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Responding department: Global Workplace Rights

Stock Exchange Symbol: (KO:US)

Also available: Coca-Cola response to our Myanmar Foreign Investment Tracking Project

Does your company have a publicly available commitment to respect human rights?

The Company has two human rights policies:

1) Human Rights Policy [link]; and

2) Supplier Guiding Principles [link]

How are human rights governed in your company?

The Public Issues and Diversity Review Committee of the Board of Directors, chaired by former U.S. Secretary of Labor Alexis Herman, has overall human rights policy oversight of the policies and their implementation.

Global Workplace Rights within human resources has primary responsibility for their implementation but other corporate functions have responsibility and accountability depending on the issues involved.

Rights related issues have historically been handled by human resources. As is stated in the first sentence of the Human Rights Policy: Respect for human rights is fundamental to the sustainability of The Coca-Cola Company and the communities in which we operate.

How are human rights managed within your company?

The Coca-Cola Company’s Respect for Human Rights Framework.

We were fortunate that, starting in 2005, we worked with Professor John Ruggie, the former UN Special Representative for Business and Human Rights, and his team in the development of a framework for respecting human rights.  In 2007, we joined the Business Leaders Initiative on Human Rights and later became a founding member of a successor organization, the Global Business Initiative on Human Rights as well as adopting the Company’s human and workplace rights policies.

In 2009, we began engaging with the Danish Institute on Human Rights to identify gaps in our global policies on human rights and to develop checklists to identify critical human rights issues. We endorsed the United Nations Guiding Principles on Business and Human Rights in May 2011 prior to their being adopted by the United Nations Human Rights Council.  The Guiding Principles establish a respect for human rights framework that has been endorsed by governments, business and civil society, starting with the primary duty of the state to protect its citizens from human rights harm.

This framework means that a company with some confidence can implement the Guiding Principles without any concern of any debate from stakeholders. It is the key touchstone for implementing our human rights policies, conducting human rights due diligence, and mitigating any human rights impacts if they occur. We expect our Company, our bottling partners and our suppliers to avoid causing, or contributing to adverse human rights impacts as a result of business actions.  This is reinforced through bottler and supplier training and our Supplier Guiding Principles assessments of bottlers and suppliers.

The Company utilizes numerous tools to identify human right impacts that have evolved and been refined over time. In 2007, our primary human rights due diligence tools were from three sources: (1) information provided by critical stakeholders such as the International Union of Foodworkers, Human Rights Watch, socially responsible investors and many others; (2) human rights audits conducted of the Company, bottling partners and supply chain; (3) issues raises by the Company’s human rights grievance mechanisms.

Today, the due diligence tool box is improved and continues to expand. We now conduct 2500 human rights audits with corrective action plans put in place, as needed, for the Company, bottling partners and suppliers each year and we have a Global Human Rights Scorecard reflecting overall compliance with meeting the Company’s standards.

Our goal for 2014 is 88 percent compliance well above the global compliance standard of 63 percent just a few years ago.  We have several human rights due diligence checklists ranging from plant siting to child labor to migrant and forced labor.  In 2011, we conducted an end-to-end value chain analysis from raw materials to end use to identify potential human rights impacts. As a result, we have established seven priority human rights issues with metrics that we report to the Board of Directors with 2020 goals on progress being made.

As a result of our investment in Myanmar in 2012, we conducted comprehensive human rights diligence in the country, and have filed two Responsible Investment in Myanmar Reports to the U.S. State Department that transparently set out our human rights due diligence process, what human rights impacts we found, what our mitigation strategies and results were, and what work still need to be done.

Learning from our Myanmar experience, we are beginning to conduct 28 country human rights impact assessments for our sugar supply chain on land rights, and child and forced labor to be completed by 2020.

The goal of expeditious corrective action has been a keystone to addressing human rights impacts whether it is brought to our attention by stakeholders, local events, the findings of our 2500 annual audits, or through social or print media.  Resolving and preventing abuses can be very complex and multifaceted particularly across an entire country or several countries, requiring the involvement of government, community leaders, and industry leaders to address the problem.

An Issue Resolution Example: Migrant workers and Holding of Passports

In early 2009, The Coca-Cola Company began auditing its suppliers in the Middle East and Gulf Region. This included the 19 independent bottling plants and 2 owned and operated by the Company. The countries covered included Bahrain, Kuwait, Oman, Qatar, United Arab Emirates and Yemen. In the first several assessments by third party auditors, it became immediately clear that almost all of the supplier facilities in the region were withholding the passports of migrant workers.

