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• Speak Up Hotline
• Non-retaliation
• Examples
• Call Process

Speak Up Hotline

PepsiCo expects its employees, contractors, subcontractors, agents and their employees to promptly report on a confidential and/or anonymous basis any conduct or situation that she/he believes conflicts with PepsiCo's Code of Conduct or violates a local, state or federal law to their immediate supervisor, PepsiCo's General Counsel or General Auditor or through the PepsiCo Speak Up hotline. The number of this line is communicated within PepsiCo.

PepsiCo is committed to reviewing any such report in a prompt manner and taking remedial action when appropriate, and every affected employee is required to fully cooperate with any inquiry that results form any reported conduct or situation.

Non-retaliation

PepsiCo is committed to protecting the rights of those individuals who report these issues to PepsiCo. Any PepsiCo officer or employee who is found to have engaged in retaliation against any employee who has exercised his/her rights under PepsiCo's Code of Conduct or under applicable laws will be subject to appropriate remedial action. In addition, those individuals who violate applicable law may also be subject to civil and criminal penalties. Further, any contractor, subcontractor or agent who is found to have engaged in retaliation against any PepsiCo employee will be subject to appropriate action.

Examples

Reports to Speak Up include, but are not limited to:

• Discrimination, including sexual harassment
• Product tampering
• Employee mistreatment
• Substance abuse
• Falsifying company records
• Accounting irregularities
• Internal controls
• Questionable business practices
• Fraud or theft
• Criminal conduct
• Impermissible gifts
• Safety hazards

Call Process

Calls are received by a third party call center (the vendor). Each call is assigned a case number and forwarded to PepsiCo's Law Department for evaluation. Complaints or concerns addressed to the Audit Committee or Board of Directors go directly to the addressees.

The Law Department contacts the relevant internal department to review, research and resolve the case. Cases are researched principally by interviews, review of transactions or review of a situation. The case is investigated and resolved by the appropriate department (e.g. Internal Audit, Human Resources, etc.) with Law Department assistance if necessary.

If found that inappropriate conduct occurred, appropriate action is taken. The Law Department provides the vendor with status updates. The vendor communicates the status and resolution of the matter to the individual if he/she calls back. Updates may also be provided directly to the complainant if he/she chose to provide a name.

Reports of cases are summarized quarterly and sent to the Law Department, General Auditor and to the Senior Vice President Human Resources. In instances where inappropriate conduct occurred, reports are provided for the Disclosure and Audit Committees as part of quarterly Code of Conduct reporting.

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