to The Coca-Cola Company or ensure that the Coca-Cola employee does so.

Similarly, a supplier should not share with anyone at The Coca-Cola Company
information related to any other company if the supplier is under a contractual
or legal obligation not to share the information.

Code of Business Conduct for

Suppliers to The Coca-Cola Company

This document is applicable to suppliers, including contingent workers, of

The Coca-Cola Company and its majority-owned subsidiaries. Use of the
terms “The Coca-Cola Company” and “the Company” in this document refers
to The Coca-Cola Company or one or more of its subsidiaries, whichever
is relevant to the particular supplier relationship. The Coca-Cola Company
expects that all of its suppliers will comply with the law and act ethically
in all matters. This Code of Business Conduct for Suppliers sets forth our
expectations for doing business with our Company. Working together,
we can achieve great success by doing the right thing, with integrity.
Bribery Reporting Potential Misconduct
Suppliers acting on behalf of The Coca-Cola Company must comply with Suppliers who believe that an employee of The Coca-Cola Company, or
the U.S. Foreign Corrupt Practices Act and the UK Bribery Act, as well as all anyone acting on behalf of The Coca-Cola Company, has engaged in illegal
local laws dealing with bribery of government officials. In connection with or otherwise improper conduct, should report the matter to the Company.
any transaction as a supplier to The Coca-Cola Company, or that otherwise The supplier can contact the employee’s manager or The Coca-Cola
involves The Coca-Cola Company, the supplier must not transfer anything Company Ethics & Compliance Office at compliance@coca-cola.com, or
of value, directly or indirectly, to any government official, employee of a use the Company’s EthicsLine reporting service at www.KOethics.com,
government-controlled company or political party, in order to obtain any or call toll-free using the access codes that can be found on the EthicsLine
improper benefit or advantage. Suppliers may not give anything of value to a website. A supplier’s relationship with The Coca-Cola Company will not be
government official on the Company’s behalf (or in the course of interacting affected by an honest report of potential misconduct.
with government on the Company’s behalf) without prior written approval from
Company legal counsel, which can be obtained through the Supplier’s primary Question or concern?
contact/relationship manager at the Company. The Company also prohibits Log on to EthicsLine at www.KOethics.com
commercial bribery. Suppliers must keep a written accounting of all payments
(including any gifts, meals, entertainment or anything else of value) made on
behalf of The Coca-Cola Company or out of funds provided by The Coca-Cola
Company. Suppliers must furnish a copy of this accounting to The Coca-Cola
Company upon request.

Business and Financial Records

Both the supplier and The Coca-Cola Company must keep accurate records
of all matters related to the supplier’s business with The Coca-Cola Company.
This includes the proper recording of all expenses and payments.
If The Coca-Cola Company is being charged for a supplier’s employee’s
time, time records must be complete and accurate. Suppliers should not
delay sending an invoice or otherwise enable the shifting of an expense to
a different accounting period.

© 2018 The Coca-Cola Company