When asked why this was taking place, managers typically informed the auditors that this was either required by law, a customary practice or a requirement of insurance companies to safeguard against significant cash theft.  Our response to these audit findings was immediate. The Company commissioned a third party review of national laws and regulations of the countries concerned, and followed up with an immediate tour of the region and its suppliers by senior management from regional and global headquarters. We also engaged with the International Labor Organization to provide us advice on the issues. In 2008, in conjunction with the ILO, we had held our first global human rights Conference in Atlanta on forced labor. On the basis of this research, consultation with the ILO, human rights organizations and government officials in the region, the Company developed further guidance and implementation guidelines on the issue of passport retention. The guidelines were supported by face-to-face training involving the ILO, ongoing written communications and one-to-one follow-up with supplier relationship managers.

Once the new guideline had been distributed, a one-day seminar was held by The Coca-Cola Company for all of its suppliers in these countries. The seminar offered suppliers the opportunity to discuss the new policies, raise questions about them and address next steps in implementing operational changes. This consultative process and the clarity of the new guidelines led to agreement by suppliers and the implementation of changes. In order to sustain this improvement, The Coca-Cola Company maintains ongoing monitoring and has built the issue and guidelines into routine supplier communications and forums. Building on the success of this engagement, the Company has implemented a human rights due diligence migrant labor checklist and additional global polices and guidance to address risks of forced labor among migrant workers. The policies cover both the recruitment and the employment phase and require that:

• Work shall be represented in a truthful, clear manner and in the local language;

• Worker shall not pay recruitment fees (including transportation to and from host country); and

• Worker shall have access to personal identity documents.

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

The Company takes a robust and comprehensive approach to both global and local stakeholder engagement. Some examples. In 2005, we became the first North America headquartered company to establish an ongoing relationship with a global union federation--the International Union of Foodworkers. Twice a year, we hold meetings with the IUF and individuals from their affiliated unions to identify and address human rights impacts with ongoing discussions and remediation during the year.

Since 2008, we have hosted an annual human rights conference that brings in human rights NGOs, socially responsible investors, trade unions and others to discuss leading edge respect for human rights issues.

Since 2009, we have had a global-local strategy to address child labor in agriculture. Key to the success of this strategy has been both global and local stakeholder engagement. Beginning in 2014, we have initiated country studies in 28 countries to identify whether there is forced labor, child labor or land rights issues in our agriculture issues. A key component of these studies is local interviews with relevant experts and civil society stakeholders.

Another example of our approach to stakeholder engagement can be found in our Responsible Investment in Myanmar Reports, which are posted on the U.S. embassy in Rangoon's website: [link]. See also: [link]

Priority human rights issues: What are some of the priority human rights issues for your company?

The company selected the following from a check list:

  • Health (including environmental health, workplace health & safety)
  • Workplace diversity / non-discrimination
  • Forced labour and human trafficking (including in supply chains)
  • Operations in conflict zones
  • Sexual harassment
  • Access to water
  • Freedom of association and trade union rights
  • Transparency in payments to governments / responsible tax practices
  • Women
  • Racial and ethnic minorities
  • Children (including child labour)
  • Indigenous peoples
  • Migrant workers

Actions on forced labour and human trafficking

In 2014, we began conducting country level human rights due diligence studies on forced labor, child labor and land rights that will eventually encompass 28 countries by 2020.  We have Board of Directors metrics for these studies, including remediation metrics.  We also have several human rights due diligence checklists on a number of these issues, including migrant labor, child labor, land and water rights in plant siting, promotional item procurement, for example, that are implemented locally in the 207 countries in which we operate.  As mentioned previously, we have a global-local strategy to address and mitigate human rights impact where it exists.  See also: [link]

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

We make extensive use of digital media to communicate internally and externally on our human rights commitments. In addition, we have a number of events such as our human rights conferences: [link] - and annual celebration of human rights day on December 10th.

Each year, we have a number of well known human rights experts, such as Mary Robinson, John Ruggie and others, publish their human rights opinion on our Company website.  See, e.g., [link]; [link].

Since 2007, we have had over 40 human rights events for Coca-Cola associates that bring in human rights thought leaders such as President Jimmie Carter, John Morrison, Auret Van Heerden, a number of International Labor Organization officials, and members of Professor John Ruggie's UN Guiding Principles team.

Annually, the Company publishes a Sustainability Report that contains a Human and Workplace Rights section.  See, e.g., [link]. On the Supplier Guiding Principles section of our human rights website, the reader can find five country sugar studies on human rights impacts and issue guidance on HIV-AIDs, Migrant Labor, Land Rights and Pregnancy Testing issues. See: [link].

On the Addressing global issues section of the website, the reader can also find our Hours of Work guidance and the El Salvador Child Labor case study.  See: [link].

Our Responsible Investment in Myanmar Reports documenting our human rights due diligence and remediation can be found at: [link].

What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

There are a wide variety of grievance procedures and access to remedy mechanisms. These include:

  • The EthicsLine, www.KOethics.com, or by calling the country’s toll-free Ethics Line
  • Human Resources
  • Strategic Security
  • Independent third party assessments of suppliers' and bottlers’ compliance with the SGP Due Diligence Processes and Checklists
  • IUF Dialogue and Bi-Annual Meeting Process
  • Consumer inquiry mechanisms
  • Journey (TCCC’s internet site)
  • Via External Stakeholders

Each grievance is promptly investigated and responded to.

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

In 2006, we became a participant in the UN Global Compact and in 2011 in the UN Global Compact LEAD program.

We were actively involved in the Business Leaders Initiative on Human Rights before it sunset in 2009. In 2009, we were a founding company of the Global Business Initiative on Human Rights and continue to play and active leadership role. In 2009, we joined AIM-PROGRESS, a coalition of companies in the fast moving goods industry and have been one of its vice chairmen.

In 2012, we became a participant in The Shift Project, which is a business learning environment on implementation of the UN Guiding Principles on Business and Human Rights. In 2013, we were a founding company for the Global Business Coalition Against Human Trafficking and maintain an active leadership role. In 2013, we joined the UN Global Compact Child Labor Platform to address child labor issues.

Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.

We have had since 2005 five baseline strategies to identify and mitigate human rights risk: (1) Early issue identification and expeditious resolution of issues (2) Defining what the Company stands for (3) Engaging stakeholders and critics proactively (4) Global alignment of human and workplace rights and labor strategies across the business system and (5) Branding the Company internally and externally as respecting human rights.

For the last decade, we have worked very hard to implement and demonstrate respect for human rights. We have found that the “Golden Triangle” of the private sector, government and civil society has been especially important to identify best practices, build tools, devise global strategies, and develop local solutions to complex local problems. Above all, we have come to appreciate that implementing respect for human rights does not occur over night but requires a sustained, step-by-step, concentrated focus over many years—a journey that will never end. In particular, it requires the attention of the Board of Directors and senior executive commitment.

We were fortunate that, starting in 2005, we worked with Professor John Ruggie, the former UN Special Representative for Business and Human Rights, and his team in the development of a framework for respecting human rights. In 2009, we began engaging with the Danish Institute on Human Rights to identify gaps in our global policies on human rights and to develop checklists to identify critical human rights issues. We endorsed the United Nations Guiding Principles on Business and Human Rights in May 2011 prior to their being adopted by the United Nations Human Rights Council. The Guiding Principles establish a respect for human rights framework that has been endorsed by governments, business and civil society, starting with the primary duty of the state to protect its citizens from human rights harm. This framework means that a company with some confidence can implement the Guiding Principles without any concern of any debate from stakeholders. It is the key touchstone for implementing our human rights policies, conducting human rights due diligence, and mitigating any human rights impacts if they occur.

We expect our Company, our bottling partners and our suppliers to avoid causing, or contributing to adverse human rights impacts as a result of business actions. We have several human rights due diligence checklists ranging from plant siting to child labor to migrant and forced labor. In 2011, we conducted an end-to-end value chain analysis from raw materials to end use to identify potential human rights impacts. As a result, we have established seven priority human rights issues with metrics that we report to the Board of Directors with 2020 goals on progress being made.

As a result of our investment in Myanmar in 2012, we conducted comprehensive human rights diligence in the country, and have filed two Responsible Investment in Myanmar Reports to the U.S. State Department that transparently set out our human rights due diligence process, what human rights impacts we found, what our mitigation strategies and results were, and what work still need to be done. Learning from our Myanmar experience, we are beginning to conduct 28 country human rights impact assessments for our sugar supply chain on land rights, and child and forced labor to be completed by 2020.

What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?

Implementing respect for human rights is not as simple as flipping a switch.  It requires a holistic, step by step process that is immensely complicated to implement across 207 countries and deep into the supply chain.  A platform to share human rights due diligence tools and case studies would be immensely valuable.